Consultation outcome

Summary of responses

Updated 2 April 2019

1. Overview

1.1 Introduction

This document provides a summary of responses to Defra’s consultation on proposals to introduce Inshore Vessel Monitoring System (I-VMS) legislation requiring all licensed British fishing boats under 12 metres in length to install and maintain I-VMS when fishing in English waters. English boats (i.e. those boats than are registered at an English port) under 12 metres will also be covered by the I-VMS requirements wherever that boat is fishing. This document includes the government’s response to queries raised by respondents.

The consultation ran from 4 October 2018 to 14 November 2018. The aim of this document is to provide a summary of the responses received and how the government is responding to those. It does not offer a detailed opinion on the comments received.

1.2 Background

A Centre for Environment, Fisheries and Aquaculture Science (CEFAS) report commissioned by the Marine Management Organisation (MMO)^{[footnote 1]} identified a number of gaps and anomalies in existing data collection methods. The catches observed were found to be higher than those recorded which could affect sustainability and distort the fleets’ track record. The report concluded that if we are to meet our commitments to sustainability and demonstrate this to trading partners we need to improve our management and enforcement capability of the fleet and stocks.

The government recognises that there is more we can do to improve data gathering and sharing and gain an enhanced understanding of the activities of licensed British under 12 metre fishing vessels operating in English waters. We need to create sustainable fisheries for the future through more effective enforcement and better informed management. Combined with the MMO’s project to require catch reporting for vessels under 10 metres in length, the installation of an inshore vessel monitoring system will provide the government and fisheries management authorities with a greater understanding of fishing activity in English waters.

Monitoring systems like VMS play a crucial role in developing a framework for fisheries management that is both profitable and sustainable – and that allows all sections of our fleet to thrive. Currently, VMS is only required on fishing vessels 12 metres and over in length.

The policy objective of this proposal is to gain better information on where all licensed British fishing boats under 12 metres in length operating in English waters are fishing. Extending vessel monitoring to all inshore vessels will provide a more accurate picture on fishing location and activity. This policy proposal will broadly align the requirement for VMS across the whole fleet thus improve understanding of the entire fishing activity of our fleet. In turn this will help inform future fisheries management, enabling a more fair and efficient approach.

I-VMS records the accurate location, speed and heading of vessels using a secure tamper resistant system. It sends this information to an established hub using mobile telephone technology. This information can be assessed in the field using a secure access web platform and is recorded allowing risk-based intelligence led analysis. Vessel owners will simply need to have a working unit installed on their vessel in order to demonstrate compliance.

English waters in this instance means British Fishery Limits (out to 200 nautical miles or the median line where Exclusive Economic Zones (EEZs) meet) excluding the Northern Ireland, Scottish and Welsh zones, and excluding the territorial seas adjacent to the Isle of Man and the Channel Islands. British fishing boats registered in a port in Scotland, Wales, Northern Ireland and England and British-owned fishing boats will be covered by the I-VMS legislation when operating in English waters. Fishing boats owned by Crown Dependency citizens, and British boats registered in the Isle of Man or the Channel Islands, operating in English waters will also be covered. English registered boats under 12 metres will also be covered by the I-VMS requirements wherever they are fishing. Depending on any agreed access of EU or foreign vessels post-Brexit, a similar requirement would be applied to such vessels insofar as that is possible. Depending on any agreed access post-Brexit, this could be required via a separate statutory instrument.

The following categories of boat are captured within the term “licensed British fishing boat”:

• fishing boats that are registered in the United Kingdom
• fishing boats that are “British-owned”
• British fishing boats registered in the Isle of Man, or any of the Channel Islands

British-owned means owned by:

• a British citizen (this includes a Crown Dependency citizen but not a Crown dependency corporation)
• an EU National exercising their right of establishment in the UK
• a Corporate body in the UK (or in an EU member state with a place of business in the UK)
• a European Economic Grouping registered in the UK
• a UK local authority

The consultation set out proposals to introduce I-VMS for all owners or operators of licensed British fishing boats under 12 metres in length operating in English waters. We invited views on the following topics:

• question 1 – Do you agree with the proposal that I-VMS is needed on under 12 metre vessels? Yes / No, please provide comments below in support of your view
• question 2 – What alternative approaches could be taken to achieve the same aim?
• question 3 – What are your views on the costs and benefits as set out in the Regulatory Triage Assessment, do you agree with them? Yes / No, please provide comments below in support of your view
• question 4 – Do you agree with the analysis of the costs and benefits as set out in the Regulatory Triage Assessment? Yes / No, please provide comments below in support of your view
• question 5 – Are there any costs or benefits that have not been identified in the Regulatory Triage Assessment? What evidence do you have to support this?
• question 6 – Are there any further comments you would like to make on the impact of the proposal?

