Lobster Stock Management Consultation Report
Results from Consultation on Proposals
Report Name:
Lobster Stock Management Consultation Report
Prepared by:
Department of Agriculture, Food and the Marine
In partnership with Marine Institute, Bord Iascaigh Mhara & Sea-Fisheries
Protection Authority
Stage:
April 2014 - Publication
Contents
1.
Summary of Responses ................................................................................................................... 3
2.
Consideration of Alternatives Measures ........................................................................................ 6
3.
Stock Advice .................................................................................................................................... 7
4.
Recommendations .......................................................................................................................... 7
5.
4.1
Illegal fishing should be tackled as a priority .......................................................................... 7
4.2
Introduce a Maximum Landing Size of 127mm ...................................................................... 7
4.3
Promote consumer awareness of Irish lobster ....................................................................... 7
4.4
Strengthen V-Notching Programme ....................................................................................... 8
4.5
Explore restocking potential of hatcheries through pilot project .......................................... 8
Appendix ......................................................................................................................................... 9
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1. Summary of Responses
It is important to bear in mind the purpose of consultation is to gather views to inform decisionmaking. Fisheries management decisions must take account of fishermen’s knowledge in addition to
expert scientific and socio-economic advice to achieve sustainability for the fish stocks, the
communities who depend on them and the marine environment. A range of alternative measures,
including non-regulatory measures, were received which suggests that the fishing industry
acknowledges the need for improved management and is open to further discussion on how best to
achieve improved recruitment for this stock.
Over 90% of the 258 submissions were from fishermen. A review of the licences of the participants
illustrates a broad range of fishing gear, including many small polyvalent fishing boats who use a
number of gear types and a cohort of potters registered under the Polyvalent Potting segment.
There was strong participation from the Western seaboard with the highest volume of submissions
coming from Cork to Donegal collectively.
Submissions were also received from fishermen’s associations including v-notching co-ops and the
producer organisations. A small number of shellfish buyers/processors also made submissions.
It is important to note that some submissions recommended more than one approach, including one
or other of the proposed measures and alternatives.
Proposal
Introduce a maximum landing size of 127mm (1.3kg)
Increase the minimum landing size from 87mm to
90mm
Do neither because (i) Existing measures are
adequate
Do neither because (ii) Alternative measures should
be put in place
Table 1.
Count
% of fishermen
57
24.2%
39
16.5%
86
36.4%
54
22.9%
Views expressed by fishermen
Table 1 illustrates that neither of the proposed options received overwhelming support from
fishermen. There was a small preference for the introduction of the maximum landing size over the
minimum landing size. Commentary submitted by a number of participants identified that an
increase to the Minimum LS would cause financial hardship due to the market demand for lobsters
of that size. This view was also supported by a number of buyers. By contrast, offshore fishermen
who catch lobster further from shore expressed concern that the introduction of a Maximum LS
would unfairly impact on their catch. A number of submissions identified that stock features and
catch locations varied by location and suggested separate local/regional measures should be
developed.
The largest view submitted (36.4%) was that neither of the proposals should be adopted and that
the existing measures are adequate; however it is worth noting that a number of fishermen who
expressed this preference still indicated that they would support alternative measures such as
compulsory v-notching (11% of all fishermen), effort controls such a pot limits (5.9%), improved
monitoring and enforcement (5.5%), a prohibition on catching/landing/selling berried females (3.4%)
and controls on recreational/leisure fishing for lobster (3.4%). Therefore, of the 36.4% who
indicated that existing measures are adequate, it is apparent that many recognise that changes,
other than to landing sizes, may be needed.
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Lobster Co-operatives & Associations
The following co-operatives/fishermen’s associations participated in the consultation:

