The Inconvenient Truth: Sustainable Deep Sea Fishing is Possible

Claim 7: Deep-sea fishing in Europe is not a French issue involving a handful of boats and a few dozen jobs.
The reality: The document mixes the boats that fish from the shelf and down the slope, e.g., for monkfish and megrim, to those that fish selectively for deep-sea species. If the ban on trawling gear starts at 600 m, as proposed, it will not impact the first group of boats, and will impact a small number of vessels, largely from France.

Claim 8: The United Nations has never recommended a ban on trawling and gillnets, nor has the scientific community working on the North East Atlantic.
The reality: The UN considered a complete ban on bottom trawling in 200 but relented only when other measures were proposed that would supposedly protect deep-sea bottom communities1. As the Deep Sea Conservation Coalition has shown, none of the nations agreeing to the regulations have actually lived up to their requirements, so a ban may yet happen.

Claim 9: The European fleets aren’t the only ones fishing in the North-East Atlantic… Third country boats will move in and take over.
The reality: The regulation does not aim to prohibit deep sea fishing, only to phase out the most destructive fishing methods. Any non-EU boats will have to comply with this regulation.

Claim 10: The industry is not kicking up a fuss for nothing. It is not possible to convert the entire fleet of bottom trawlers to long lines overnight. And not just because of the costs…
The reality: The prohibition on bottom trawling and gillnetting would be phased in over two years, sufficient time to convert boats and crews to other methods.

Detailed examination of claims made in The Inconvenient Truth: Sustainable Deep Sea Fishing is Possible

Claim 1: The seabed environment is not some sort of fantasy reef from a cartoon. The truth is that huge parts are made up of sand, mud or gravel.
The reality: Bottom trawling eradicates much of the surface life from the seabed regardless of whether the bottom is hard or soft sediment, and where sediments are soft, trawls cause damage to significant depths beneath the surface too.

Most of the seafloor is sand and mud, but that does not mean that Vulnerable Marine Ecosystem species are not present. It is important to understand that sand and mud bottoms are not “lifeless.” In fact, many species of small animals live in those sediments, many of which are food for deep sea bottom fish. While muddy bottoms are home to countless numbers of species, most being quite small, larger forms such as sea pens, hyalonemid (stalked) sponges, football sized xenophyophores (one of the largest single-celled organisms in the sea), sea urchins, sea cucumbers (sometimes called sea pigs)2, brittle stars, bryozoans, and octocorals3 also can be found, often in abundance4.

1 https://savethehighseas.org/whatsbeendone/unprocesses.cfm
2 See for example, http://deepseanews.com/2012/09/the-great-recession-of-the-deep-oceans/
3 Not all are found on hard bottoms. See this report from Newfoundland and Labrador for images of several species of octocorals living on muddy bottom. http://www.dfo-mpo.gc.ca/dpr-rpp07-08/sect3j-eng.htm
4 Roberts, J.M., S.M. Harvey, P.A. Lamont, J.D. Gage, J.D. Humphrey. 2000. Seabed photography, environmental assessment and evidence for deep-water trawling on the continental margin west of Scotland. Hydrobiologia 441: 173- 183.

In a recent study of the muddy bottoms off the west coast of Scotland, an area well within the zone currently and historically trawled by the French deep-sea fleet, trawl marks were seen in as many as 47% of the bottom photos5. In those areas, damaged hyalonemid sponges were observed, and other larger organisms, including xenophyophores, were absent. The smaller animals were undoubtedly impacted as well. Many of those are responsible for the habitat structure of the muddy bottoms6, which in turn provides living space for many of the species that are necessary as food for fish such as roundnose grenadiers7.

Claim 2: The North-East Atlantic isn’t the Wild West where it’s a free for all: Deep-water fishing is not a cosmic threat.
The reality: While some fishery closures exist, the great majority of the deep sea in European waters is open to bottom fishing.