1.3 Number and categories of responses

In response to the consultation, Defra received contributions from 181 respondents. These responses were received online via the consultation website (Citizen Space), email and by letter. All responses were considered. The government would like to thank all those who took the time to provide feedback on this policy proposal.

Respondents who chose to respond online were asked for their organisation name and their sector or interest. Some respondents who sent their response in an email or a letter also declared their organisation, sector or interest; others did not. Similarly, some respondents who responded online did not declare this information.

2. Summary of responses

2.1 Overview of responses

There were mixed responses to the proposal to introduce I-VMS for all owners or operators of licensed British fishing boats under 12 metres in length operating in English waters. Some respondents did not respond directly to the consultation questions and others offered general comments about fisheries management.

The main benefits outlined by respondents who supported the proposed legislation included:

• improved enforcement, monitoring and fisheries management
• managed access to Marine Protected Areas (MPAs)
• deters Illegal, Unreported and Unregulated (IUU) fishing
• useful tool for stock management, traceability and sustainability

The main issues that were raised by respondents who opposed the proposed legislation included:

• the cost of implementing I-VMS and downtime costs
• privacy including access and use of data
• operational issues such as running I-VMS on a vessel with low/no power
• the relevance for monitoring smaller vessels in comparison to vessels 12 metres and over in length
• discrimination against the fishing industry

Each topic will be explored in further detail in the analysis of the consultation questions below.

2.2 Responses to question 1 – Do you agree with the proposal that I-VMS is needed on under 12 metre vessels?

We asked whether respondents agreed with the proposal that I-VMS is needed on under 12 metre vessels. Several respondents expressed a range of views both in support of the proposal and in objection.

Respondents who agreed with the introduction of I-VMS to the under 12 metre fleet predominantly stated that it would improve monitoring, enforcement and compliance. In addition the contribution of this proposal to fisheries management was also highlighted, particularly for understanding the spatial-temporal distribution of fishing effort. On occasion, respondents also stated that I-VMS as a monitoring tool would allow enforcement resources to be deployed more efficiently and effectively.

Many respondents stated that I-VMS was crucial for the management of MPAs. It would both discourage fishing in no take zones whilst also enabling access to specific areas. In terms of sustainability, many respondents also stated that the proposal would help manage stocks, aid traceability and guard against IUU fishing activities. In addition, a small number of respondents referred to alternative benefits such as the protection of marine heritage sites and the reduction in protected species bycatch.

Several respondents also referred to the scientific value of collating spatial-temporal data, the ecological and safety benefits (for example preventing collisions at sea) and the alignment with VMS requirements for the 12 metre and over fleet. Conflict resolution was also referred to by many respondents as a benefit, both in terms of conflict between fishers (for example gear conflict) or conflict between fishers and other industries. Some respondents also regarded marine planning as a notable benefit, stating that I-VMS would provide adequate evidence of fishing activity for spatial planning.

Many respondents raised practical concerns with I-VMS devices. The most frequent concerns were in regards to installation in small spaces and installation without electrical power. Many respondents also objected to the proposal, stating that it would be unreasonable and disproportionate for smaller vessels. These concerns were raised in comparison to the 12 metre and over fleet. Many respondents offered alternative proposals such as a requirement on over 7 metre vessels only.

Privacy and unnecessary bureaucracy were also objections stated by many. In regards to privacy, respondents were concerned that a requirement to have an I-VMS device would be an invasion on fishers’ privacy and would identify potential fishing grounds to other fishers. Many respondents also raised concerns with the use of I-VMS data and sought clarification over who would have access. Several respondents also suggested the use of Automated Identification Systems (AIS), catch reports and sales notes as alternative tools for understanding the fishing activities of the under 12 metre fleet.

In addition, several respondents also referred to the proposal as discrimination against English vessels and fishers in general, questioning why the proposal did not apply to all UK vessels regardless of devolved administration. On occasion respondents suggested the extension of the proposal to all third country and EU vessels fishing in UK waters.

