Submissions received from the public consultation on a proposal to increase the allocation to the Celtic Sea Herring Sentinel Fishery for 2016 Proposal



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Submissions received from the public consultation on a proposal to increase the allocation to the Celtic Sea Herring Sentinel Fishery for 2016

Proposal: The Minister is considering an increase in the allocation to the Celtic Sea Herring Sentinel Fishery for 2016. A once off increase of 500 tonnes for this fishery for 2016, on an exceptional basis, is proposed

Public Consultation: A public consultation process on the proposal ran from 11th July to 26th July, which requested all interested stakeholders to submit their views electronically or by post. A total of 22 submissions were received in this period plus 70 individual signatures were received from members of the Inshore fishing sector.

Submissions: All submissions received are in support of an increase in the allocation to the Celtic Sea Sentinel Fishery for 2016. Submissions received from the following stakeholders are attached at Appendix 1.

Killybegs Fishermens Organisation

Irish Fish Producers Organisation

Dunmore East Fishermen’s Co-op

Alex Crowley MFV Emma Lou

Michael Byrne MFV Rachel D

Michael & Angela Crossan MFV Donna Julie II

Padraic and Gerard McDonagh MFV Roisin Bairbre

Elizabeth O Toole MFV Sunrise II

Erris Inshore Fishermens’s Association

NWRIFF

Patirck Downes MFV Ocean Pearl



Patrick Myler MFV Southern Sun

Padaig Dillane MFV Elsie Louise

Irish South and East Fish Producers Organisation

National Inshore Fisheries Forum

Iveragh Fishermen’s Co-op Ltd

Nicholas Murphy MFV Starlight

Stephen Burke MFV Boy River

Daryl O’Donnell MFV Michelle

Joseph Whitty MFV Ellen Marian

Edward Fahy

Cian Daniels

Inshore Fishing Sector



Appendix 1

Killybegs Fishermens Organisation


I refer to the Minister’s proposal to increase the amount of herring allocated to the sentinel fishery by 500 tonnes for one year only, 2016.

I must state at the outset that the KFO has members fishing in both the Celtic Sea Main Fishery and the Celtic Sea Sentinel Fishery and as such I must represent both their interests in this fishery.

With this in mind the KFO can support an increase of 500 tonnes in the sentinel quota for one year only, 2016, on an exceptional basis.

Regards


Sean O’ Donoghue

Chief Executive


Irish Fish Producers Organisation


The IFPO supports the proposal by Minister Creed to increase the allocation in the Celtic Sea Herring Sentinel Fishery by 500 mt above the normal allocation for 2016 only. We appreciate this initiative as those prosecuting this fishery in 2015 we subjected to extremely challenging weather conditions and were not in a position to maximise their  respective fishing opportunities.

Kind regards,

Francis O’ Donnell

CEO


IFPO

Dunmore East Fishermen’s Co-op


Dunmore East Fishermen’s Co-Operative Society Ltd.

Tel: 051 383307 E-Mail defcoop@eircom.net Fax: 051 383446 Vat. Reg. No. IE 8J88277R

I would like to give my reasons why I support the Ministerial proposal for an increase in the Celtic Sea Herring Sentinel Fishery quota.

The hardships endured by the small boat sector, which is very weather dependant, during the prolonged period of bad weather last year has been well documented. The loss of income suffered by the boats could not be recouped in other fisheries later in the year due to quota restrictions, therefor an increase in the herring quota this year would help greatly alleviate some of the losses incurred and may encourage more boats to join the fishery.

The Herring fishing has historically given the local boats, and visiting boats from all around the country, a welcomed source of income at what would be an otherwise lean period for the fishing sector. The fishery not only benefits boats but also the local economy and the employment given by boats landing is much needed.

I hope the Minister and all involved will look favourably on an increase in the quota. 500 Tonnes is not a large amount of the overall quota but would be a huge benefit to the Sentinel Fishery.