North West Kerry

Union Hall

Cork Harbour

Erris Lobster Conservation & Restocking

Cuman Iascairi Choss Costa Iorrais

Inis Oirr ‘local group’ & Iascairi Cois Costa Inis Oirr

Galway Bay Inshore

Clare Lobster
The common proposal raised by the co-operatives was for increased and/or mandatory rates of vnotching to be established. A number of the co-operatives raised similar alternatives to those raised
by fishermen themselves (see section Error! Reference source not found.). Some cited the difficulty
in achieving a consensus of views.
Irish South and West PO
The ISWPO represents the area from the Shannon Estuary to Wexford Harbour. Membership
includes 90 vessels; 10-15 potting boats in west Cork and south Kerry.
Regarding the proposals; IS&WPO recommended:
1. prioritising the introduction of the Max LS
2. the Min LS a NOT priority as 87-90mm lobsters are in high demand from market.
Additional options recommended to be pursued through further consultation:
a) Amendment of the minimum and maximum landing sizes for Lobster.
b) Mandatory inclusion in stock conservation via formal inclusion and verified records of
lobster live returns/v-notching through the national BIM V-notching and Lobster
Conservation Scheme.
c) A ban on the landing, or retention on-board, of female lobster in the ‘berried’ state.
d) A phase-in of mandatory escape gaps in lobster pots, designed to allow for the real time
escape of captured lobsters below the minimum landing size.
e) Future review of effort management via the introduction of maximum pot limits for vessels
of different length classes.
f) Management and regulation of recreational fishing interests by way of maximum pot limits,
identification tags on recreational pots and maximum daily and weekly bag limits.
Irish Fish Producers Organisation
IFPO recommended introducing a Max LS of 127mm but with a weight of 2kg.
Additional proposals:
1. Introduce a maximum landing size to 127mm but the weight should be increased to (2 kg)
2. Logbooks should be mandatory for all pot fisheries
3. No recreational pot fishery should be allowed in Ireland
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4. A mandatory 10% of all females caught over a 12 month period (June to June) to be V
notched regardless of vessel size. This to be supervised by BIM/SFPA to ensure compliance.
Those not engaged in the lobster fishery in the previous 12 months to purchase and V notch
under supervision a minimum of 20kg of female lobster
5. A pot restriction to apply for inshore vessels under 10m in length
6. A pot restriction to apply to vessels 10m to 12m in length
7. A pot restriction to apply to vessels 12 to 15 m in length
8. Stronger sanctions for fish buyers/agents found with V notched or undersized lobsters
Killybegs Fishermen’s Organisation
KFO recommend re-visiting the BIM Shellfish Management Framework as a first step so that regional
management with input from stakeholders could form the basis of future management.
“In recent years fishermen have developed a very mature attitude to issues of sustainability and
quality; the atmosphere for regional management could now be more acceptable and such
management would come with fewer compliance issues.”
The activities of recreational fishermen were described as “a growing problem” around the coast,
particularly in the context of increasing the minimum landing size. Concerns were also expressed
about the challenge of cross-border management if parallel measures are not in place in Northern
Ireland with specific consideration of impact on the marketing sector.
Buyers
A small cohort of buyers presented submissions in the consultation. Four of the buyers felt that vnotching should be compulsory. One buyer supported the proposal to raise the minimum landing
size (despite others citing demand for lobsters of this size) and two buyers supported the proposal to
introduce a maximum landing size. Two buyers proffered support for a ban on landing/sale of
berried females.
One buyer also supported the introduction of further stock management measures in a detailed
submission. Those additional measures were mirrored by the Irish South and West proposals
described above.
Other
One NGO, the Federation of Irish Salmon & Seatrout Anglers, made a submission recommending “no
decision be made on lobster fishing regulations until after an in-depth habitat study is completed as
there is a lack of scientific knowledge at present.”
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2. Consideration of Alternatives Measures
A wide range of alternative proposals were suggested in the submissions. Of these, some were
made in addition to, rather than in lieu of, the proposed changes in landing size. A summary of the
most recommended alternatives is presented in Table 2.
Total
Fishermen
Others
Compulsory or increased v-notching
89
83
6
Introduce controls on non-commercial pot fishing
43
38
5
Ban on landing/sale of berried females
46
38
8
Improve enforcement of controls
43
41
2
Introduce pot controls (limits)
40
35
4
Introduce seasonal controls
20
20
0
Alternative Suggestions
Table 2.
Most Recommended Alternatives
