Consultation outcome

Summary of responses and government response

Updated 7 December 2023

Introduction  

From 17 July to 4 September 2023, Defra consulted on establishing permitting regimes for the recreational targeting of bluefin tuna in UK waters. The consultation was conducted predominantly using Citizen Space, our online consultation tool, and was supplemented by face-to-face meetings with stakeholders at local ports in England, virtual meetings with stakeholders and email communication. 

This document covers the ‘summary of responses’ received to the consultation as well as the ‘government response’. 

The analysis presented in the ‘summary of responses’ is based on the formal responses to the consultation which we received through Citizen Space and by email, but we have taken account of all views expressed in other discussions, to develop the government response.

Background

Eastern Atlantic bluefin tuna (BFT) (Thunnus thynnus) is present again in UK waters after an absence of many years, most probably due to changes to environmental or prey conditions. This is not an isolated development. In 2021, the International Union for the Conservation of Nature (IUCN) changed their entry for BFT from “endangered” to “least concern” reflecting the improving state of the stock.

The increasing abundance of BFT in UK waters is generating interest from both commercial and recreational fishers as well as the science community and environmental non-governmental organisations (eNGOs). BFT is highly regulated at an international level, through the International Commission for the Conservation of Atlantic Tunas (ICCAT). In 2021, after leaving the EU, the UK established its own BFT quota for the first time.

This presents an opportunity to develop BFT fisheries in UK waters which meet the interests of the commercial and recreational sectors while respecting the environment and ensuring compliance with both international standards and domestic legislation.

The UK has in the last few years operated successful scientific catch and release tagging (CHART) programmes. Read the Cefas CHART 2021 programme review for more information. These programmes demonstrated that BFT can be caught and released with a very low incidental mortality rate while providing data on the social and economic benefits associated with recreational access to BFT.

Defra is currently running a small, UK-wide, trial commercial BFT fishery, enabling 10 under-15 metre commercial fishing vessels to fish for BFT using low impact rod and reel gear. This document does not cover the future of the trial commercial BFT fishery, which will be evaluated once the trial has closed.

Summary of responses – overview

Number of responses

167 responses were received, 165 via Citizen Space (our online consultation tool) and 2 via email. In the consultation, we asked respondents to categorise themselves based on their interest in the fishery:

• 21 respondents categorised themselves as a ‘Recreational fishing charter vessel owner or  charterer that may want to participate in a future fishery’
• 74 respondents categorised themselves as a ‘Private recreational fishing charter vessel owner or user that may want to participate in a future fishery’
• 48 respondents categorised themselves as a ‘Recreational fisher’
• 4 respondents categorised themselves as a ‘Conservationist’
• 15 respondents chose ‘Other’ – this included several organisations representing the recreational fishing sector
• 5 respondents did not answer this question in the consultation

A list of relevant organisations who responded to the consultation is set out in Annex 1. 11 respondents stated they wished for their response to be kept confidential, so the names of the organisations listed by these respondents have been omitted. Annex 2 shows a breakdown of how stakeholders in each category responded to each consultation question.

There was a small amount of duplication in responses from the recreational angling sector. As duplicate responses were received in relatively low volumes, we have treated them as individual responses rather than as a campaign.

Methodology

Most consultation questions included both a ‘yes’ or ‘no’ part, as well as the opportunity to provide comments. The ‘yes’ and ‘no’ responses have been quantified. Due to the qualitative nature of the comments a thematic analysis was conducted. Each response was analysed twice to identify both the themes raised by respondents and policy recommendations put forward. The responses to each question were summarised to produce the overall summary of responses.

Headline messages

Of the 167 responses, the vast majority of respondents (139, 83%), across all interested groups, broadly supported the proposed design for the new UK permitting regimes for the recreational targeting of BFT.

Of those respondents not in favour, the vast majority supported the concept of recreational BFT fisheries but had specific concerns about the proposed design. Only 7 respondents (4%) fundamentally objected to the concept of a BFT catch and release recreational fishery (CRRF). Reasons ranged from not supporting any regulation for recreational sea fishing to objecting to any fisheries exploitation of BFT, even when catch and release.

Noting the high levels of overall support, several concerns appeared as recurrent themes throughout the consultation responses. These were:

• permit charges
• fishery standards and enforcement
• phased roll out and scale of the fishery
• parity with the commercial sector

Permit charges

There was broad support (over 75%) for charging, but respondents sought more information on the level and use of charges. Many stated that charges should be fair and affordable, with charge income being used to improve the fishery.

Fishery standards and enforcement

The majority of respondents (over 80%) supported the use of permit conditions and a voluntary code of conduct to drive fishery standards. However, concerns were raised about the ability of regulators to hold participants to these standards. Multiple respondents called for mandatory training in catch and release techniques. Concerns about the ability of regulators to enforce against recreational fishers operating outside of a BFT CRRF were also raised.

Phased roll out and scale of the fishery

The consultation did not include specific questions about the phased roll out and scale of the fishery. However, respondents articulated a desire to see more access to the fishery in year one than just vessels that have previously participated in CHART. Several also argued that, based on the socio-economic benefits of a BFT CRRF as compared to the economic benefits of a commercial BFT fishery, sufficient quota should be allocated to allow any eligible applicants to participate in the fishery.

Parity with the commercial sector

Throughout the responses there was a desire for the full socio-economic benefits of BFT CRRFs to be taken into account in decision making and for parity with the commercial sector, including on permit charges and access to fisheries grant funding.