Government response

Privacy and use of I-VMS data

I-VMS is a closed data system, unlike AIS. Fishers would not be able to see the location, speed or direction of another’s fishing vessel. The data will be visible to enforcement regulators (the MMO and IFCAs in England) and the UK Fisheries Administrations (Devolved Administrations and Crown Dependencies). In addition, the UK currently exchanges VMS data with the EU via a secure one-to-one connection, which directly connects the UK VMS hub to Member State VMS hubs. Data is automatically forwarded by a Member State’s VMS hub when a report is generated for a vessel fishing in waters of another Member State and vice versa.

All UK Fisheries Administrations have shared access to the UK VMS Hub which I-VMS data will feed into. The data is also shared with the National Maritime Information Centre (NMIC) for the coordination of at sea surveillance assets. For clarity, the IFCAs’ enforcement jurisdiction extends from 0-6 nautical miles, and MMO jurisdiction extends to 200 nautical miles or the EEZ median line. In instances where data is used to inform future policy, evidence bases and statistical and science research, all data will be anonymised. Compliance with data protection legislation (the Data Protection Act 2018 and the General Data Protection Regulation (GDPR) by data processors would minimise any privacy risks. Fishers will have access to their own data. Suppliers are also providing access to vessel owners to view data of their fishing vessel via the supplier’s web portal. The MMO is also able to provide data to vessel owners if they are able to prove they are the owner and are identified as the licence holder.

This data may be used to develop business plans and to demonstrate a track record in catching species of fish. For example, we have previously required fishermen to demonstrate they have a track record in catching a certain species of fish. If they have I-VMS and catch reporting data they could meet this requirement, e.g. for bass.

Other concerns were raised in relation to I-VMS data being used to identify fishing activity in criminal prosecutions. I-VMS data will be used to inform and target risk based intelligence led enforcement. The data may be used as supporting evidence as part of a prosecution against a vessel.

Practical issues

Every effort has been made to mitigate the known risks involved in the operational implementation of I-VMS. The MMO are aware of some of the practical issues that can affect vessels that have no wheelhouse or on-board electrics and is working hard with potential suppliers to explore all the possible options in order to implement a robust and fit for purpose solution for these boats.

In regards to associated safety/fire risks, the government takes safety at sea seriously and as stated above, all units will have been rigorously tested to ensure they are safe to be installed on vessels. In addition, the majority of the under 12 metre fleet already have electronic equipment on board and as a result this is not considered to be a concern.

I-VMS devices can store data and transmit once in range of a mobile signal. This ensures that vessel location data history is always available to enforcement regulators. The use of real time data would require satellite transmission and as a result, increased costs to industry. The government does not think that would be proportionate for the under 12 metre fleet at this stage.

Suitability of I-VMS for vessels under 12 metres in length

As there are over 2,600 vessels under 12 metre in length that fish on average 63,000 tonnes of fish per year (on average worth £138 million), it is vitally important for regulators and policy makers to gain a better understanding of fishing activity for the entire inshore fleet. The government and the MMO have developed this proposal in light of experience and insight gained from the VMS project applying to vessels 12 metre and over. As a result, great care has been taken to consider and mitigate for all known risks.

Inshore fishing activity is currently unquantifiable. The government does not wish to prevent any fleet from functioning however there is a need to understand where a fleet functions, the spatial footprint and the impact of all fishers. Therefore it is crucial that the activity of the under 12 metre fleet is understood in its own right. The 12 metre and over fleet represents a different fishing sector with its own environmental impacts. This proposal does not seek to gain an understanding of the comparative impacts of these two fleets.

Several respondents were keen for smaller vessels to be exempt from the proposal, in particular vessels under 7 metres on the basis that the level of impact smaller vessels have on the marine environment is different to that of a 12 metre vessel. As I-VMS is an enforcement tool, regulators are not concerned with the size of a vessel but rather their location and its activity. The introduction of any exemptions would provide regulators or policy makers with an inaccurate picture of activity in inshore waters.