Yours Sincerely

Maurice Glody

Manager

Dunmore East Fishermen’s Co-op


Alex Crowley MFV Emma Lou


To Whom it concerns,

I would support the proposal to increase the quota allocation available to the 2016 Celtic Sea Herring Fishery by 500 tons as a one off exceptional measure for 2016.


Alex Crowley Fisherman

Owner / Operator MFV Emma Lou T450


Michael Byrne MFV Rachel D


Good afternoon all. 

In relation to the proposed increase in the Celtic Sea Herring sentinel fishery increase for 2016 I welcome the suggestion and hope it not only is put through this year but for the future as well. 

I would also like to ask the question. Further to rumours there was word before the election that it was under consideration to have a Sentinel fishery for the North West herring,  is this going to be the case or will the Donegal boats have to steam to the south east coast, while there is ample herring in the inshore waters of Donegal?

I myself fish herring and sprat every year on the MFV Rachel D SO 976. 

Last year we had to leave Donegal Bay as there was no herring quota issued for 6 A south. Yet there was plenty of fish there. 

We also missed out on a very heavy sprat fishing as the herring and sprat mixed. 

The next question i want to ask is will the area of 6 A be joined as there seems no sense to have sub area? (6 A north and 6 A south) 

The fish migrate from area to area. To have sub areas is making life harder for small vessels. 

Thank you all for your time

Michael. 


Michael & Angela Crossan MFV Donna Julie II


Dear Sir/ Madam,
As owners of the vessel Donna Julie II, registered number SO394, we wish to state that we would agree with the proposed increase in the allocation for the Celtic Sea Herring sentinel fishery.

Our vessel is already booked into the 2016 CSH sentinel fishery and we intend to use our allocation.

Regards,

Michael & Angela Crossan


Padraic and Gerard McDonagh MFV Roisin Bairbre


I PADRAIC and Gerard Mc Donagh owners of the MFV Roisin Bairbre G777,would greatly appreciated if the quote of this fishery be increased.It is badly needed at this time of year special with the dropping in the Prawns Quote,Thanks in advance.

Elizabeth O Toole MFV Sunrise II


To whom it concerns,

I'm replying to the proposed increase of 500 ton to sentinel quota for winter 2016.

  An increase is very welcome indeed, we all as boat owners, skippers and crew were very badly affected in 2015 by bad weather.After an extremely harsh weather and financial winter 2015, an increase for 2016 winter quota is definitely required. It will encourage more inshore boats to partake in the fishery. The local economy is in dire need of such in one of the leanest times of the year.

 There was huge pressure to put to sea in very bad weather conditions, in an attempt to catch some of the quota, which put lives and careers at risk. Just thankfully no one was lost. 

I believe all of the inshore have a right to earn a living and access this fishery, so there an increase for this year should definitely be given. One should not attempt to underestimate the knock on effect that this fishery has on the fishing villages of the southeast.(it was sorely felt in winter 2015.

yours sincerely 

Elizabeth OToole

MFV sunrise 11 W216   


Erris Inshore Fishermens’s Association

NWRIFF


I am writing to you in my capacity as Secretary of Erris Inshore Fishermen's Association and Chairperson of NWRIFF.

Members of both organisations would like to support Minister Creed's proposal to increase the allocation to operators for 2016 for the Celtic Sea Herring Sentinel Fishery.  This is a much needed proposed increase in quota and gives the inshore sector a greater fishing opportunity.  In light of last year's bad weather, this would provide the inshore sector with an additional opportunity to increase their income for 2016.   

We look to a forward to a positive outcome to this proposal.

Regards.


EAMON DIXON

Patirck Downes MFV Ocean Pearl


Dear sir

It would be a great benefit to the small boats that fish in this fishery, to give any extra allocation as the boats in this fishery have to survive on very minor weekly quotas..

It is a very essential fishery for our area when the weather prohibits fishing for other species.

It would be also be a benefit if more Quota was released each week to avoid the quota not being taken over the season..