Summary of responses – by question

Overarching approach

The consultation document set out key design principles for BFT CRRFs:

“ICCAT requires vessels participating in a recreational BFT fishery to be authorised. However, in the UK, recreational vessels are currently exempted from fisheries licensing. Therefore, to enable the establishment of CRRFs for BFT, we propose introducing new secondary legislation to prohibit the unauthorised targeting of BFT across the UK and to introduce permitting regimes for the recreational targeting of BFT, for each of the UK’s 4 fisheries administrations (FAs). The key design principles for the UK’s permitting regimes are as follows:

• All permitted recreational fishing for BFT will be on a catch and release only basis. The new permitting regimes will be constrained to issuing non-transferable, time-limited permits, for catch and release purposes only. Catch and release fishing means that BFT can potentially be caught more than once, allowing more fishers to target BFT to increase the associated social and economic benefits. There will be no provision for the recreational boarding, retaining or keeping of BFT.
• It will be for each UK FA to determine if, and when, to introduce a CRRF in its waters. Eligible vessels registered anywhere in the UK will be able to apply to participate in any of the UK’s CRRFs, to comply with the Fisheries Act 2020 (FA2020) equal access objective.
• Quota will be held centrally, at either the UK or FA level, to allow it to be used more efficiently and effectively. A successful fishing trip will not use any quota, but quota will be required to account for incidental BFT mortality, so the amount of quota available will determine the maximum number of permits offered.
• Permits will be chargeable, to cover costs associated with the fishery.
• It will be an offence to target BFT without a permit.”

“In order to prepare for implementation in 2024, we have developed a more detailed operational design for the English CRRF. The key design principles for the English CRRF are as follows:

• Defra and the Marine Management Organisation (MMO) will seek to co-design the fishery with the recreational sea fishing (RSF) sector, to build a fishery culture where individual fishers and the wider RSF community perform a key role as stewards of the fishery.
• The fishery will initially operate within a relatively light touch regulatory framework. Voluntary measures to protect fish welfare and minimise environmental impacts will be set out in a code of conduct. This will be supported by mandatory operating requirements set out in secondary legislation and permitting conditions, which the relevant authorities will be able to enforce.
• Defra and MMO will take a phased implementation approach to this novel fishery, initially prioritising access for vessels that will be operated by those with proven experience in the successful release of BFT.
• Over time, the fishery is expected to be opened up to more vessels, this will maximise social and economic benefits, improve fishery operability and support fishers to embrace their role as stewards of the BFT fishery.”

Question 1 asked respondents whether they supported these principles.

Question 1: Do you broadly support the design for the new UK permitting regimes for the recreational targeting of BFT?

Response	Number of respondents
Yes	139 (83%)
No	27 (17%)
Unclear or no response to question	1 (0%)

166 out of 167 respondents provided a response to this question.

Of those that answered the question, 139 stated they broadly supported the design for the new UK permitting regime for the recreational targeting of BFT. This included 3 out of 4 conservationists. A small number of these positive respondents gave caveats, which were aligned with themes raised by negative respondents.

Of the 27 respondents who answered ‘no’, all provided comments. Most set out concerns about the details of the proposed design, as opposed to the core concept of the BFT CRRF. The most common themes were:

• calls not to restrict permits to skippers with previous CHART experience (several respondents questioned how this would signify progress from the CHART programme)
• concerns about how constraining access to the fishery too much in year one could increase the risk of illegal fishing
• concerns about standards in the fishery (several questioned the proposed voluntary code of conduct and how this will be enforced)
• concerns about charging (some called for charges to be capped and others asked that funding was ringfenced for the development of the sector)
• concerns that the allocation of quota to BFT CRRFs would be based on an underestimate of the economic value of the RSF sector
• that further details and discussions with the sector are needed before proceeding

The following views were shared in smaller numbers:

• recreational anglers should not be restricted by a permitting regime
• limited catch retention should be allowed
• the proposals would not be enforceable
• any exploitation of BFT, even catch and release, could result in unintended mortality and welfare impacts

A few respondents sought further clarification on matters including who would be eligible to apply for permits in year one and how charter boats and private boats will be integrated into the fishery. This is referred to in our government response.

Commercial fishing vessels access to BFT CRRFs

The consultation document set out that “the proposed permit regimes will apply to UK recreational fishing vessels only. Commercial fishing vessels will not be eligible for recreational BFT permits.”

Question 2 asked respondents whether they supported this approach.

Question 2: Do you support this approach to commercial fishing vessel access to CRRFs?

Response	Number of respondents
Yes	128 (77%)
No	38 (23%)
Unclear or no response to question	1 (0%)

166 out of 167 respondents provided a response to this question.

Of those that answered the question, 128 stated they supported the proposal that commercial fishing vessels would not be eligible for recreational BFT permits.

Of the 38 respondents who answered ‘no’, 37 provided comments. The most common themes were:

• allow dual licensing, so commercial vessels can apply for access to both commercial and recreational BFT access
• allow commercial fishing vessels to choose whether to access the commercial or recreational fishery, but do not allow them to access both simultaneously
• do not allow dual licensing, as this could leave the system open to abuse by commercial fishermen
• more details needed, specifically on whether the restriction will be placed on the vessel, owner or skipper – this is addressed in the government response

The following comments were raised in smaller numbers:

• recreational anglers should not be restricted by a permitting regime
• consider an alternative approach of commercial and recreational zones

Determining the number of permits available in the English CRRF

The consultation document set out that “In the English CRRF, a fisheries model calibrated with best available data will be used to determine the number of permits available, based on estimated incidental mortality rates. Vessel level effort controls may be applied to limit the amount of fishing activity each vessel is permitted to undertake in order to increase the number of permits available and maximise social and economic benefits. Defra have committed to work with the RSF sector stakeholders to refine the fisheries model.”

