The planned English Bluefin Catch and Release Recreational Fishery, (‘CRRF’).
Everything you wanted to know, but were afraid to ask……
Background.
In early December, DEFRA announced their intention to establish a Bluefin Tuna CRRF in England in 2024. This follows three years of operation of the very successful English CatcH And Release Tagging (‘CHART’) programs. These were put in place after lobbying and a co-design project with interested Recreational Sea Angler bodies, Including ‘Bluefin Tuna UK’ (which became the UKBFTA), the Angling Trust, PBA, SCBI and SACGB.
In Autumn 2022 DEFRA undertook a public consultation to assess ‘what should we do?’ with the UK’s then 48t of Bluefin Tuna quota. The conclusion of that following feedback from a range of groups and individuals was that the UK should move towards the establishment of a fully-fledged recreational catch and release fishery as well as establish a pilot rod and line commercial fishery.
International obligations.
The UK became a sovereign member of the species’ global management body, (the International Commission for the Conservation of Atlantic Tunas, ICCAT) following the finalisation of Brexit in December 2020.
As a member the UK is bound by the rules, and one key rule is that any participants in a bluefin fishery, Commercial or Recreational (including even C+R) need to be specifically ‘authorised’. In every single ICCAT member fishery this requirement has been met by a form of licensing.
Current UK fisheries regulations, as set out in the Fisheries Act 2020 do not contain any provision for the licensing of recreational fishing vessels and so a change to the Act was required. This is to be done in the form of a ‘Statutory Instrument’ that must be passed by both Houses of Parliament.
Establishing a recreational fishery.
Representatives from the UKBFTA , PBA and AT, including experienced ‘CHART’ skippers and crew were asked by DEFRA to engage with them in spring 2023 to help draft a further consultation, which would seek feedback on framework for the CRRF. We were moving from ‘should we?’ to ‘how would we?’.
These discussions, taking place over seven weeks, were concerned primarily with the legal and basic operational framework of the fishery, NOT the granular detail that we would need to agree before operations began.
Another consultation.
That process led to DEFRA launching a further eight week public consultation in July 2023, seeking feedback on the basic structure they were proposing. Whilst stakeholders advised DEFRA on the proposal, it should be noted that the proposal was DEFRA’s, and not that of the RSA sector. Indeed, stakeholder groups did disagree and still do disagree with some aspects of the proposal.
DEFRA received significant majority support for most of the proposals, which was no mean feat given the complexity of the task, and the wide range of views on some topics even within the RSA sector. The additional feedback provided by RSA stakeholders in particular was very clear on a number of areas, that we will come on to shortly.
The conclusion.
On the 8th December, DEFRA published the summary responses and their policy decision, which was to move forward to establish a CRRF in England in 2024.
This decision is very welcome to those who began lobbying for a recreational fishery in 2018. We had to win the argument for CHART and then design and deliver it to skippers and anglers. The efforts of skippers, crew and anglers in three years of CHART provided not only legal fishing opportunities that thousands of anglers took advantage of, generating millions of pounds of revenue for the SouthWest ports hosting the fleets, but also the evidence required to establish a fully-fledged recreational fishery.
Following the DEFRA publication, stakeholder groups have issued press releases on their views on the proposal, and social media platforms have seen a lot of commentary on this topic.
We thought it might be useful to try and answer some of those more frequently heard questions….
Frequently Asked Questions
So, I can just go fishing for Bluefin in England next year?
Firstly, it is NOT YET A ‘DONE DEAL’.
The ‘Statutory Instrument’ must be passed in Parliament which is scheduled for March. A ‘snap’ early election in the spring could derail that process. We are talking to DEFRA regarding managing this risk.
Assuming the SI goes through ok.
You will need to be granted a LICENSE and DEFRA/MMO are setting up that licensing regime and process. Licenses will be for the vessels/owners operating in the fishery, NOT for individual anglers who may fish on a licensed Charter Boat or a friend’s licensed private boat.
Who can get a license?
