“Arguments” Against Day-at-Sea

FFL propose an hours based effort control management system as the only fit-for-purpose method of managing the UKs rich demersal mixed fisheries, as detailed in the Brexit Textbook on Fisheries. http://ffl.org.uk/product/the-brexit-textbook-on-fisheries/



Recently the NFFO attempted to highlight the supposed pitfalls of Days-at-Sea, this showed either a woeful misunderstanding of the principles of Days-at-Sea or a gross misrepresentation.

Fishing for Leave have developed mechanisms within an hours based effort control system to refine the “blunt instrument” and address the supposed pitfalls.

By the NFFOs own admission Days at Sea would solve the insurmountable problem they highlighted of choke species and them being a fundamental result of Quotas.

Consequently, it isn’t the principle or the applicability of Days which the NFFO is criticizing but the implementation and refinement of the system. FFL welcomes this and in answering the supposed pitfalls look forward to the NFFO endorsing Days-at-Sea as the only way, by their own admission, to avoid choke species.

In seven years neither the SFF or NFFO have found a solution to avoid the devastation of the remainder of the UK fleet and the consolidation into a few hands. FFL hopes they will now endorse this fit for purpose effort control system as the only alternative.


i) Flexible Catch Composition Percentages– Fishing for Leave has designed a system of “flexible catch composition percentages” to avoid a free for all and over exploitation on high value species. This negates the need to manage by the lowest common denominator species. It also preserves/incorporates FQAs into effort control to maintain investments in particular fisheries.

FFLs policy proposes a smooth transition for the UK fleet to an hours based effort control system whilst retaining FQA track records. This policy would convert a vessels FQA entitlement (owned and rented) from being entitlement to an arbitrary kilogram quota to being an entitlement to a flexible catch composition percentage of the overall catch per month.

This catch composition on high value or endangered species would allow vessels to fish the mixture of species they currently have track record for. A vessel with 20% of its FQAs being Cod or Sole can still retain 20% of these species.

If exceeded a vessel needn’t discard but can retain the catch in exchange for a loss of hours on a gradated basis. This would be time not needed as the vessel has a catch aboard. This provides a deterrent from a free for all however a vessel can still keep what it catches.

This is a balancing system, if a vessel behaves sustainably it receives maximum time at sea. If a vessel tries to go free for all on a high value or endangered species it is reigned in by the loss of time at sea. This would facilitate catch less but land more in less time eliminating discards and mark a return to keep what you catch.

Crucially this system provides a mechanism to stop any “race to fish” for high value species. This  negates time being set by the lowest common denominator species.  By converting FQAs it provides financial stability on the substantial investments which were in FQA entitlements – not the quota!

ii) Soak Time hours based system for effort control –FFLs proposed policy sets and allocates effort control in a soak time hours based system providing greater precision of operations, management and monitoring through sensors on the gear integrated through a vessels VMS system.

Soak time negates the need to set a precautionary lower level of effort to account for the presumption that every day is a possible full 24 hours fishing and that time needs to be accounted for steaming.

Soak time provides flexibility to allow the fleet to naturally spread out over its full geographical range and stocks, means all types of fishing are on an equal footing whether gill net or trawl as it is gear deployment that is clocked and it removes the pressure of avoiding loosing time dodging.

Most importantly soak time allows managers to set effort accurately and to maximise time in letting the fleet accurately use all its time as fishing time. In return managers know exactly when gear is deployed and where.

When VMS, keep what you catch E-log info and soak time are combined in an integrated monitoring system this will provide science and management pin point, real time accurate data on stocks improving science and therefore fishing opportunities and finally accounting for fishermens knowledge reflected in their catches.

Currently quotas lead to misconstrued, falsified reporting, criminalising fishermen and grossly distorting fisheries science whilst creating an adversarial situation between managers, scientists and fishermen.

iii) Conservation Credits- A system of conservation credits would award extra time to vessels who, in being even more selective and sustainable, can be given extra time to account for their lighter impact. This would encourage the adoption of the best possible measures as vessels would look to avoid species that the do not have adequate catch composition for or are of little value.


2)- NOT ENOUGH DAYS AS EFFORT LOWEST COMMON DENOMINATOR Suggests time at sea would have to be set to protect the lowest species.

This will happen under the Catch Quota/Discard Ban with Choke Species where vessels will be tied up upon exhausting their smallest quota displacing effort into ever smaller opportunities. The days of discarding to find what you can keep are over.

Saying effort must be set to the lowest common denominator is a misrepresentation and fundamentally misunderstands the principle behind Days-at-Sea.

Effort control recognises that vessels will catch a mix of species and takes an ecology wide approach rather than individual species with effort set to manage a whole area.

“Saying the fleet needs mountains of Days misses the point – if you can reach the sustainable TAC faster with keep what you catch you are more profitable. Needing limitless time at sea to find a quota is economic perversity”.

To be sustainable an even slice should be taken across all species to maintain the ecological balance rather than ‘cherry pick’ with Quotas and increase effort with discarding. Balancing overall recruitment to the ecology of a mix of species with catches of that mix is perfect sustainability.