One respondent referred to the 3 minute reporting frequency for I-VMS and the disparity to a 2 hour reporting frequency for VMS on vessels 12 metres and over. VMS reporting for vessels 12 metres and over is in line with the EU Control Regulation (1224/2009), the I-VMS proposal is domestic legislation and therefore the selection of a reporting frequency is flexible. An increased reporting frequency for under 12 metre vessels was deemed necessary as smaller vessels have the ability to enter and exit a Marine Protected Area (MPA) within the space of a 2 hour reporting frequency. In addition, the reporting frequency rate for a vessel 12 metres and over can be increased by regulators if a vessel is fishing within certain areas such as MPAs.

Devolved administrations and non-UK vessels

Fisheries control and enforcement is a devolved matter. Scotland, Wales and Northern Ireland are all currently working on I-VMS projects for their under 12 metre fleets. In Scotland many vessels by 2020 will have some form of tracking device fitted that will provide spatial data. In Wales, the implementation of inshore VMS is estimated for completion in early 2020 and will be delivered through the European Maritime and Fisheries Fund (EMFF). In Northern Ireland, a pilot I-VMS scheme on 10m and under vessels was launched in December 2018. Subject to the return of the Northern Ireland Executive, the department intend to extend I-VMS to all vessels under 12 metres. All devolved administrations are adopting similar policy proposals. This policy will align and complement enforcement regulations across the UK.

This proposed legislation does not extend to third countries and other Member States’ vessels, however, post Brexit any foreign vessels granted access to fish in UK waters may need to meet the same requirements as our fleets across all UK fishing zones, including adherence to sustainable practices.

Alternative tools

Catch reports and sales notes are useful fisheries management tools. Catch reports are not currently submitted by the under 10 metre fleet and for vessels between 10 and 12 metre fleet these reports are paper-based. Sales notes are not mandatory because of a range of exemptions for vessels under 10 metre in length (e.g. annual financial turnover, minimum buyer quantity, minimum landing quantity etc). Incomplete catch data and reporting inaccuracies were highlighted in a European Court of Auditors report published in 2017^{[footnote 2]} which stated that many member state fleets are not monitored by VMS which was hindering effective fisheries management.

Several respondents queried the use of Automated Identification Systems (AIS) technology as an alternative approach to I-VMS on under 12 metre vessels. For the government’s response regarding this point please refer to question 2.

Consultation process

This consultation was carried out in accordance with the Code of Practice on government consultations and guidance published by the Cabinet Office.

The consultation process is designed to receive feedback from all relevant stakeholders, with a great level of consideration given to the feedback received in deciding whether to develop the policy proposal further. The entire process is designed to bring about a greater level of transparency to government policy making.

2.3 Responses to question 2 – What alternative approaches could be taken to achieve the same aim?

We asked whether respondents had any suggestions for alternative approaches that would be able to achieve the same aim as I-VMS. We received mixed responses to Question 2. Many respondents stated that there was no viable alternative approach. These respondents indicated I-VMS was the only viable cost-effective option.

Several respondents suggested utilising Automatic Identification Systems (AIS) rather than using I-VMS. A small number of respondents suggested an increase in the number of enforcement agency vessels and aircraft.

Government response

Automatic Identification System (AIS)

One of the main reasons AIS is not considered a viable approach is due to privacy concerns. AIS is an open-source system, which means all data is publicly accessible for any given fishing vessel with AIS installed. This includes information relating to a fishing vessels’ location, direction of travel and type of vessel. The data will be visible to enforcement regulators across all UK fisheries administrations and Crown Dependencies and the European Union. AIS is not considered a suitable enforcement system for smaller vessels.

An additional benefit of I-VMS is its tamper-proof design. Unlike I-VMS, AIS can be switched off, which could cause safety issues for the industry and reputational issues for Defra by implementing an enforcement system that may be tampered with.

I-VMS will help ensure enforcement regulators have a complete picture of all British fishing vessels under 12 metres in length fishing in English waters.

Increased enforcement capacity

It is important to note I-VMS records the accurate location, speed and heading of vessels. We are unable to collect this level and depth of data by simply increasing our enforcement capacity. This policy approach is considered the most effective way to monitor the inshore fleet’s fishing activity.

This does not mean the government is not considering an increase in enforcement capacity for the protection of our fisheries. The government has already taken steps to increase our level of enforcement capacity and capability. The MMO has assessed, and continues to assess, the levels of enforcement capacity required for fisheries protection and the options for best delivering this.

In preparation for our departure from the European Union, we are undertaking a significant increase in the number of personnel and surveillance assets relating to fisheries protection with a sizeable increase in support in place by March 2019. Additional capacity will be comprised of an increase in personnel, an increase in the number of planes available for aerial surveillance and an increase in the level of at-sea surveillance.