Question 3 asked respondents whether they supported this approach.

Question 3: Do you support the proposed approach to determining the number of permits available in the English CRRF?

Response	Number of respondents
Yes	125 (75%)
No	40 (24%)
Unclear or no response to question	2 (1%)

165 out of 167 respondents provided a response to this question.

Of those that answered the question, 125 stated they supported the proposed approach to determining the number of permits available in the English BFT CRRF. One of those in favour of the proposed approach did so with the caveat that anglers using the lowest impact methods should be prioritised.

Of the 40 respondents not in favour of the permitting regime, 33 provided comments. The most common themes were:

• that the number of applications made for recreational permits should determine the quota allocated to the fishery, so permit numbers would not need to be capped
• that the allocation criteria should not be limited to those with previous CHART experience

The following comments were raised in smaller numbers:

• training should be made mandatory for all permit holders
• allocate permits on a local basis to prevent concentration of vessels in a single area
• data collection (in addition to the categories required by ICCAT) should be a mandatory condition of a permit, including accurate incidental mortality reporting
• effort controls should not be implemented, as this could encourage illegal fishing
• effort controls should be considered as a tool to protect charter vessels from having to cancel trips in season

Allocation in the event of oversubscription in the English CRRF

The consultation document set out that “In the English CRRF, in the event of oversubscription Defra and MMO will initially consider whether vessel level effort controls could be used to limit vessel level fishing activity and increase the number of permits available. If the fishery remains oversubscribed following this action, then MMO will rank applications based on allocation criteria. A lottery will be used as a last resort.”

Question 4 asked respondents whether they supported this approach.

Question 4: Do you support the approach to allocating permits in the event of oversubscription, proposed for the English CRRF?

Response	Number of respondents
Yes	126 (75%)
No	38 (23%)
Unclear or no response to question	3 (2%)

164 out of 167 respondents provided a response to this question.

Of those that answered the question, 126 stated that they support the approach to allocating permits in the event of oversubscription that was proposed for the English BFT CRRF. This figure held true across the different interest groups.

Of the 38 respondents not in favour of the permitting regime, 33 provided comments. The most common themes were:

• that the number of applications made for recreational permits should determine the quota allocated to the fishery, so that permit numbers should not be capped
• that private vessels should be permitted into the fishery from the start
• that the allocation criteria should not be limited to those with previous CHART experience
• that effort controls are supported as a ‘least bad’ option if it is what is required to keep the fishery open (some did not support effort controls in any circumstances as this could encourage illegal fishing)
• that training should be made mandatory for all permit holders

The following comments were raised in smaller numbers:

• that eligibility should be proved before applying, not after
• a lottery should not be used for permit allocation
• greater clarity is needed on what defines vessel level effort controls

Allocation criteria for the English CRRF

The consultation document set out that “Defra intends to set the following allocation criterion to prioritise applications, in the event of oversubscription: Proof of training and or competence in catch and release techniques for BFT. In the first year of operation proof of training is likely to be through providing evidence of participation in a CHART programme, while in future years, this requirement may be modified to reflect alternative training options and or experience. Further allocation criteria may be added in future years, based on experience and in order to maximise delivery of FA2020 objectives.”

Question 5 asked respondents whether they supported this approach.

Question 5: Do you support the allocation criteria proposed for the English catch and release recreational fishery (CRRF)?

Response	Number of respondents
Yes	115 (69%)
No	50 (30%)
Unclear or no response to question	2 (1%)

165 out of 167 respondents provided a response to this question.

Of those that answered the question, 115 stated they had supported the allocation criteria proposed for the English BFT CRRF.

50 respondents stated that they did not support the allocation criteria. Of these, 46 left comments. The most common themes were:

• allocation criteria should not be limited to previous CHART experience
• clarity is needed on when a training regime will be developed to support new entrants to the fishery

The following comments were raised in smaller numbers:

• allow private vessel access
• consider alternatives to CHART experience to demonstrate competence, such as experience in fishing other pelagic species or fishing for BFT overseas
• consider a lottery system if the fishery is oversubscribed
• not providing a training regime for new entrants might encourage illegal fishing and reduce out of season tourism

Responses to this question included queries about what was meant in the consultation by training alternatives. This query is addressed in the government response.

Permit conditions and voluntary code of conduct in the English CRRF

The consultation document set out that “Defra are taking a co-design approach to developing the English CRRF, together with RSF sector representatives. The intention is to develop a voluntary code of conduct and positive fishery culture, to drive fisheries best practice. In England, permit conditions will only be used where relying on voluntary measures, set out in the code of conduct, is considered to be insufficient. Regular evaluation will allow Defra and MMO to improve the CRRF design, generally in consultation with stakeholders.

“Participants in the English CRRFs will be incentivised, through the code of conduct, to go beyond the legislative reporting requirements and to report all fishing activity in a timely manner, even if unsuccessful. Reporting mechanisms are still to be determined and will be specified through permit conditions. An app-based system, with a combination of mandatory and voluntary fields, is currently envisaged for the English CRRF.