The point is made that very little of the North-east Atlantic is open to deep sea bottom fishing. Not true. Many of the protected areas in the figure shown for Scotland are simply proposals, and many of the Special Areas of Conservation that do exist already are not actually protected from bottom fishing (which is true of the vast majority of Special Areas of Conservation in Europe). So it is highly misleading to suggest that 13,000 km2 is closed to bottom fishing or about to be. The text goes on to state that “did you know that only 6,5 % of the North East Atlantic International fishable Waters are effectively open for bottom fisheries operations?” While it is true that the authors of the document have identified from the North East Atlantic Fisheries Commission a large area as not presently fished, that area is still open to fishing under the Interim Exploratory Bottom Fishing Protocol (http://www.fisk.fo/Admin/Public/DWSDownload.aspx)8. So although fishing is a bit more onerous in terms of paperwork, and requires the expense of an observer, it is not banned.

Claim 3: Deep-sea fishing is not an unregulated sector just doing what it wants.
The reality: Total allowable catches were introduced in 2002 for a handful of deep sea species. In the majority of cases they have been set above scientific advice, which was in any case constrained by limited data. TACs regulate landings, not catches and fishing mortality, and therefore are an inadequate tool to achieve sustainability in mixed species fisheries with high bycatch, such as those which prevail in the deep sea.

The document refers to an EU Regulation on deep sea bottom fishing from 2002 that remains in place. The regulation of 2002 came about because stocks of blue ling, especially, but also of several other deep-

5 Ibid, Roberts et al.
6 Gage, J.D., J.M. Roberts, J.P. Hartley, J.D. Humphrey. 2005. Potential impacts of deep-sea trawling on the benthic ecosystem along the Northern European continental margin. American Fisheries Society Symposium 41: 503-517.
7 Drazen, J. and Seibel, B.A., Depth-Related Trends in Metabolism of Benthic and Benthopelagic Deep-Sea Fishes, Limnol. Oceanogr., 2007, vol. 52, no. 5, pp. 2306–2316.
8 Interim Exploratory Bottom Fishing Protocol for New Bottom Fishing Areas
Until the Commission adopts a new protocol in accordance with Article 4, paragraph 1 of this Recommendation, exploratory bottom fisheries may commence only when the following information has been provided to the Secretary by the relevant Contracting Party:
(a) A harvesting plan which outlines target species, dates and areas. Area and effort restrictions shall be considered to ensure fisheries occur on a gradual basis in a limited geographical area.
(b) A mitigation plan including measures to prevent significant adverse impact to vulnerable marine ecosystems that may be encountered during the fishery.
(c) A catch monitoring plan that includes recording/reporting of all species caught. The recording/reporting of catch shall be sufficiently detailed to conduct an assessment of activity, if required.
(d) A data collection plan to facilitate the identification of vulnerable marine ecosystems/species in the area fished.
The Secretary shall promptly forward this information to all Contracting Parties and PECMAS.

sea species were seriously depleted. That is, landings had dropped precipitously, and something had to be done (see summaries in WGDEEP 2013 report9). The European Commission introduced the TAC regulation in 2002 in order to reduce pressure on all stocks in Community waters10. However, a recent analysis of the TACs and reported catches for 27 deep sea species concluded that the TAC was set higher than ICES recommended in 60% of the cases, and that in the end the catch exceeded the TAC in 50% of the cases. Furthermore, TACs were based on limited scientific information for the species in question, and ignored most species caught as bycatch. So this is not a system of regulation that has been effective or promoted sustainability for these stocks11.

Claim 4: Not all deep-sea species are fragile and endangered.
The reality: The great majority of deep sea species have characteristics that make them more vulnerable to depletion and loss than shallow water species. Many have declined to levels where they must be considered endangered.

It is true that some species of fish are more resilient and more productive in fisheries than others. However, it is a robust generalisation, based on extensive scientific research, that deep sea fish are much more vulnerable to overexploitation than shallow water ones. They live in a completely dark, very cold environment which has a very low rate of productivity compared to sunlit surface waters where plants grow. Sustainable rates of fishing are therefore far below those possible for species like haddock, cod or plaice.

The orange roughy may be an extreme example of vulnerability, reaching ages of 150 years or more and not reproducing until it is in its 20s or 30s. However, it is far from unique. A general pattern is that longevity of fish increases with increasing depth, and there are many species known from this environment that live to 70 years or more and start reproducing late in life (10+)12. Many species are so long-lived that they need to be aged using radiometric dating methods benchmarked to radionuclides released during atmospheric testing of atomic bombs in the 1950s and 1960s.

Available evidence shows that many species of fish have been commercially extirpated from regions that were formerly productive in the early days of deep sea fishing. Others have seen declines in stock size of 80 or 90% in the last 25 years, sufficient to qualify them as endangered according to the World Conservation Union’s Red List Criteria13.