Effort is set to the overall environment and, as detailed above, flexible catch compositions discourage vessels from high value species whilst still allowing keep what you catch. This negates the need to slash overall effort to the lowest common denominator.

The number of hours vessels can fish is set by combining ALL demersal TACs in an area which is then divided by the daily average catch rate across the fleet in the area to find how long it will take the fleet to catch this combined pot of TACs

 **Example**  200 vessels catch 2 ton each per day equaling 200 ton catch per day in area.
                   100,000 tons of TAC divided by 400 tons catch per day equals 250 days.
                    Fleet will need 250 days per vessel per year for the fleet to catch the 100,000ton.

The 4 tables below show (**Click to open) correctly the methodology and proper allocation of days using the principle above. They categorically refute that the UK fleet would have no time at sea.

FN - FFL - No. Days at sea - North Sea FN - FFL - No. Days at sea - Irish Sea FN - FFL - No. Days at sea - West Coast

FN - FFL - No. Days at sea - South West

As clearly shown, the UK fleet would receive more time at sea in every area than it currently uses at present.  Even when accounting for the “extra” fish that can be landed that has otherwise been Discarded and unaccounted for.

 “Soak time in Hours converted back to days presumes vessels use 20 hours soak time every 24. Most vessels do not – we challenge Mr Deas or Mr Armstrong to take a vessel to the North Sea and fish 4,442 hours of soak time a year!”

Currently, on average, the vessels fishing the;

  1. West of Scotland (VI)- exert 164 (24 hour) days. Effort Control awards the equivalent 223 (24 hour blocks of soak time).
  2. Irish Sea (VIIa) – exert 121 (24 hour) days. Effort Control awards the equivalent 166 (24 hour blocks of soak time).
  • South West (VIIb-k) – exert 144 (24 hour) days. Effort Control awards the equivalent 384 (24 hour blocks of soak time).
  1. North Sea (IV) – exert 150 (24 hour) days. Effort Control awards the equivalent 222 (24 hour blocks of soak time).

Effort control actually gives an INCREASE in days on effective current working time. Whilst facilitating keep what you catch meaning the fleet will be catching within the sustainable TAC limit whilst landing more by eliminating discarding.

“Effort control is Fishing Smarter not Harder”

As these tables show, Fishing for Leaves proposed system of Effort Control in an hours based soak time system with flexible catch composition controls and conservation credits mean that all vessels will have more time at sea than they use currently use under quotas. They will be able to keep what they catch, reach the TAC in less time and have no crippling quota costs their business will be more profitable.

As this answers the apparent reservations on Days-at-Sea/Effort Control we look forward to the NFFO backing this system as a way to show its support in securing a future for all sectors of the industry in avoiding quota consolidation and the discard ban.


3)- CAPITAL STUFFING INTENSIFIES FISHING EFFORT propagates the idea that effort control increases fishing technology, efficiency and consequently stock mortality.

Quotas increase mortality through discards! Forcing vessels to catch more to land less, incurring extra time to do so.

The suggestion that effort control causes a magical automatic increase in fishing intensity suggests that there is a sizeable number of boats working inefficiently who could increase their effort.  The theory that efficiency keeps growing indefinitely, and that fishing businesses do not work at maximum efficiency already, does not stack up to operational reality and is a gross simplification to discredit effort control


4) – FAILURE IN FAROEFaroes system has not failed, any dip in catches is through vessels taking advantage of access to Norway, Greenland and Iceland and the natural stock fluctuations that effort control allows accurate documentation of which quotas here have not. Current quotas and mass discarding is far worse than Faroe and the NFFO suggesting Faroe has failed is people in glass house throwing bricks.

Faroe is an applicable example of the ecological principle of effort control trying to manage the ecology as a whole rather than try to discriminate by individual species. Faroes system gives a comparison of the ecological principle not the implementation of effort control as promoted by FFL as Faroes system does not have the refinements detailed above which are developed in answer to the lessons from Faroe.


5) COD RECOVERY PLAN- Effort control under the Cod Recovery Plan failed due to the implementation. By setting the Days by one species (Cod) it perverted the purpose of Days allowing an ecology wide management and resulted in time being cut to the lowest common denominator. To compound this It failed conservationally because quotas still existed, this continued excess mortality of discarding.  By working alongside the quota system it created the operational contradiction of vessels needing time to discard to find their quota but having limited time to do so.


6) JOINT MANAGEMENT OF SHARED STOCKS–  Suggesting that to co-operate on joint stocks the UK should conform with our neighbours and retain quotas is piffle and a disingenuous justification to retain quotas.

There is no legal position to substantiate this, UNCLOS clearly states in Article 63 that coastal states should agree upon measures to co-ordinate conservation.  This is done through NEAFC and a system of Total Allowable Catches (TACs).