“Restrictions to fishing areas are likely to be driven by a desire to minimise environmental and ecological impacts of the fishery. The intention for the English CRRF is to introduce best practice gear use through the voluntary code of conduct, in the first instance. If this is unsuccessful, gear restrictions could be set through permit conditions, in the future.

“Initially, the fishing season for the English CRRF is likely to run from July or August until November or December, when BFT are most abundant in our waters. This will be reviewed if migration patterns change. The fishing season will be set through permit conditions, as it is key to ensuring the fishery does not exceed quota.

“Effort restrictions will only be introduced if the fishery is oversubscribed, to allow more vessels to participate and benefit from the UK’s limited BFT quota. These restrictions could take a variety of forms including restricting the number of fishing days in a season or the number of hook-ups permitted per trip. If required, effort controls will be set through permit conditions, as they’re key to ensuring the fishery does not exceed quota.

“It is anticipated that in the first instance permit conditions would be generic across all permitted vessels within the English CRRF.

“In addition to setting out best practice reporting and gear selection, the voluntary code of conduct is expected to cover fishing techniques and vessel set up.”

Questions 6 and 7 asked respondents whether they supported this approach.

Question 6: Do you support the approach to permit conditions proposed for the English catch and release recreational fishery (CRRF)?

Response	Number of respondents
Yes	134 (80%)
No	31 (19%)
Unclear or no response to question	2 (1%)

165 out of 167 respondents provided a response to this question.

Of those that answered the question, 134 stated they supported the approach to permit conditions proposed for the English CRRF. This figure held true across different interest groups.

A number of positive respondents provided caveats emphasising the importance of adherence to a voluntary code of conduct. Some suggested that items proposed for a voluntary code of conduct should be in permit conditions, specifically training, gear or technique and data collection. One respondent advocated for area-based permitting monitored through inshore vessel monitoring systems (IVMS).

Of the 31 respondents not in favour of the permitting regime, most provided comments. The most common themes were:

• concern that the scope of the proposed permit was too narrow, with a desire for more of the measures proposed under the voluntary code of conduct (see question 7) to be mandated via permit conditions, to ensure high standards of fishery operation
• a desire for mandatory training – this was the most common point, but respondents also highlighted a need to mandate extensive reporting and gear restrictions through permit conditions
• concerns that effort controls would be impractical and would hinder the operation of charter fishing businesses, particularly if introduced mid-season

Other concerns, raised in smaller numbers included:

• that the proposed permit conditions were too constraining and more should move into a voluntary code of conduct
• a call for participants in the CRRF for BFT to be allowed to use various gear types and fishing methods, rather than being constrained to trolling, as in the CHART fishery
• a concern that the proposed approach was too complex for private recreational fishing vessels
• a concern that in-season variations to permits would be confusing
• a feeling that recreational fishers should neither need to report, nor be liable to prosecution if they broke the fishery’s operating conditions

Responses to this question included queries about the registration requirement for permit eligibility, what was meant by the term ‘charterer’ and MMO’s role in managing the fishery against permit conditions. These queries are addressed in the government response.

Question 7: Do you support the idea of a voluntary code of conduct to drive best practice in the English catch and release recreational fishery (CRRF)?

Response	Number of respondents
Yes	131 (79%)
No	35 (21%)
Unclear or no response to question	1 (0%)

166 out of 167 respondents provided a response to this question.

Of those that answered the question, 131 stated they had supported the idea of a voluntary code of conduct to drive best practice in the English BFT CRRF. At the interest group level, the 4 conservationist organisations were split, with 2 in favour and 2 opposed. Private recreational fishing vessels owners and users were the most supportive group.

A small proportion of those who responded positively caveated their responses with comments about the importance of monitoring, enforcing and policing of a voluntary code of conduct. Some cited concerns about the voluntary approach. One respondent suggested video monitoring for private vessels and another suggested that all permit holders should be members of the UK Bluefin Tuna Association, who could then oversee adherence with a voluntary code of conduct.

Some respondents in favour of a voluntary code of conduct suggested that guidance on the following areas be included in a voluntary code of conduct:

• appropriate fishing gear and tackle
• appropriate fishing technique, including minimisation of fight time
• effective catch and release techniques
• maximum amount of BFT that it would be appropriate to catch in a day
• safety measures, including equipment that should be carried and minimum vessel standards
• what to do in the event of a BFT mortality
• how to minimise shark bycatch and mortalities

Of the 35 respondents who did not support the idea of a voluntary code of conduct to drive best practice in the English BFT CRRF, 29 provided comments. The most common theme raised was that a voluntary code of conduct should be mandatory, or that some provisions should be mandatory. Training was mentioned consistently here, as also seen in question 6.

Smaller numbers of respondents commented that there is no value in a voluntary code of conduct.

In terms of how a voluntary code of conduct is developed, one respondent suggested it should be developed collaboratively with the recreational sector. A couple of respondents suggested looking to international best practice, particularly the USA. The need to consider how best to communicate changes and updates was also raised.

Charging for access to BFT fisheries

The consultation document set out that “Taking into account our BFT management principle that ‘fishers should contribute towards managing fisheries to promote sustainable use of natural resources’, it is intended that recreational fishers will be charged for their BFT permit, to contribute toward the costs associated with the permitting regimes, in line with managing public money principles (see Chapter 6 of Managing Public Money)”.

Question 8 asked respondents whether they supported this approach.

Question 8: Do you support the concept of the recreational BFT permits being chargeable?

