Fair Seas Ireland’s response to:
Public Consultation on Trawling Activity Inside the Six Nautical Mile Zone and the Baselines
Fair Seas is a group of Ireland’s leading environmental non-governmental organisations and networks seeking to protect, conserve and restore Ireland’s unique marine environment.
Fair Seas partners: BirdWatch Ireland, Coastwatch, StreamScapes, Irish Environment Network, Irish Whale and Dolphin Group, Irish Wildlife Trust, Sustainable Water Network.
Submitted 09/04/2024
Summary
Fair Seas recommends that the Minister progresses option 3 ‘All sea-fishing boats over 18m in length overall excluded from trawling inside the six nautical mile zone and baselines’ as soon as is feasible at a national level.
We believe this fisheries management option gives the greatest environmental and conservation benefit while also preserving and potentially increasing the social, economic and cultural positives of the inshore fishing sector and coastal communities in Ireland.
General comments
Fair Seas welcomes the opportunity to respond to the public consultation on trawling activity inside the six nautical mile zone and the baselines. Fishing activity is one of the most culturally, socially and economically important and widespread commercial activities taking place within Ireland’s 6nm zone. Therefore, any efforts taken to ensure this activity is conducted sustainably, fairly, and in a manner which safeguards biodiversity is warmly welcomed.
It is worth highlighting that improving the management of fishing activity in Ireland’s inshore waters will not only contribute to the delivery and implementation of the Sea Fisheries and Maritime Jurisdiction Act 2006, but a long list of other EU and nationally derived laws of which Ireland’s implementation is currently falling short. This list includes Ireland’s obligations under the;
- EU Common Fisheries Policy (1380/2013),
- EU Marine Strategy Framework Directive (Directive 2008/56/EC),
- EU Birds Directives (Directive 2009/147/EC),
- EU Habitats Directive (Council Directive 92 /43 /EEC),
- Ireland’s Maritime Area Planning Act 2021, and,
- United Nations’ Sustainable Development Goal 14.
Furthermore, while neither of the forthcoming Nature Restoration Law or Ireland’s Marine Protected Area law are as of yet on their respective Statute Books at EU or national level, it is apparent that each would also benefit from improved management of fishing activity within Ireland’s 6nm limit. This is particularly relevant as Ireland’s own Marine Strategy Framework Directive (MSFD) assessment in 2020 concluded that the most significant man-made pressure on biological diversity in Ireland’s maritime area, including inshore waters is “the extraction of fish and shellfish…(both commercial and non-commercial species) and associated disturbance introduced by human fishing activity”.
Fair Seas believe that a continuation of the status quo in how fishing activity is managed within Ireland’s 6nm limit, with very few restrictions on large fishing vessels including within the baselines, is clearly not the most sustainable way to manage our coastal waters from either a social, economic or environmental perspective. This is most decisively demonstrated by the fact that the inshore fishing industry itself supported a change to how trawling activity was managed in Ireland’s inshore waters when the trawling ban proposals were first offered for public consultation in 2018.
Subsequently, in an unprecedented response to 2020 decision by Ireland’s High Court to overturn the ban on fishing vessels larger than 18m from operating within six nautical miles of the coast, 15 fishing and environmental organisations came together for the first time to call on Ireland’s Minister for Agriculture, Food and the Marine to take the steps necessary for the ban’s reinstatement. The joint letter was signed at the time by Birdwatch Ireland, the National Inshore Fishermen’s Association (NIFA) and National Inshore Fishermen’s Organisation (NIFO), An Taisce, Cork Environmental Forum, Cork Nature Network, Coomhola Salmon Trust, Environmental Pillar, Friends of the Irish Environment, Irish Seal Sanctuary, Irish Whale and Dolphin Group, Irish Wildlife Trust, Oceana, Seas at Risk, Sustainable Water Network (SWAN) and Our Fish.
According to the signatories of the letter, the collaborative action between a large segment of the fishing industry and environmental groups highlighted how the proposed shift in fishery management policy in Ireland’s inshore waters in 2018 “was one of the most important fisheries policy shifts in the history of the Irish state and was broadly welcomed as being the right decision from a social, economic, environmental and a social justice perspective”, and was backed by expert analysis by the Marine Institute and the Bord Iascaigh Mhara at the time. Fair Seas coalition partners feel strongly that six years later, this is still one of the most important fisheries management changes brought forward by the Irish Government.
As highlighted in the Marine Institute assessment, ‘a high proportion of the areas inside the baselines and inside 6nm, is designated as Special Areas of Conservation and Special Protection Areas under the EU Habitats and Birds Directives’. These sites include many of Ireland’s most diverse marine habitats including large areas of reed, coarse sediments, sands and muds, each supporting different fish species and assemblages of marine organisms. It is also rightly highlighted in consultation documents that ‘fishing can have significant effects on local ecology and ecosystems’ and that ‘by changing the fishing access arrangements in respect of sea-fishing boats trawling inside the six nautical mile zone, policy options could potentially address some of these impacts on ecosystems’.
Therefore, Fair Seas recommends that the Minister progresses policy Option 3 ‘All sea-fishing boats over 18m in length overall excluded from trawling inside the six nautical mile zone and baselines’. We believe this fisheries management option gives the greatest environmental and conservation benefit while also preserving and potentially increasing the social, economic and cultural positives of the inshore fishing sector and coastal communities in Ireland.
Fair Seas echo the point made by our coalition partners the Irish Whale and Dolphin Group (IWDG) that ‘The unregulated fishing of ecologically vital forage fish such as sprat, pilchard, anchovy and sandeel has caused a critical removal of biomass from the inshore areas around Ireland. These forage fish provide a fundamentally important trophic link between zooplankton and whales, dolphins, porpoises, seabirds and predatory fish. These forage fish populations are dynamic, fast-growing, and vulnerable both to overfishing and shifting temperatures caused by climate change’. Prohibiting sea-fishing boats over 18m in length from performing trawling activities within the 6nm limit would in Fair Seas view deliver the maximum conservation benefit by reducing fishing pressure in the area, while also preserving and re-prioritising opportunities for the smaller inshore fleet.
Similar arguments may be made for progressing Option 4 in the consultation documents that ‘All sea-fishing boats over 15m in length overall excluded from trawling inside the six nautical mile zone and baselines’. However, we know from the consultation documents that there are only an additional 14 vessels in the 15-18m size class nationally. Banning these vessels from trawling activities within the 6nm limit could present a social and economic strain on the viability and success of the inshore fishing and local fishing communities, while only delivering a marginal conservation benefit over what is gained from Option 3 in which vessels over 18m are banned from trawling activities.
Fair Seas stresses the importance of due process and encourages the Minister to introduce policy Option 3 in a robust and legally defensible manner. However, it is also our view that it should be progressed as soon as is feasible at a national level, so that the environmental, societal and economic benefits of such a management measure can begin to accrue for biodiversity and the community as soon as possible. The introduction of such fisheries management measures for the inshore area have already been delayed by years. In that time, the health and condition of our environment has continued to decline. There must not be any further delays.
Fair Seas wishes the Minister the very best in this endeavour to improve fisheries management of Ireland’s inshore area.
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