Regards

Patrick Downes Ocean Pearl


Patrick Myler MFV Southern Sun


To whom it may concern my name is Patrick Myler My boat is the Southern Sun due to bad weather last year we were unable to catch our Herring Quota. It would be great to get an increase in the herring quota because when the quota is divided up between the under tens and over tens the under tens "it is very small your sincerely Patrick Myler

Padaig Dillane MFV Elsie Louise


To whom it may concern

We as fishing vessel owners urge the minister to use every avenue available to him to ensure the proposed increase in quota for the sentinel fishery. This increase would mean that at the most lean time of the regarding fishing and weather conditions for these small fishing vessels there would be a chance that hard working crews have a chance at making a weekly wage in the weeks running up to Christmas . The buzz words of our generation are "small sustainable inshore fisheries". Well it's about time the government helped put these into practice.


Mise lè meas
Padraig Dillane,Mairtin Dillane, Aonghus Dillane, Liam Dillane.
Mfv Elsie Louise G711. Mfv Atlantic osprey G274. Mfv Sharlisa SO 765.

Irish South and East Fish Producers Organisation


Our proposal will agree with the submission to Minister Creed subsequent to a meeting of Celtic Sea Herring Management Advisory Committee on Thursday the 14th July 2016, in which we proposed a 5% increase as an exceptional measure on top on the usual 11%, totaling 16% for 2016, in the sentinel share of the fishery due to the bad weather in 2015.

Regards, Hugo Boyle

Irish South & East Fish Producer's Organisation,
Ground Floor,

Viewmount House,

Viewmount Park,

Dunmore Road,

Waterford, X91 NCK4.

Tel (Office): 051-853627

Hugo Boyle (CEO):
Email: ISEFPO@Eircom.net

National Inshore Fisheries Forum


To whom it concerns,

Based on the arguments previously outlined to Minister Michael Creed T.D. at a meeting of the National Inshore Fisheries Forum on 22/06/16 and in previous correspondence with his predecessor Minister Simon Coveney T.D., the National Inshore Fisheries Forum (NIFF) supports the proposal to increase the quota allocation to the Celtic Sea Herring Fishery for 2016 by a minimum of 500 tons as a one off exceptional measure.

Yours Faithfully,

Alex Crowley,

Chairman National Inshore Fisheries Forum.

Iveragh Fishermen’s Co-op Ltd


To whom it concerns,

The Iveragh Fishermen’s Co-Operative supports the proposal to increase the quota allocation for the Celtic Sea Herring Sentinel Fishery by a minimum of 500 tons as a one off exceptional measure for 2016.

Yours Faithfully,

Alex Crowley, Hon. Sec.

Iveragh Fishermen’s Co-op Ltd.

Nicholas Murphy MFV Starlight


To whom it may concern,

The following are my views on the proposed increase to the Sentinel Celtic Sea Herring quota for 2016.

         The - 2016 quota after contingencies is 17,091 tonnes.

         The 2016 Main 84% allocation of 17,091 is 14,356 tonnes.

         The 2016 Sentinel 11% allocation is 1,880 tonnes.

         The carryover from the Main Fishery in 2015 is 2,100 tonnes, of which the Sentinel fishery is allocated 11% or 231 tonnes.

         The carryover from the Sentinel fishery in 2015 is 1,222 tonnes, of which the Main Fishery is allocated 84%, 1,026 tonnes.

         Therefore, the net transfer from the Sentinel to the Main Fishery due to carryover from 2015 is 795 tonnes (1,026 – 231 = 795)

The Main Fishery has profited 795 ton at the misfortune of small inshore boats during an exceptionally bad period of weather. While Minister Creed giving consideration to an increase in Sentinel allocation is welcome, I believe the full amount of 795 ton should be allocated to the Sentinel Fishery. Serious consideration should also be given to a long term annual increase in the allocation to the Sentinel Fishery due to the critical importance of this fishing to the South East in terms of employment, not only of fisherman, but other local businesses at an otherwise quiet time of year.  The importance of the Sentinel Fishery to small fishing communities in the South East cannot be underestimated. Shops, restaurants, pubs, fuel suppliers, accommodation rentals etc. all benefit from this fishing. The fishery harbour centre of Dunmore East, along with other ports, depends on this fishery for their long term future.