Response	Number of respondents
Yes	126 (75%)
No	38 (23%)
Unclear or no response to question	3 (2%)

164 out of 167 respondents provided a response to this question.

Of those that answered the question, 126 stated they supported the idea of recreational BFT permits being chargeable. All conservationists were in support.

Some respondents who supported this measure caveated their answer. The most common caveat was that the charge should be capped to make it fair and affordable, followed by a desire for more information on charge levels and how the money would be used.

Of the 38 people who did not support the concept of the recreational BFT permit being chargeable, most provided reasons why. The most common theme was that more information is needed before a decision is made, including:

• cost of a permit
• what the funding raised would be used for
• whether the permit would be issued to the skipper, owner or vessel

Other comments raised by small numbers of respondents included that:

• this could set a precedent for other recreational fisheries
• that charges would be ‘unfair’, either due to the catch and release nature of the fishery, the elitist nature of charging or for unspecified reasons
• a permit fee would be too much for fishers, considering the necessary training and equipment outlay
• different charge rates should be set for charter vessels and private vessels
• there is a lack of parity with the commercial sector

Economic and social impact

The consultation set out that “The proposed CRRF seeks to align the UK’s regulation with its international counterparts. This will enable more recreational vessels to catch and release BFT, thereby utilising economic and social opportunities associated with a recreational BFT fishery.

“In 2021, after leaving the EU, the UK received BFT quota from ICCAT for the first time. UK FAs initially took a cautious and measured approach to managing their BFT quota by running scientific CHART programmes in 2021 and 2022. This restricted the number of vessels that could access the quota, so the quota was not fully utilised. Government intervention is needed to align the UK’s regulation with international ICCAT requirements, allowing for more vessels to access a new BFT recreational fishery. As a result of this, recreational fishers’ welfare will be increased, and resources will more efficiently allocated.

“The proposed intervention is likely to impact directly on the vessels which opt into the fishery. In the first instance, we anticipate that around 75 charter vessels and 40 private vessels will be interested in joining CRRFs across the UK. These vessels and fishers will face familiarisation costs and licensing costs and we expect charter vessels to become involved in the fishery if it is profitable to do so. The profits will likely arise from recreational fishers paying for the experience (as a form of tourism). As any BFT that are caught will be released back into the sea, there will be no profits relating to the commercial value of BFT. As such, the direct net economic impact of opening the fishery is likely to be relatively small and net positive – equal to the profit of the vessels who opt into, and are granted permits for, the fishery.

“There will also be indirect economic impacts associated with the opening of a recreational fishery. These include tourism spending in local restaurants and hotels as well as in local shops for the appropriate fishing gear. The size of these impacts is positively correlated with the size of the recreational fishery.”

Questions 9 and 10 asked whether respondents agreed with this assessment and question 11 asked for further information on the socio-economic benefits of the fishery.

Question 9: Do you agree with our estimate of likely levels of interest in catch and release recreational fisheries (CRRFs)?

Response	Number of respondents
Yes	111 (67%)
No	54 (32%)
Unclear or no response to question	2 (1%)

165 out of 167 respondents answered this question.

Of those that answered the question, 111 stated they agreed with Defra’s estimate of likely levels of interest in BFT CRRFs.

Of the 54 respondents who contested the levels of interest, most provided comments. The vast majority felt that the estimates were too low, in particular for private vessels, with one respondent suggesting those interested could be in the thousands. That 74 respondents categorised themselves as ‘Private recreational fishing charter vessel owner or charterer that may want to participate in future fishery’ indicates a higher level of private vessel demand than originally expected.

The following comments were made in smaller numbers:

• that the figures are too high
• that interest will grow over time
• that uptake is dependent on permit cost (particularly for private vessels)
• that much higher interest than permit availability will present a fisheries management challenge

Question 10: Do you broadly agree with the direct and indirect economic impacts associated with the opening of a recreational fishery?

Response	Number of respondents
Yes	133 (80%)
No	32 (19%)
Unclear or no response to question	2 (1%)

165 out of 167 respondents provided a response to this question.

Of those that answered the question, 133 stated they broadly agreed with the direct and indirect economic impacts associated with the opening of a recreational fishery. There were similar levels of support across interest groups.

No space for comments was provided, but respondents had the opportunity to share further evidence via question 11.

Question 11: Do you have any data or evidence which identifies and values the economic impacts associated with the opening of a recreational fishery?

Response	Number of respondents
Yes	53 (32%)
No	112 (67%)
Unclear or no response to question	2 (1%)

165 out of 167 respondents answered this question. 53 respondents offered to provide additional data or evidence which identifies and values the economic impacts associated with the opening of a recreational fishery. No conservation organisations were able to provide additional data.

The most common types of data provided were anecdotal information about the scale and breadth of economic benefits associated with a BFT CRRF. Several respondents highlighted the importance of understanding the socio-economic benefits of a BFT CRRF as compared with a commercial BFT fishery.

Additionally, references to existing and potential studies were provided. These can be found in Annex 5.

Additional information

Question 12: Is there anything else you would like to add?

106 respondents provided additional comments.

Several respondents commented on the format of the consultation, most often stating that the character limits hampered responses. A number of respondents indicated that they would email additional information to address this constraint.

About one-third of respondents reiterated their support for the development of a BFT CRRF. Conversely 3 respondents reiterated that they do not support the fishery.

Several respondents reiterated the need for strong enforcement, including concerns about the voluntary nature of a code of conduct and a call for a mandatory rather than voluntary code of conduct. Others called for no commercial fishing of BFT.