The document states that “For the record, the specific nature of the orange roughy has been recognized by the EU which has imposed a 0 TAC and Quota on that species, meaning it is not threatened anymore.”

9

http://www.ices.dk/sites/pub/Publication%20Reports/Expert%20Group%20Report/acom/2013/WGDEEP/01%20 WGDEEP%20-%20Report%20of%20the%20Biology%20and%20Assessment%20of%20Deep- sea%20Fisheries%20Resources%20Working%20Group.pdf
10 Clarke, M., Patterson, K., 2003. . Deep-sea !sheries Management: the approach taken by the European Union. In: Shotton, R. (Ed.), Deep Sea 2003: Conference on the Governance and Management of Deep-sea Fisheries, Part 1: Conference reports. Queenstown, New Zealand, 1e5 December 2003, FAO Fisheries Proceedings N# 3/1. FAO, Rome, p. 718.

11 Villasante, S., Morato, T., Rodriguez-Gonzalez, D., Antelo, M., O¨sterblom, H., Watling, L., Nouvian, C., Gianni, M., Macho, G. 2012. Sustainability of deep-sea fish species under the European Union Common Fisheries Policy. Ocean and Coastal Management 70: 31-37.
12 For life history analysis with depth: Drazen and Haedrich (2012). Resilience values are from Fishbase.org, calculated according to the method of Musick, J.A. 1999,. Criteria to define extinction risk in marine fishes,. Fisheries 24(12):6-14. Vulnerability values are from Fishbase.org, calculated according to Cheung, W.W.L., T.J. Pitcher and D. Pauly, 2005. A fuzzy logic expert system to estimate intrinsic extinction vulnerabilities of marine fishes to fishing. Biol. Conserv. 124:97- 111.

13 Devine, J., K. Baker, R.L. Haedrich. 2006. Deep-sea fishes qualify as endangered. Nature 439: 29.

Declaring a TAC of zero certainly does not mean a species is safe. TACs regulate only what is landed, not what is caught and killed. The orange roughy and many other rare and sensitive species are vulnerable to capture as bycatch in fisheries for other more productive species. Highly vulnerable bycatch species like these require a very high level of protection to be safe. TACs, with their associated discards of over-quota and unwanted fish, have been the bane of fisheries management in shallow waters of Europe since the onset of the Common Fisheries Policy in the 1980s. They will certainly not safeguard deep water species14.

Regarding the fish called Baird’s slickhead (sometimes called smoothead), it should be noted that this species lives about 38 years but other critical information, such as age at maturity, is not known for this species15. This species is an Annex II species so landings data for the NE Atlantic have been recorded with regularity since 2002 and are summarized in the WGDEEP 2013 report (Table 14.4, p.475). Landings peaked in 2002 and 2005 at more than 12,000 t. Since then there has been a steady decrease to a total of 472 t reported in 201216.

Claim 5: Fishermen are not decimating the deep-sea ecosystems.
The reality: In mixed species bottom trawl and gillnet fisheries it is impossible to fish at sustainable levels for all species simultaneously. Fisheries for more resilient species cause high levels of collateral damage to bottom habitats and deplete and extirpate less resilient species of fish.

The issue of whether the three main species, blue ling, black scabbardfish, and roundnose grenadier are being fished at a sustainable level is case of looking at the glass as half full rather than half empty, and only from a very narrow angle. There have been problems with all three species in the area west of Scotland. Blue ling, for example, aggregates in this area for spawning17, and those spawning aggregations were targeted by the trawl fishery until regulations were put in place requiring the spawning aggregations be left alone. Landings of all three species dropped precipitously from very high values in the 1970s and 1980s to a few thousand tonnes in the 2000s (summarized in WGDEEP 2013). An examination of the graphs in WGDEEP 2013 shows mean index values that are roughly similar for the last five or six years. The best that can be said for these species is that the catch per unit effort has not dropped further, not that the catches have stabilized, or that they are sustainable. The French fleet, for example, has contracted the area over which they are fishing, thus concentrating their effort in areas where the target species still exist, thus keeping their catch per unit effort at stable values.