Article 61 states the coastal state shall ensure proper conservation measures within its EEZ.  Therefore, it is at the UKs discretion as to what system it uses to administer its share of the TAC.  It is certainly a gross breech of UNCLOS to have a quota system that criminally forces the slaughter and discarding of huge volumes of fish as the “lubrication” (collateral damage) to allow the continuation of such an inept and bankrupt system to appease a small minority of vested interests.

By administering the UKs TAC shares through effort control the UK will be fulfilling the terms of UNCLOS along with still working in Joint Management on Shared Stocks under its terms.


7)- FQAs/ITQs

Contrary to the NFFOs blithe pronouncement that FQAs stopped black fish it did not, strict enforcement through a pelothra of rules needed as plasters on the ailing regime such as designated ports, VMS and electronic log books is what stopped black fish.

FQAs whether deliberately or by accident have acted as a ITQ system in all but name to cause internal decommissioning of the UK fleet. Caused by the inevitable consolidation of FQAs into fewer hands as the industry has been forced to invest increasing amounts of liquidity into FQAs to tread water with the amount of quota needed to be viable.

It cannot be beneficial even to multi million pound companies to have to keep investing large sums of capital into quota when a better system could see them be able to fish more sustainably and profitably for a better return.



All of the current suggestions of how to cope with the discard ban are mere mitigation measures of re-arranging the deck chairs on a sinking ship.

Comparisons with Norway are superfluous as they have a totally different ecology. Their lower number of TACs is because they have less of a mixed fishery.

No flexabilities have been offered that solve the problem that quotas cause discards and discard bans cause chokes other than ways to cheat the point of quotas.

Instead of recognising that quotas are a busted flush we have risible efforts of mitigation that increasingly look like desperation by a cartel of vested interests to keep quota rather than accept that a better system would benefit all fishermen and communities including them.

Bank and Borrow – using quota from future years to cover the current merely staves the execution of a choke to the future.

Interspecies Flexibility – using Haddock TAC to cover Cod makes a mockery of having a quota in the first place. By coincidence the idea inadvertently gets closer to the ideological basis of effort control treating the ecology as a whole without actually using applicable conservation measures to do so.

Grouped TACs – undermines the point of a quota. Furthermore, whether Cod and Hake choke the North Sea fishery as independent quotas or lumped together doesn’t solve the crux of the problem

Better Science –the is to rigidity and unreactive quota system with distorted landing will always produce bad data and never allow accurate science.  If the TACs can be set to allow an un-choked year long fishery then we have unlimited fishing 365 with no conservation.

“Facts have to be faced that Quotas are not applicable to as mixed fisheries as those found around the British Isles and that the industry has been shovelled into a hole that it must get out of before the logical conclusion of quota enforcement through catch quotas/discard ban fills in the grave”.


Quotas fail by imposing a rigid man made system on a dynamic marine environment and  trying to discriminate by species in an indiscriminate mixed fishery.

They lead to discards and the discard ban merely bans the symptom not address the cause. The resultant choke species will see the fleet decimated as quantified by a Seafish report.

Quotas have financially crippled the industry as increasing amounts of profit and liquidity are bled away to obtain enough quota just to remain stagnant.  Causing artificial consolidation into fewer hands destroying the families, communities and heritage that is the foundation of the industry, this will only accelerate with choke species.

Generation old fishing families find themselves dependent on guard jobs for annual profit and/or trapped in servility to big quota renters and slipper skippers who, in bleeding the industry dry, have a vested interest in maintaining the status quo rather than looking to a brighter future for everyone post Brexit as FFL is doing.

Quotas give no reflection of catches as they are an artificial landings limit, this has given inaccurate science which combined with a rigid system based on out of data man made figures means the system is increasingly detached from the dynamism, fluctuations and reality of the environment.


FFLs proposed system, although a totally different perception and approach to mixed fisheries management, is achieved not by revolution but evolution with only slight modification.

FFLs system is a way to retain FQAs to protect and maintain the investments and business stability underpinned by them whilst transitioning them into a different system.

FFL have provided an approach above that solves the apparent problems of effort control with refinements detailed in the points above by retaining FQAs and expressing them differently and allocating effort in soak time.

Effectively in exchange for the fleet being able to keep what it catches the fleet is accepting a ceiling of effort whilst allowing catch less but land more in the time limit allocated.

This is in contrast to the less sustainable and less profitable effect of Quotas where boats want 365 days at sea a year to catch more fish than necessary to find what their quota allows them to keep.

**Example** – Rather than fishing 300 days a year, catching 100 boxes per day (30,000 per year) and only retaining 60 (18,000 per year) keep what you catch would see 200 days a year for 20,000 boxes with expenses cut by a third.

The Discarding of fish has been a criminal and reprehensible practice where we have been forced to slaughter our own future and this makes Quotas a damned disgrace of a system.

The industry is now faced with a Discard Ban which everyone recognises will devastate what is left of the industry. Therefore, with a fit for purpose policy alternative hours based effort system answering all the problems, anyone advocating retaining Quotas needs to ask if they are doing so for a long term sustainable future or to look after their own short term interests?