The rest of the comments covered a wide variety of themes, including concerns about:

• post release mortality rates for BFT
• illegal fishing of BFT
• creating a monopoly for some anglers
• government not treating recreational angling appropriately, given the high level of participation

There were also suggestions to:

• ensure the full value of RSF sector and recreational BFT fishing is considered in decision making
• give the recreational BFT fishery priority access to BFT quota
• not expand the commercial BFT fishery
• allow commercial fishing vessels to operate as BFT charter fishing vessels
• ensure the fishery is open to all, including private vessels, as soon as possible
• allow various fishing techniques including trolling, live baiting, lure fishing and fly fishing
• allocate permits on basis of competence
• provide regional permits
• allow catch and keep
• consider opportunities to attract more overseas tourists
• ensure all locations are included, not just the South West
• keep permit costs reasonable or low
• provide coaching for participants, as in CHART, and use experienced skippers to train new skippers
• learn from others, including USA and Canary Islands
• manage BFT bycatch in shark fishing
• share a clearer plan
• better manage the food sources of BFT, to protect the species

Government response

On the basis of the strong support to the consultation for new UK permitting regimes for the recreational targeting of BFT, Defra will bring forward the necessary legislation.

It will be for each UK FA to determine if, and when, to introduce a BFT CRRF in its waters. Eligible vessels registered anywhere in the UK will be able to apply to participate in any of the UK’s BFT CRRFs, to comply with the FA2020 equal access objective. The intention is to open a BFT CRRF in English waters in 2024.

UK legislation

The UK legislation to introduce permitting regimes for the recreational targeting of BFT in each of the UK’s 4 FAs will be in line with the approach consulted on. In light of the consultation responses and further preparatory work, there will be 3 key refinements:

1. Permit charges

The consultation showed strong support for the concept of chargeable permits, although many respondents sought further information on the scale and use of permit charges. The intention remains for BFT CRRF permits to be chargeable.

However, further work is required to confirm the scope and scale of such charges, as well as how any charge income would be used. On this basis, the legislation will omit charging provisions, which will be brought forward in due course. BFT CRRF permits will therefore initially be free of charge.

2. Fishing vessels that hold commercial fishing licences

The consultation showed strong support for excluding commercial fishing vessels from BFT CRRFs. However, a number of respondents put forward strong socio-economic arguments for allowing vessels with commercial fishing licences to operate as recreational fishing charter vessels within BFT CRRFs.

Having considered the responses, Defra is mindful that this type of commercial access may help maximise the socio-economic benefits attainable from the BFT quota. On that basis, the legislation will not exclude commercially licenced fishing vessels from the BFT CRRF.

However, the following points will be policy decisions to be made by the relevant FA, taking account of relevant factors:

• whether to allow certain classes of fishing vessels (including those that hold commercial fishing licences) to access a BFT CRRF
• the circumstances under which such vessels may be allowed access
• the number of vessels allowed access

3. Charterers

We consulted on making permits available to both vessel ‘owners’ and ‘charterers’. Vessel ‘owners’, ‘charterers’ and ‘masters’ (also referred to as ‘skippers’) would all be responsible for complying with operating conditions and subject to enforcement activity in the event of non-compliance.

However, consultation responses indicated that the term ‘charterer’ had caused confusion around who needed to apply for permits. Following discussions with fisheries licensing authorities we will instead make permits available only to vessel ‘owners’. A vessel’s ‘owner’ and ‘master’ will each be responsible for complying with operating conditions and subject to enforcement activity in the event of non-compliance.

This does not prevent chartered vessels from being used in the BFT CRRF fishery. In this instance, it would fall to the vessel’s ‘owner’ and ‘master’ to take responsibility for ensuring compliance with operating conditions. In no instances will ‘customers’ angling on a recreational fishing charter vessels need to apply for individual BFT CRRF permits.

Enforcement action

Concerns about the ability of regulators to take enforcement action against those fishing recreationally outside of BFT CRRFs, and to take enforcement action against those breaking BFT CRRF operating conditions, have been considered at length. At this stage the overall legislative approach set out in the consultation is considered proportionate to the risks. However, these concerns will be taken into account in the detailed design work for the English BFT CRRF and fishing activity outside the BFT CRRF will be closely monitored.

Design of English BFT CRRF

Responses to consultation questions relating to the design of the English BFT CRRF will inform the detailed design work that Defra and MMO are now undertaking. Defra will set the policy for the English BFT CRRF and MMO will lead on operational implementation, including the issuing of permits and associated monitoring and enforcement activity.

Defra and MMO remain committed to co-designing the fishery with the RSF sector, to build a fishery culture where individual fishers and the wider RSF community perform a key role as stewards of the fishery. Annex 3 lists the organisation represented on the English BFT CRRF design and delivery working group.

Defra and MMO recognise that this is not only a new fishery but also the first permitted recreational sea fishery in the UK. Defra and MMO are committed to:

• fully evaluating the English BFT CRRF after its first year of operation
• evaluating it on an ongoing basis thereafter
• revising the future approach in line with the evaluation findings

Building on the consultation proposals and taking into account the key themes raised in consultation responses, the following approaches will be taken.

Scale

The maximum scale of the English BFT CRRF in 2024 will be determined by the availability of quota. As in 2023, the UK expects to receive around 60 tonnes of quota from ICCAT in 2024.