The results in Table 2 and Table 3 illustrate that there would be more support for compulsory or
increased v-notching, with many seeing the need to make it mandatory in order to achieve
improved participation. At present, participation in v-notching is voluntary but with legal protection
for the v-notched stocks. A mandatory programme, while potentially positive for stock recruitment,
could pose validation and cost-recovery challenges which would need to be carefully addressed at
design stage. It is unlikely however that more v-notching alone will significantly increase
recruitment of stock to the fishery.
Alternative Suggestions
No.
%
Compulsory or increased v-notching
83
35.2
Introduce controls on recreational lobster fishing
38
16.1
Ban on landing/sale of berried females
38
16.1
Improve enforcement of controls
41
17.4
Introduce pot controls (limits)
35
15.3
Introduce seasonal controls
20
8.5
Table 3.
Fishermen’s Support for Alternatives
A ban on landing/selling berried females (with eggs attached) was suggested by a significant
number of participants. Such a ban could be positive as breeding stock would be put back and this
could enhance recruitment. Implementation of the ban would not be without challenges though as
the eggs can be scrubbed off by unscrupulous operators (a few submissions suggested this practice
takes place already). A ban on berried females could also lead to significant catch declines,
particularly as eggs are carried for up to 11 months, with financial consequences for the fishermen
affected. Some suggested that the ban could be implemented by v-notching berried females. This
would also have financial consequences for fishermen as the female could not be fished again until
the v-notch had grown out (2-3 years) but offset by the present v-notching scheme which funds up
to 55% of the market value.
Management of non-commercial fishing was identified by a significant number as a challenge to
effective management of the lobster stocks. Many fishermen expressed views that recreational
fishing was ‘out of control’ with too many pots being deployed and a lack of awareness of the catch
rules. Others suggested that illegal sale of catch was taking place, including undersize stocks,
indicating that ‘recreational’ fishing may be a cover being used to fish illegally at a commercial level
in some locations. Not surprisingly then, there were a number of calls to Improve enforcement of
controls; over 17% of fishermen specifically suggested that more visible monitoring and
enforcement is warranted. Some submissions also recommended that steps be taken to generate
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awareness among the fishing, tourism and catering sectors of the rules regarding sale of catch and
the minimum landing size.
Recommendations were also made to control fishing effort; either by seasonal closures (8.5% of
fishermen) or by pot limits (15.3% of fishermen). With regard to seasonal closures, many suggested
over-winter closures which would see the fishery shut at the time when market prices are at the
highest. Considering that lobsters are generally sold and transported live, a closure during the
period of highest financial return is unlikely to be universally supported. The introduction of pot
limits, which was also supported by two of the Producer Organisations, could be a measure worth
further consideration with the industry as a long term measure given its benefits in achieving
sustainability. An important consideration in the potential application of pot limits is the need to
have controls on potting by non-commercial fishermen.
3. Stock Advice
The most recent stock advice from the Shellfish Stocks and Fisheries Review 2012 by the Marine
Institute and BIM notes that the egg production level for the stock is estimated to be below
generally accepted limit reference points. This advice comes with caveats on the limitations of
existing landings, catch and effort data for this fishery.
The stock advice recommends the introduction of the maximum landing size of 127mm to support
the existing conservation measures. This recommendation is aimed at protecting these lobsters with
large reproductive potential and protecting “some of the investment that has been made through
the national v-notch programme since 2002”. Data from the catch and effort indicators from data
collection initiatives conducted by MI and BIM indicates that this would affect a small percentage of
current catch compositions. The measure would be less economically penalising than other
alternatives, although it may affect some boats fishing offshore catch larger stock.
4. Recommendations
4.1
Illegal fishing should be tackled as a priority
The consultation highlighted concerns about illegal fishing and excessive catch of lobster catches
from non-commercial fishermen. The lack of controls on recreational/leisure pot fishing is seen as
providing a cover of legitimacy for illegal fishing. The potential prevalence of illegal fishing of this
stock poses immediate challenges to the success of any stock management measures and therefore
should be addressed as a priority.