In broad terms, as the proposal stands at the moment, DEFRA’s intention is that the fishery is open to both Charter vessels and Private boat owners. Such vessels/owners may be primarily domiciled anywhere in the UK, (under the FA2020 ‘equal access rule’), BUT if they obtain a license will be required to operate in a specific area identified as ‘English waters’.
What are the criteria to get a license?
Well, a lot of the detail is still to be thrashed out in the next few months. The basic requirement is for vessels to be recorded on Part 1, 2 or 3 of the ships register. This allows the MMO to identify all vessels in the fishery. ‘Permit conditions’ can also be attached which may set further requirements. This is an area where stakeholder groups are concerned with some aspects of the design as it stands currently.
How many licenses will there be?
A CRRF requires part of the UK’s Bluefin quota to be set aside to account for potential mortalities in the fishery. It is envisaged that these will be low, in the order of 1-2% based upon the thousands of captures over three years of CHART.
So, the number of licenses has an impact upon the quota required, or looked at another way, the amount of quota secured for the fishery determines the number of licenses.
Stakeholder groups are working with DEFRA/CEFAS on detailed models to estimate how many licenses can be issued under different quota scenarios. Charter boats are estimated to use more quota than private vessels on an individual basis, but also provide a much greater socio-economic benefit to coastal communities.
It is understood that a cautious, ‘phased’ approach will be taken in year one of a CRRF, to ensure no early closure if quota is exhausted, and that the fishery will expand in following years.
Won’t it just be a closed shop for the ‘CHART skippers?’
The initial estimates based upon quota assumptions and various inputs such as days fished, CPUE, mortality rates etc, would see more licenses available than possibly requested by former CHART participants.
CHART skippers, given their existing financial investment, expertise and potential role in support and training of new entrants will be given first call on licenses in year one we understand, but additional, new entrants are anticipated from the charter sector as well as a number of private vessels.
Will there be a charge for the license?
From the start of discussions with officials, DEFRA/MMO/IFCA’s and the stakeholder bodies have agreed that a ‘reasonable’ fee should be charged for the license for a variety of reasons. One key example of this is to fund the data collection and reporting as mandated by ICCAT, and support enforcement.
If we are not paying for access we crucially could be subject to a year to year decision re funding the fishery from the general DEFRA budget. Such uncertainty would not be good for anyone….
HOWEVER, DEFRA have identified a legal, technical problem with establishing a charging regime in year one, related to the MMO’s mandate (they will issue the licenses). The INTENTION to charge for the license is clearly stated, but in year one this will not be in place.
What about ‘Commercial fishers’ of bluefin also being allowed to hold a CRRF license?
The consensus from the early CRRF discussion stages was that fishers should have to choose to hold one license or the other. This was partly to ensure that the CRRF license holders focused their efforts on the recreational fishing that we know generates many multiples of revenue per tonne than that of the commercial sector. Further concerns re complicating the enforcement regime had been voiced by several agencies as well as stakeholders. This restriction on ‘dual-hatting’ was contained in the DEFRA consultation proposal.
Subsequently DEFRA have changed their position on this and WILL allow fishers to hold both CRRF and CF licenses. ‘Economic arguments’ and legal issues have been mentioned but not detailed.
Why won’t licensed recreational fishers in the English CRRF be able to keep even one fish?
The UK has limited quota, currently 63t. That quota must be shared out in a variety of ways.
Firstly the four home nations all have a call on that quota if they desire. Secondly various sectors, Recreational, Commercial and even ‘scientific’ must share it out, and then an allowance must be set aside for incidental bycatch in non Bluefin focused fisheries.
Should the CRRF begin to retain fish, it eats up quota very quickly. In 2-3 years time we could have several hundred charter and private vessels operating in recreational fisheries across the UK. Even 150 boats taking one large fish, (250kg?) would equate to 37.5t, plus our ‘mortality related’ quota allowance….
The early discussions with DEFRA envisaged a review of the fishery after 3-4 years of operation. If that is the case and the UK may have sought and obtained additional quota from 2026 (next option) then this could be revisited, bearing in mind that there are a range of views on the merits of the recreational fishery also retaining fish and that a Catch and Release fishery with low mortality is by far the best economic use of any quota allocation.