Decisions on how to utilise the UK’s BFT quota in 2024 will take into account:

• the outcome of the 2023 commercial BFT fishery trial
• the anticipated interest in any 2024 recreational BFT fisheries
• analysis of the potential social and economic contribution and environmental impacts of each fishery

The feedback on the scale of social and economic benefits has been noted. The references will be reviewed alongside other evidence.

The UK will set out its proposed quota use in its annual BFT fishing plan to ICCAT in mid-February 2024, which will be subsequently agreed with ICCAT in March 2024

A fisheries model calibrated with best available data will be used to link BFT CRRF vessel numbers and quota. Defra have committed to work with RSF sector stakeholders to refine this fisheries model.

Concerns were raised about the impact of constraining the scale of the English BFT CRRF too much in year one. In response, Defra and MMO will further consider the optimal size and eligibility criteria for a year one fishery. They will take into account quota availability and the likely level of interest, as indicated through the consultation responses.

Effort controls

Vessel level effort controls may be applied to limit the amount of fishing activity each vessel is permitted to undertake in order to increase the number of permits available and maximise social and economic benefits. Vessel level effort controls would only be required in the event of the fishery being oversubscribed.

Concerns around the use of vessel level effort controls have been noted and Defra and MMO will engage further with the RSF sector to determine the best approach, if required.

Registration

To be eligible to apply for a BFT CRRF permit, vessels will need to be registered in the UK under Part 2 of the Merchant Shipping Act 1995.

In the English BFT CRRF it will be possible to meet this requirement by providing proof of registration on Part 1 (Merchant and Pleasure), Part 2 (Fishing) or Part 3 (Small Ships) of the UK Ships Register. This allows both private and charter recreational vessels to meet this eligibility requirement.

Further eligibility requirements for the English BFT CRRF fishery will be determined by Defra and set out by MMO in guidance on the application process.

Data collection

Catch reporting to meet ICCAT requirements will be set out in legislation.

It is intended that BFT CRRF participants will be able to voluntarily provide additional data. This is subject to detailed design work, but the importance placed on data collection in consultation responses has been noted.

Annex 4 contains a list of data fields provided by participants in the commercial BFT trial, to allay concerns about parity of reporting requirements.

Voluntary code of conduct

Given the high levels of support, a voluntary code of conduct will be used as the key tool for driving fishery best practice, above and beyond what will be set out in legislation and permits. Initially, training will form part of a voluntary code of conduct, but there is a strong expectation that all participants will complete training, particularly as permits will initially be issued free of charge, which should help mitigate concerns around training costs.

The efficacy of a voluntary code of conduct in driving fishery best practice will be monitored and reviewed.

Training

Defra has noted consultation feedback on the importance of training in catch and release practices to protect fish welfare in the fishery. This is an area Defra would like to focus the collaborative design work.

The concept of mandatory training was raised repeatedly in consultation responses. Currently there is no intention to mandate training, as Defra considers the voluntary approach to be proportionate the risk. In order to mandate training in the future there would need to be a mechanism available for the MMO to efficiently validate that suitable training had been successfully completed.

Next steps

Defra and MMO are now undertaking the detailed design work for the English BFT CRRF and remain committed to co-designing the fishery with the RSF sector.

The maximum size of any 2024 English BFT CRRF will be indicated in the UK’s fishing plan, which will be submitted to ICCAT for approval in February 2024.

The outstanding details for the English BFT CRRF will be set out by MMO in guidance on the application process, ahead of the 2024 fishing season. Any BFT CRRF is dependent upon the necessary legislation being in place ahead of the season start.

Annex 1 – List of all organisations who responded to the consultation

Some respondents do not appear on this list, including those who asked for their responses to be kept confidential. However, their views have still informed the analysis of this consultation and are incorporated in the figures presented throughout.

These are presented in alphabetical order.

Amaretto Sport Fishing

Angling Cymru

Angling Trades Association Ltd

Angling Trust

Bell Rock Lures

Bembridge Angling Club

Blue Marine Foundation

British Big Game Fishing

British Spearfishing Association

Cachalot Charters

Extreme Boats EU Ltd

Fishing Charter

Freeman Marine

Hookpoint Fishing Magazine

Jersey Spearfishing Club

Marine Conservation Northern Ireland

Marine Conservation Society (MCS)

Patricia Rose Charters

Poole Bay Small Boat Angling Club (PBSBAC)

Plymouth Fishing and Seafood Association

Poole Bay Small Boat Angling Club

Portland Bluefin Adventure

Professional Boatman’s Association (PBA)

Sea Fishing Poole

Shark Trust

Smart Fishing UK

Sportfishing Club of the British Isles (SCBI)

The UK Bluefin Tuna Association

Trueblue Charters

Wembury Marine Conservation Area Advisory Group

Annex 2 – Breakdown of responses

Question 1: Do you broadly support the design for the new UK permitting regimes?

Response	Charter vessel	Private vessel	Recreational fisher	Conservationist	Other or unspecified
Yes	17	66	40	3	13
No	4	8	9	1	5
Unclear or nil	0	0	0	0	1

Question 2: Do you support this approach to commercial fishing vessel access?

Response	Charter vessel	Private vessel	Recreational fisher	Conservationist	Other or unspecified
Yes	15	65	34	3	11
No	6	9	15	1	7
Unclear or nil	0	0	0	0	1

Question 3: Do you support the proposed approach to determining the number of permits available?

Response	Charter vessel	Private vessel	Recreational fisher	Conservationist	Other or unspecified
Yes	15	60	36	4	10
No	6	14	13	0	7
Unclear or nil	0	0	0	0	2

Question 4: Do you support the approach to allocating permits?