I would like to see the Sentinel Fishery open earlier at the beginning of November and run to the end of January to allow small boats fish their quotas. The boats should be allowed back-fish uncaught quotas. The present system of “use it or lose it” forces small boats to fish in dangerous weather conditions in order to catch a weekly quota that cannot be carried forward. This is a serious safety issue that need not have arisen.

The Main Fishery closed with 2,100 tonnes uncaught due to the fact that the large boats went on to fish more lucrative fisheries of mackerel and scad. This adds to the case for any un-caught small boat quota to remain in the small boat fleet.

Yours,


Nicholas Murphy

Stephen Burke MFV Boy River


TO WHOM IT MAY CONCERN ,

THE FOLLOWING ARE MY VIEWS ON THE PROPOSED INCREASE TO THE SENTINEL CELTIC SEA HERRING QUOTA FOR 2016

2016 QUOTA AFTER CONTINGENCIES 17091 TON

2016 MAIN 84% OF 17091 =14356 TON

2016 SENTINEL 11% OF 17091=1880 TON

CARRYOVER FROM MAIN FISHERY 2015 IS 2100 TON

SENTINEL BENEFITS FROM 11% OF THIS CARRYOVER WHICH IS 231 TON

CARRYOVER FROM SENTINEL FISHERY 2015 IS 1222 TON

MAIN FISHERY BENEFITS FROM 84% OF THIS CARRYOVER WHICH IS 1026 TON

THEREFORE WE HAVE A NET TRANSFER FROM SENTINEL TO MAIN FISHERY DUE TO CARRYOVER FROM 2015 OF 1026 TON MINUS 231 TON =795 TON

THE MAIN [BIG BOAT]FISHERY HAS PROFITED 795 TON FROM THE MISFORTUNE OF SMALL INSHORE BOATS DURING AN EXCEPTIONALLY BAD PERIOD OF WEATHER.

MINISTER CREED GIVING CONSIDERATION TO AN INCREASE IN SENTINEL ALLOCATION IS WELCOME

HOWEVER I BELIEVE THE FULL AMOUNT OF 795 TON SHOULD BE GIVEN TO THE SENTINEL FISHERY.

NOT ONLY THAT BUT SERIOUS CONSIDERATION SHOULD BE GIVEN TO A LONG TERM ANNUAL INCREASE IN ALLOCATION TO THE SENTINEL FISHERY WHICH IS OF HUGE IMPORTANCE TO THE SOUTH EAST NOT ONLY FISHERMEN BUT LOCAL BUSINESS AT A QUIET TIME OF YEAR.

THE IMPORTANCE OF THE SENTINEL FISHERY TO SMALL FISHING VILLAGES IN THE SOUTH EAST CANNOT BE UNDER ESTIMATED .SHOPS RESTAURANTS PUBS AND HOUSE RENTAL ALL BENEFIT AT A TIME WHEN THE SUMMER TOURISTS ARENT AROUND.THE FISHERY HARBOUR CENTRE OF DUNMORE EAST ALONG WITH OTHER LOCAL PORTS NEED THIS FISHERY FOR THERE LONG TERM FUTURES AS WITHOUT IT FURTHER LOSS OF BOATS WOULD OCCUR FROM AN ALLREADY DECIMATED FLEET.ALSO EXTRA QUOTA FOR THE SENTINEL FISHERY WOULD DIVERT EFFORT FROM STOCKS THAT ALLREADY VERY HEAVILY EXPLOITED SUCH AS CRAB ,LOBSTER WHELK AND INDEED BENIFIT ALL INSHORE FISHERMEN NOT ONLY THOSE PARTICIPATING IN THE SENTINEL FISHERY BECAUSE IF WE DONT HAVE THIS FISHERY WE ALL WILL PURSUE SOME OTHER FISHERY INSTEAD WHICH ONLY INCREASES PRESSURE ON THESE OTHER FISHERIES.

