Alan Riddell saif advisory Group c/o Access to Fisheries Team Area 2C, Nobel House, 17 Smith Square

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Alan Riddell

SAIF Advisory Group

c/o Access to Fisheries Team

Area 2C, Nobel House,

17 Smith Square,

London SW1P3JR

26th March 2010
Dear Alan
I am writing on behalf of the Shellfish Association of Great Britain (SAGB). We are the UK industry trade association based at Fishmongers’ Hall, home of the Worshipful Company of Fishmongers; one of the 12 great livery companies of the City of London.
We welcome the publication of the proposition paper and the solutions-based approach to the well documented problems in the inshore sector.
The inshore shellfish sector is not directly affected by chronic shortages in quota – the only UK shellfish species with a quota is Nephrops norvegicus – but we remain concerned by the ever increasing pressure on shellfisheries, particularly high-value species such as scallops and brown crab, caused by fishers being forced to redirect effort onto non-quota species.
We have sought feedback from our members and in summary the SAGB supports option 2: wholly differentiate inshore fisheries from those off-shore.
We believe that a system based on technical measures and effort restrictions (possibly hours at sea) will empower the inshore fishing industry to become sustainable and profitable. At present the current quota-based system is not reducing fishing mortality as expected due to the high levels of discarding. Furthermore, by having restrictive licences based on track records we are seeing vessels pigeon-holed preventing a fluid approach to harvesting. Option 2 will enable the fishers to target stocks as they come into season, to reduce discards to minimal levels and reduce pressure on non-quota stocks.
Option 2 requires a greater understanding of the state of stocks, and environmental impacts on the ecosystem, and we therefore recommend that inshore managers adopt the approach taken by Sussex Sea fisheries Committee in utilising the Marine Stewardship Council (MSC) standards in developing a long-term management plan (
Our members do not support the option of reducing fleet capacity in the inshore sector through decommissioning or otherwise as this may have significant effects on social sustainability of small-scale ports and we do not support the option of increasing quota as this will only address the symptoms rather than the malady.
In addition to supporting option 2 the SAGB welcomes the group’s understanding that there is a missed opportunity around inshore seafood potentially commanding higher prices.
At the moment there is no real premium paid for quality inshore seafood. The market in the UK is almost entirely price driven. In order to change attitudes there needs to be a promotion drive on the sustainability, quality and provenance of inshore fish and shellfish with a view to obtaining a premium for such product. The Fishmongers’ Company are proposing to run a seminar on the 3rd June 2010 to highlight and promote “the market opportunities for sustainable inshore seafood” ( It does however, require a concerted marketing campaign if the public and trade are to amend their buying habits and pay a premium for such product. Maybe Defra could consider following the French example ( whereby the French government has signed off on a €350,000 (£312,000) marketing campaign for French seafood advertisements?
We also wish to point out that there is concern by many in the industry over the amount of latent effort within the shellfish sector. Many of the local shellfishermen feel that until this has been sorted out any moves to try and manage crustacean fisheries will be pointless. The SAGB sits on the UK & Republic of Ireland Brown Crab Working Group (an industry led group) and they share this view.
Finally, we believe that the issue of unlicensed and unregulated fishing impacting on stocks needs to be addressed by Defra. As a first step there needs to be a study into the scale of the impact which can be, our members consider, considerable on a local scale.
Please do not hesitate to contact me if I can provide any further information.
Yours sincerely

Dr Tom Pickerell

Mob: 07507 339156


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