So, it sounds promising, what are the stakeholder representative groups unhappy about?
The lack of a fee for the license and the associated funding risks are unfortunate but it appears unavoidable for 2024. We however must ensure that certainty around year to year funding is assured by DEFRA.
DEFRA have changed their position at the last minute on ‘dual-hatting’ and views on this amongst stakeholders we speak to range from ‘incandescent’ to ‘what’s the problem?’.
The UKBFTA, AT and PBA have taken a pragmatic view that even where arguments against this DEFRA change of view exist, it is extremely unlikely that DEFRA will change tack, (citing possible legal challenges), and it would be a very divisive issue. Should such ‘dual-hatting’ present a threat or damage the CRRF in any way, we will of course revisit that position.
We reiterate that we do not ‘oppose’ or ‘support’ a commercial bluefin fishery. Our focus is the delivery of a world class recreational fishery and we will only actively oppose any aspects of a Commercial Fishery if/when they impinge upon our aspirations or ability to operate our fishery.
Eligibility, training and gear/techniques. The huge success of CHART was in part (initially at least) founded upon appropriate training, experience criteria, and gear mandates.
We have never envisaged the conditions of a CRRF would be as strict as that of CHART, (which is a licensed scientific program, NOT a fishery). However, the overwhelming feedback from skippers, crew, anglers we have engaged with for the last five years is that these huge, powerful but vulnerable fish, as well as the ANGLERS deserve to be looked after and kept safe in a truly world class fishery.
The feedback in the recent consultation, and the strong majority view on social media since, is that some form of training for less experienced fishery participants, possibly some entrance criteria, and maybe some limited gear requirements would be appropriate.
We have argued that any such requirements should be part of the ‘permit conditions’. Enforcable and transparent. DEFRA’s position is that setting out such requirements as part of an unenforcable ‘Code of Conduct’ is adequate. We disagree.
You can mitigate risks from no requirement for experience, IF you have a strong basic, mandatory training regime, or vice versa. Having neither as mandatory risks very bad outcomes for anglers, fish and the reputation, or even continuation of the fishery.
Add this to free licenses in year one, not having to choose between ‘CRRF’ and ‘CF’, low eligibility criteria, all of which could see hundreds of applications, then resolved by a lottery, might see many inexperienced, untrained individuals being licensed. That is a bad recipe….
Who does the training?
Contrary to some views we have seen….. We are not talking about a group of ‘self appointed armchair anglers and jobsworths’. Many very experienced CHART skippers and crewmen have offered to form the backbone of a balanced, focused training regime….
What about enforcement?
Up to this stage, the MMO position that ‘unauthorised targeting’ (i.e. non-CHART and ThunnusUK vessels) of bluefin was ‘not permitted’, has not been enforced.
It is clear however from the draft consultation and conversations we have had that DEFRA/MMO/IFCA are serious about establishing effective enforcement in a CRRF.
Part of the SI and accompanying processes intends to establish a new offense in UK law, and set out the penalties. It remains to be seen how effective as a deterrent or a prosecution regime this may be, but things are changing from the current situation, that much is clear.
What about Wales, Northern Ireland and Scotland?
Whilst DEFRA’s mandate and intention is to establish an ENGLISH CRRF in 2024, this process is very important for the other three Home Nations.
The SI is establishing UK LEGISLATION with regards to the basic framework of recreational bluefin fisheries in the entire UK. Beyond the basic framework sits the ‘permit conditions’ that can set season, locations, and a range of other conditions as desired by the various Devolved Administration’s fisheries departments.
i.e. This work sets a framework that Wales, Northern Ireland and Scotland MAY USE, from 2024, IF THEY WISH, to move beyond their own CHART, scientific programme and into fully fledged, licensed recreational fisheries in their own waters
In conclusion…..
We hope that the above has helped make more sense of this complex issue, and maybe answered some of the questions you may have. You can contact us on
if you have further questions. Please bear in mind that the team engaged in the direct discussions is small, volunteers and with other jobs in many cases…. We will come back, but it may take a day or two.