Claim 6: By-catch in deep-sea fishing operations are not out of control.
The reality: Bycatch is an inescapable aspect of unselective bottom trawling and gillnetting methods and many bycatch species have been depleted to low levels by fishing in Europe. The document aims to mislead by confounding numbers of bycatch species with volume of catch.

The fishing industry document states “You have perhaps also been told that boats are catching 100 species and keep only 3 for the markets. Do you really think that the crews of the boats spend their time at sea sorting the fish, throwing 97 % of their catch overboard?” The issue of bycatch as stated is a good example of how to lie with statistics. No one is claiming that 97% of the catch is being thrown overboard. But it has been stated in reports from French observers that for the three target species being caught, more

14 Norse, E.A. et al. 2012. Sustainability of deep sea fisheries. Marine Policy 36: 307–320.
15 http://www.fishbase.org/Summary/speciesSummary.php?ID=230&AT=Baird%26%2339%3Bs+slickhead
16 It is possible that the catch is higher than this because some countries, such as France, do not record the catch of this species, even though EU Council Regulation 2347/2002 requires that all nations do so.
17 Large, P. A., Diez, G., Drewery, J., Laurans, M., Pilling, G. M., Reid, D. G., Reinert, J., South, A.B., and Vinnichenko, V. I. 2010. Spatial and temporal distribution of spawning aggregations of blue ling (Molva dypterygia) west and northwest of the British Isles. ICES Journal of Marine Science, 67: 494–501.

than 100 other species are also caught18. What those species are and their abundances is not reported and the data have not been made public in spite of requests for that information. Bycatch in fisheries is often very high at the beginning and then decreases over time because the fishery progressively eliminates vulnerable species. To see the full impact of a fishery on bycatch species therefore requires that we look beyond those caught at present and include those that have been depleted early on in the fishery.

Claim 7: Deep-sea fishing in Europe is not a French issue involving a handful of boats and a few dozen jobs.
The reality: This point mixes the boats that fish from the shelf and down the slope, e.g., for monkfish and megrim, to those that fish selectively for deep-sea species. If the ban on trawling gear starts at 600 m, as proposed, it will not impact the first group of boats, and will impact a small number of vessels, largely from France.

Claim 8: The United Nations has never recommended a ban on trawling and gillnets, nor has the scientific community working on the North East Atlantic.
The reality: The UN considered a complete ban on bottom trawling in 2004 but relented only when other measures were proposed that would supposedly protect deep-sea bottom communities19. As the Deep Sea Conservation Coalition has shown, none of the nations agreeing to the regulations have actually lived up to their requirements, so a ban may yet happen.

Furthermore, ICES scientists cannot be considered to be a reasonable cross-section of the global deep-sea research community. The majority of scientists engaged in the activities of the ICES working groups are employees of national fisheries management agencies whose responsibilities include helping the fishing industry continue to fish. Deep-sea scientists from the academic research sector also attend ICES meetings but in most cases must raise the funding to attend these discussions from external sources. This limits the number of academic sector deep-sea scientists able to participate in ICES discussions.

Claim 9: The European fleets aren’t the only ones fishing in the North-East Atlantic… Third country boats will move in and take over.
The reality: The regulation does not aim to prohibit deep sea fishing, only phase out the most destructive fishing methods. Any non-EU boats will have to comply with this regulation.

The issue of foreign fleets fishing in EU waters is a completely false issue. The regulation being proposed does not ban EU vessels from fishing in the NE Atlantic. The regulation is intended to no longer allow vessels fishing for deep-sea species to use bottom trawls or gill nets. Any non-EU nation wishing to fish within EU waters would have to comply with EU regulations. On the other hand, by setting this precedent, it may also pressure the North East Atlantic Fisheries Commission to adopt similar regulations for deep-sea bottom fisheries, in which case all countries, whether a part of the EU or not, would have to give up the use of bottom trawls and gill nets when fishing for deep-sea bottom fish. Saying that third country boats would move in and take over is plain and simple scare-mongering.

Claim 10: The industry is not kicking up a fuss for nothing. It is not possible to convert the entire fleet of bottom trawlers to long lines overnight. And not just because of the costs…
The reality: The prohibition on bottom trawling and gillnetting would be phased in over two years, sufficient time to convert boats and crews to other methods.

18 IFREMER OBSMER report
19 https://savethehighseas.org/whatsbeendone/unprocesses.cfm