2.4 Responses to question 3 – What are your views on the costs and benefits as set out in the Regulatory Triage Assessment, do you agree with them?

Several respondents expressed a range of views both in support and objection of the cost-benefit analysis. Many respondents were supportive of the costs and benefit analysis set out in the Regulatory Triage Assessment (RTA). These respondents considered the financial cost to be appropriate and reasonable. Respondents particularly noted the benefits I-VMS would bring towards the management of MPAs.

The majority of respondents who disagreed with the costs and benefits of I-VMS as set out in the RTA predominantly raised concerns regarding the financial cost burden to the fishing industry, both in terms of reporting and downtime costs in the event of a device requiring repair.

Government response

Financial cost

The initial cost of the I-VMS unit (approximately £1,280 including installation per device) is being met by the European Maritime and Fisheries Fund (EMFF). There will be no cost to individual fishers for the initial device or its installation.

In order to introduce I-VMS to under 12 metre vessels, the cost to industry is limited to reporting costs, repairs, replacement costs and the option of purchasing an extended warranty.

As outlined in the RTA, reporting costs will average at around £142/year per vessel based on information received from suppliers. This equates to £2.73 per week. The government considers these costs to be reasonable and appropriate.

With regard to repairs, it will be a matter of whether damage is incurred and the severity of that damage. This is therefore not possible to quantify.

The cost to replace a unit is estimated at approximately £1,280 per unit. In terms of lifespan of the I-VMS units, suppliers have indicated their device would work for longer than five years, but similar to a mobile phone, become outdated at that point. Additionally it is likely that in future year’s I-VMS units may cost less and reduce in size as we see technological improvements.

In regards to downtime cost, vessel owners are responsible for ensuring a working I-VMS unit is on their vessel at all times. We encourage vessel owners to speak to suppliers to make any further warranty arrangements.

2.5 Responses to question 4 – are there any costs or benefits that have not been identified in the Regulatory Triage Assessment? What evidence do you have to support this?

The majority of respondents pointed out the financial burden of replacement cost for I-VMS units.

Many respondents questioned the longevity and integrity of I-VMS units, suggesting the cost to industry will be higher than identified in the RTA.

Many respondents also highlighted the financial cost associated with the time lost at sea for damaged or faulty equipment. Respondents also referred to the cost burden of paying for reporting costs throughout the year when inshore fishers are conditioned by the weather, seasonal fish and other factors.

A small number of respondents also highlighted the time lost from a faulty or damaged I-VMS unit increases the likelihood of the amount of ghost gear.

Government response

As identified above, the owner of a fishing vessel is responsible for establishing warranty conditions dependent on their own risk appetite. The government has maximised its efforts to limit the financial burden of this policy through the use of EMFF and government funding.

With regard to the integrity of I-VMS devices, all approved units will have undergone a thorough testing process. The trialling of I-VMS units has indicated they will be suitable in all expected weather conditions.

All I-VMS units are MMO approved and have been rigorously tested and type-approved to ensure they are fit for purpose. MMO and IFCA representatives administrate the Approval Programme and validate submitted products against a specification of requirements through an audit and technical validation process. Each of the current suppliers offers a free 2 year warranty which can be further extended after the period ends. Vessel owners are responsible for choosing the warranty conditions direct with the supplier. The cost of extending the 2 year warranty will entirely depend on an individual’s risk appetite and personal choice.

Fishing vessel owners are responsible for ensuring they have a working I-VMS installed at all times. The RTA has outlined the annual cost of I-VMS incurred to fishers. The government considers this financial cost to be reasonable. I-VMS is the most cost-effective solution in achieving the intended policy outcome.

In regards to the implication that there will be an increased amount of ghost gear as a result of fishers being unable to collect gear due to a non-functioning device, if fishers are unable to retrieve their lost gear they must notify the UK fisheries authorities. For the purposes of fisheries enforcement, clear guidance is in place that requires masters of a fishing vessel using static gear or beam trawls to mark their fishing gear so that it is identifiable.

2.6 Responses to question 5 – are there any further comments you would like to make on the impact of the proposal?

The majority of respondents to the consultation did not include any further comments to this question.