Response	Charter vessel	Private vessel	Recreational fisher	Conservationist	Other or unspecified
Yes	14	61	36	4	11
No	7	13	13	0	5
Unclear or nil	0	0	0	0	3

Question 5: Do you support the allocation criteria?

Response	Charter vessel	Private vessel	Recreational fisher	Conservationist	Other or unspecified
Yes	14	54	34	4	9
No	7	20	15	0	8
Unclear or nil	0	0	0	0	2

Question 6: Do you support the approach to permit conditions proposed for the English CRRF?

Response	Charter vessel	Private vessel	Recreational fisher	Conservationist	Other or unspecified
Yes	17	67	35	3	12
No	4	7	14	1	5
Unclear or nil	0	0	0	0	2

Question 7: Do you support the idea of a voluntary code of conduct to drive best practice in the English CRRF?

Response	Charter vessel	Private vessel	Recreational fisher	Conservationist	Other or unspecified
Yes	17	66	34	2	12
No	4	9	14	2	6
Unclear or nil	0	0	0	0	1

Question 8: Do you support the concept of the recreational BFT permits being chargeable?

Response	Charter vessel	Private vessel	Recreational fisher	Conservationist	Other or unspecified
Yes	13	61	35	4	13
No	8	13	14	0	3
Unclear or nil	0	0	0	0	3

Question 9: Do you agree with our estimate of likely levels of interest in CRRFs?

Response	Charter vessel	Private vessel	Recreational fisher	Conservationist	Other or unspecified
Yes	14	46	36	3	12
No	7	28	13	1	5
Unclear or nil	0	0	0	0	2

Question 10: Do you broadly agree with the direct and indirect economic impacts?

Response	Charter vessel	Private vessel	Recreational fisher	Conservationist	Other or unspecified
Yes	18	64	36	3	12
No	3	10	13	1	5
Unclear or nil	0	0	0	0	2

Question 11: Do you have any data or evidence on the economic impacts?

Response	Charter vessel	Private vessel	Recreational fisher	Conservationist	Other or unspecified
Yes	10	25	13	0	5
No	11	49	36	4	12
Unclear or nil	0	0	0	0	2

Annex 3 – Organisations represented on English BFT CRRF Design and Delivery Group

Organisation	Role, remit and interest
Defra	Chair and policy ownership
MMO	Operational delivery
Cornwall Inshore Fisheries and Conservation Authority (IFCA)	Represents IFCAs on regional monitoring and enforcement
Natural England (NE)	Conservation impact
Cefas	Technical and scientific expertise
Stakeholder – Angling Trust	Represents recreational fishers
Stakeholder – UK Bluefin Tuna Association	Represents the recreational fishing sector, specifically with regard to BFT fishing
Stakeholder – Professional Boatman’s Association	Represents the recreational charter boat fishing industry

Annex 4 – Commercial BFT reporting requirements

Authorised BFT trial commercial fishers must provide prior notification to relevant port authorities before landings with the following information:

• estimated time of arrival
• estimate of the quantity and weight of bluefin tuna retained on-board
• information on the geographic area where the catch was taken
• the vessel identification details (including vessel name, vessel PLN, IMO number (where applicable)
• intended port of landing (this should be a designated port unless force majeure permits an alternative – masters are asked to provide a legitimate reason for not landing into designated port)
• merchant details (if intended to be sold)
• email address for which the vessel or its owners can receive an electronic bluefin tuna catch document (eBCD)

Fishers must record fishing activity through their logbook or catch app, and all landings must also be accompanied by a full eBCD record.

Annex 5 – Social and economic case studies

The following case studies were referenced by respondents in response to question 11.

1. Nova Scotia catch and release bluefin fishery, ‘reeling in revenue’ (2010).

This report looked at operators commercially fishing and recreational catch and release fishing. The recreational fishery made an estimated 6 to 8 times the revenue of the commercial fishery, per tonne.

2. Hatteras, North Carolina, USA. University of Texas study (1997).

This study details the revenue generated by a new winter bluefin fishery that emerged from 1993. This fishery went from zero to millions of dollars of revenue generation in the space of 2 years.

3. CHART 2021 socio-economic survey, (Defra and Cefas published data).

This survey indicates Total Economic Impact (TEI) from a small scale, 15-vessel fishery, which was constrained in terms of technique and season. It generated TEI of £889,000, equating to £89,000 for each of the 10 mortalities.

4. CHART 2022 socio-economic survey (Defra and Cefas published data).

This survey indicates TEI from a 25-vessel science fishery of £2,600,000 equating to £520,000 for each of the 5 mortalities.

5. Technical University of Denmark (DtU) study of socio-economic benefits from the Scandinavian Bluefin Marathon.

This study reviews revenue generation per mortality experienced, estimated of over €300,000 per fish.

6. Participation, catches and economic impact of sea anglers resident in the UK in 2016 & 2017.

7. Marine Recreational Fisheries: Socio-Economic Value & Challenges.

8. Assessing the contribution of recreational sea angling to the English economy.

9. Analysis of the economic contribution of recreational and commercial fisheries to the Costa Rican economy. This analysis defines the significant impact of recreational angling and associated tourism activities of anglers to the economy of Costa Rica.

Further case studies were suggested, but without reference to existing reports:

• looe sport fishing
• blue marlin fishing in Cape Verde
• striped bass fishery in the USA
• Irish BFT fishery