BOTH MYSELF AND PAUL DANIELS SIT ON THE CELTIC SEA HERRING MANAGEMENT ADVISORY COMMITTEE REPRESENTING THE SENTINEL FISHERMEN.

IN YOUR PROPOSAL THAT I AM REPLYING TO IT STATES

“The Committee advised in March 2016 that they would not be in a position to agree on an increase in the allocation for the Sentinel Fishery as this would mean a pro-rata deduction for the Main Celtic Sea Fishery”

BOTH MYSELF AND PAUL DANIELS ATTENDED THE MEETING WHERE THIS WAS DISCUSSED AND TWO POSITIONS WERE PUT FORWARD,

NO 1;FROM THE ISEFPO WAS THAT AN INCREASE BE GIVEN TO SENTINEL FISHERY FOR 2016

NO 2 ;FROM THE ISWFPO WAS THAT THE DECISION BE LEFT TO MINISTER COVENEY TO DECIDE

IF THE ABOVE STATEMENT IS THE ADVICE THAT CAME FROM THE CSHMAC THEN IT IS TOTALLY NOT REPRESENTATIVE OF WHAT HAPPENED AT THAT MEETING AND IT HAS BEEN ALTERED TO SUIT A MAIN FISHERY AGENDA.

I HOPE AS INCOMING MINISTER YOU WILL LOOK FAVOURABLY ON THE INSHORE SECTOR AND IGNORE THE CALLS FROM THE MULTI MILLION EURO PELAGIC SECTOR WHO TREAT ALL PELAGIC QUOTA AS THEIR’S AND THEIR’S ONLY EVEN THOUGH THEY HAVE SO MUCH QUOTA THAT THEY NEED TO LENGHTEN THEIR VESSELS OR BUILD BIGGER VESSELS IN ORDER TO CATCH THE HUGE AMOUNTS THEY ARE ALLOCATED EVERY YEAR.THE SENTINEL FISHERY IS THE ONLY OPEN ACCESS PELAGIC FISHERY IN THE COUNTRY AND IT IS GIVEN A MEASLY 11% OF CELTIC SEA HERRING QUOTA. IN TERMS OF THE COUNTRYS TOTAL PELAGIC QUOTA WE ARE TALKING 1 OR 2 % ARE AVAILABLE FOR OPEN ACCESS FISHERIES SUCH AS THE SENTINEL FISHERY.A PERMANENT INCREASE IN QUOTA TO 25% OF CELTIC SEA HERRING FOR THE SENTINEL FISHERY WOULD HAVE HUGE BENEFIT FOR THE REGION AND A NEGLIGIBLE IMPACT ON THE PELAGIC/RSW SECTOR .

YOURS FAITHFULLY

STEPHEN BURKE

Daryl O’Donnell MFV Michelle


To whom it may concern,

I Daryl O'Donnell of MFV Michelle S454 wish to give my view on the quota that was allocated for 2016.

I believe it is only fair that the Sentinel Fishery receive the full quota that we lost out on last November and December 2015 due to abnormally bad weather. 

I don't believe this quota should be shared amongst the main fishery as these boats were still able to fish during said bad weather and we the smaller boats were not.

As Harold McLoughlin the Dunmore East harbour master can back up with spreadsheets and figures we the smaller boats were tied up, with no earnings, for the majority of November and December 2015.

It is extremely important that we get this quota from 2015 carried over for the Sentinel Fishery 2016 as this is a vital part of our yearly income that we were denied due to circumstances out of our control.

Yours Sincerely

Daryl O'Donnell


Joseph Whitty MFV Ellen Marian


I think that the allocations to the Celtic Sea Herring Sentinel Fishery for 2016 should be increased.

Also, in the event that a week’s quota is not landed due to weather conditions etc. the remainder should be carried forward to the following week.

In order for the fish to be at its best quality it should be landed as soon as possible and not left on boat due to landing time restrictions.