Most of those who responded reiterated the financial costs associated with the introduction of I-VMS, suggesting that this policy would over-burden industry.

A small number of respondents reiterated points previously raised including the disproportionality of I-VMS in comparison to the 12 metre and over fleet.

A small number of respondents reiterated the practical concerns of installing I-VMS particularly on smaller vessels with no wheelhouse or on-board electrics.

Government response

The financial burden associated with I-VMS has been limited to:

• reporting costs
• ongoing costs, repairs and replacement costs
• extended warranty

The government considers each of these financial costs to be reasonable and appropriate.

The reporting costs are estimated to cost fishers £2.73/week. This is considered a low and reasonable cost.

There are no known ongoing maintenance costs for I-VMS units, i.e. they do not need to be serviced each year. It will be a matter of whether damage is incurred and the severity of that damage. This is therefore not possible to quantify.

With regard to repairs, it will be a matter of whether damage is incurred and the severity of that damage. This is therefore not possible to quantify.

The cost to replace an entire unit is estimated at approximately £1,280 per unit. In terms of lifespan of the I-VMS units, suppliers have indicated their device would work for longer than five years, but similar to a mobile phone, become outdated at that point. Additionally it is likely that in future year’s I-VMS units may cost less and reduce in size as we see technological improvements.

Vessel owners may wish to extend the initial two year warranty. Fishers are responsible for making arrangements with their suppliers over an extended warranty. An extended warranty is estimated costing between £120 and £360 per annum. Ultimately the choice of the warranty and the cost paid is dependent on the risk appetite and personal choice of the vessel owner.

With regard to the proportionality concern, the purpose of introducing I-VMS is to gain a better understanding of our under 12 metre fleet. For the purposes of enforcement, it is vitally important that regulators have a complete picture of all vessels fishing in our waters. The introduction of I-VMS will play a significant part in aiding the risk-based intelligence-led enforcement regime carried out by the MMO and IFCAs.

Every effort has been made to mitigate the known risks involved in the operational implementation of I-VMS. The MMO is aware of some of the practical issues that can affect vessels that have no wheelhouse or on-board electrics and solutions are available. The MMO is working hard with potential suppliers to explore all the possible options in order to implement a robust and fit for purpose solution for boats with restricted power supply.

We would like to thank all those that took the time and effort to contribute and respond to this consultation.

3. Next steps

This requirement will be implemented via a statutory instrument. The date of implementation is not expected to be before 2021 to allow for the roll-out of an I-VMS solution on all under 12 metre vessels. The Marine Management Organisation will notify vessel owners accordingly.

Depending on any agreed access of EU or foreign vessels post-Brexit, a similar requirement would be applied to such vessels.

For further information please contact the I-VMS coordinator at: [email protected]

4. List of organisations who responded to the consultation

Angling Trust

Angling-School CIC

Barrow Licensed Fishermen’s Association

Bembridge Angling Club

Bridport Commercial Boat Owners and Fishermen’s Association

Brixham Sea Angling Club South Devon

Bude Marine Group (BMG)

Chartered Institute for Archaeologists

Cornwall Seal Group Research Trust

Dorset Fish & Shellfish Ltd

Dorset Wildlife Trust

European Submarine Cable Association (ESCA)

Evidence in Practice LLP

Felixstowe Ferry Fishermen’s association

Fjordr Ltd.

Global Fishing Watch

Harwich Harbour Fishermen’s Association

Institute of Marine Sciences

Joint Nautical Archaeology Policy Committee

MacAlister Elliott and Partners Ltd

Marine Conservation Society

Mudeford and District Fishermen’s Association

Natural England

North Eastern Inshore Fisheries and Conservation Authority

Plymouth Trawler Agents Ltd

Poole and District Fishermen’s Association

Providence Fishing Co Ltd

Renaissance of East Anglian Fishing Conference

RenewableUK

Seafish

SeaScope Fisheries Research Ltd

Solway Shell Fishermen’s Association

South Devon and Channel Shellfishermen Ltd.

Sussex Inshore Fisheries Conservation Authority

Swanage Fishermen’s Association

Thanet Fishermen’s Association

University of Exeter

University of Portsmouth

University of York

Whitby Seafoods Ltd

1. UK Technical Report for the Collection and Management of Fisheries Data (2012) ↩

2. European Court of Auditors ‘EU fisheries controls: more effort needed’ (No 8, 2017) ↩