A review of the existing legislation for this stock will be undertaken by the Department to ensure
that the penalties for any person found in non-compliance provide sufficient deterrent effect. The
SFPA has indicated that it will examine its policing strategy for the lobster fishery in response to the
concerns raised in the consultation.
4.2
Introduce a Maximum Landing Size of 127mm
In view of the stock advice and the need to ensure long-term sustainability for one of the most
economically important inshore stocks, a prohibition on landing lobsters of 127mm should be
introduced. During the first 2 years of the prohibition, the oversize lobsters could be v-notched and
financial assistance provided to offset the loss to fishermen affected in the transitional period
through the v-notching scheme.
4.3
Promote consumer awareness of Irish lobster
An important deterrent for illegal catch can come from the market place itself. Some fishermen
reported seeing undersize catch, berried females and even v-notched lobsters for sale either by
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wholesalers or the hotel/catering industry. SFPA has recognised the value of promoting awareness
of seafood sustainability through its Consumer Advice and Fisheries Information Notices, including
its Fisheries Information Notice 07-2013 Lobster fishing and conservation efforts. BIM should work
with Bord Bia and the industry to explore the potential for marketing strategies, such as labelling, to
assist consumers and to differentiate Irish pot-caught lobster in the market place.
4.4
Strengthen V-Notching Programme
V-notching is regarded as a very successful model for encouraging a positive attitude to stock
management. The rate of financial assistance provided is currently 50% of the market price of the
lobster to individuals and 55% for those participating in groups. As a starting point, an increase in
the rate of funding should be provided to incentivise participation.
There are many variations on the existing programme which could be implemented (e.g. compulsory
rates of v-notching per boat, compulsory v-notching of all berried females or v-notching of large
lobsters, etc.). In view of the voluntary nature of the current scheme, a review initiative to enhance
the programme should be industry-led and undertaken via the Inshore Consultative Forum.
4.5
Explore restocking potential of hatcheries through pilot project
The potential for lobster hatcheries to support wild stock levels was raised during the consultation.
In preliminary considerations, BIM and the Marine Institute have raised concerns regarding the
efficacy of hatcheries including high operating costs and difficulties in attracting investment on a
commercial basis. Direct re-stocking measures such as hatcheries cannot avail of EU supports under
existing rules. In the current fiscal circumstances it is important therefore to validate the value of
tools such as hatcheries before considering their wider application.
While Ireland has some mixed experience of lobster hatcheries, they are well regarded in certain
areas (e.g. Orkney, Scotland). In that regard, BIM and the Marine Institute should review the Irish
and international experience of lobster hatcheries with a view to establishing a pilot project to
review the potential restocking benefits of a best-practice hatchery.
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5. Appendix
How the consultation was conducted
The lobster and shrimp consultation documents were published concurrently online using the
Department’s website to accommodate public participation. Submissions were accepted by post
and email. An online survey was also trialled and attracted almost 25% of the responses.
In order to target fishermen directly, copies of the consultation documents were made available at
the local offices of the marine agencies, including BIM, SFPA and the Marine Institute. A very small
number of fishermen phoned the Department to have their views recorded, though all were
encouraged to put their views in writing.
Advertisements were also placed in marine trade press, both in print and online.
How were the results reviewed
All submissions were required to provide contact information for validation purposes. Fishermen
were asked to provide information on their fishing boat in order to verify that submissions were
representative of legitimate commercial fishermen.
In recognition of the local nature of commercial pot fishing and for practical purposes, the
submissions were recorded on the basis of the county in which each respondent resides. The views
of fishermen on the proposals to change the landing sizes were recorded as well as any other
comments or views which they chose to express either in writing or through follow-up
communications (including by phone).
A preliminary review of the results was presented by DAFM to the marine agencies for commentary.
Following feedback discussions, the consultation report was concluded by DAFM taking account of
advice received and presented to the Minister.
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