Yours Sincerely,

Joseph Whitty

Edward Fahy


As a consultant and journalist with a long time interest in fisheries management I would like to contribute to discussions on the above proposal. I am currently examining the distribution of quota within the Irish fleet using material released by the Department of Agriculture, Food and the Marine (DAFM) on foot of an instruction from the Office of the Information Commissioner earlier this year.i

My initial reaction to what I have learned is that the distribution of quota, which accounts for 90% by volume of landings and 70% by value, is unfair and disproportionately weighted in favour of members of Fish Producer Organisations (FPOs). When I examined their membership in 2013, I found they accounted for only 9% by number of vessels in the fleet, those being the largest and most powerful boats.ii

The role of FPOs in the management of the Common Fisheries Policy operated by the European Union gives them enormous power in designing and implementing national fisheries policy. The document Fisheries Quota Management in Ireland, published by DAFM, indicates that FPOs have a majority (four places out of seven) on the Quota Management Advisory Committee (QMAC) which, I submit, is not a healthy situation when it comes to divvying-up a national resource.

In 2014, the year I am examining most closely, there were three herring fisheries: the Atlanto-Scandian, North West and Celtic Sea fisheries. DAFM states in much of its published statements and in correspondence that there is no entitlement to quota for any species and that any such allocations are in the gift of and at the discretion of the minister. However, there is also reference to “track record” conferring preferential treatment – for some (I have no idea how many) - of the larger boats, a concept which undermines the supposition of no entitlement.

In 2014, some 57 vessels had authorisations (other than in the Celtic Sea Sentinel herring fishery and the smaller monthly allocations to Irish Sea Fishing boats as set out in Fishery Management Notices) which, combined, amounted to, in a few individual cases, 600 and 700+ tonnes. Some of these accumulated totals for a single vessel exceed the proposed extra 500 tonnes for the Sentinel Fishery. Many larger vessels had authorisations for two herring fisheries plus authorisation for other pelagic species and, some, in addition, for the most valuable demersal fishery, monkfish. All but five of the 57 were members of FPOs. The five might well have been but I have found the vessel register has not always agreed precisely with information obtained elsewhere. However, 52 vessels out of 57 makes a salient point: without suggesting anything improper, it is an observation that the QMAC, the majority of whose members belong to FPOs, distributes, for whatever justification, larger amounts of quota to members of FPOs and that, however innocently, FPOs favour their own members disproportionally. This is not satisfactory and the state should ensure there is more effective balance in the way business is done.

I would like to support the allocation of a greater proportion of the herring stocks to small and medium sized inshore boats by which herring was traditionally harvested. I would oppose “talking-up” or otherwise enlarging national quotas to obtain this end.

I would also argue for a more transparent and representative process involving a greater proportion of smaller boat operators to decide how quotas are distributed. Although there is no up-to-date census of the distribution of employment in the catching sector a 50:50 distribution of personnel between boats which are members of FPOs and those that fish smaller craft is a working estimate and that would be an appropriate balance to seek in the membership of QMAC.

Edward Fahy

Cian Daniels


To whom it may concern,
Writing to you as an inshore fisherman and also as a resident of a coastal community for all my life, i have witnessed the decimation of an industry through ill informed decision making and a lack of interest from countless members of all major political parties. We are now forced to live on the scraps of a once thriving fishery , where the inshore vessels live on 11% of the TAC and the remainder is spread between fewer than 30 boats. Once again we are facing a situation which we see all too often in Ireland where the decisions made by the political establishment will contribute to the ever widening gap between rich and poor. When we look at it on a wider scale its not only the owners and crew of the smaller vessels will suffer, the local business' of the landing ports will bare the brunt of these decisions. When the tourist season is over shops ,hotels etc will rely heavily on the crews of the 20-30 visiting boats with 2-3 crew per vessel. We hope after reading the letters the minister will see sense and support the coastal communities and give us some faith going forward that the political party we voted for will support the fishing industry
regards,

Cian Daniels


Inshore Fishing Sector




  • 70 individual signatures received from the Inshore Fishing Sector to support the above proposal



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