Consultation outcome

Summary of responses

Updated 7 May 2020

1. Introduction

This document provides a summary of responses to Defra’s consultation on the allocation of reserve quota in England in 2020 and proposed updates to the English Quota Management Rules (QMR) and how the Government is responding to those responses. It does not offer a detailed opinion on the comments received. This document should be read in conjunction with the reserve quota consultation document.

The consultation ran from 15 January to 9 March 2020.

Defra will conduct further consultation to decide on the approach to allocating reserve quota and on further updates to the English QMR, as the UK leaves the Transition Period.

2. Background

2.1 Reserve quota

Stocks subject to the landing obligation have an increased quota to allow previously discarded fish to be landed. The UK has worked closely with the European Commission and Member States to agree the method to calculate this increased quota. Before 2019, when the landing obligation was only partially in force, the European Commission calculated the total amount of uplift for a stock based on the historic discard rates of those fleets covered by the landing obligation, minus any agreed exemptions.

Since the landing obligation came fully into force in January 2019, this uplift in quota has not been differentiated by the Commission from the overall Total Allowable Catch (TAC) set for quota stocks. Defra has taken the approach of calculating the equivalent amount of quota for England using the same method of historic discard rates and referring to this as ‘reserve quota’.

The Devolved Administrations do not calculate a reserve quota, but allocate all quota to industry together, via Fixed Quota Allocation units (FQAs).

In England, since 2016, Defra has allocated reserve quota via a combination of:

• supporting the non-sector by awarding them the first 100t plus 10% thereafter of the reserve quota for each stock - there were some exceptions to this, for example, where it would create choke issues for the sector
• incentivising participation in selectivity trails, such as the Fully Documented Fisheries (FDF) scheme, to improve the sustainability of the fishing fleet
• awarding the remainder to the sector^{[footnote 1]} via Fixed Quota Allocation (FQA) units

This policy followed consultation on the implementation of the demersal landing obligation in 2015 and is in line with Defra’s long-term fisheries policy goals of having a diverse, profitable and sustainable fleet.

After the end of the Transition Period, we will consider the future of reserve quota as we review the discards policy with a view to delivering effective elimination of the wasteful discarding of fish which better reflects quota management policies, the needs of our industry and the protection of our marine environment.

2.2 English Quota Management Rules (QMR)

The English Quota Management Rules (QMR) set out how quota is managed in England. They are administrative rules and are mainly about the allocation of quotas made available to the Marine Management Organisation (MMO).

3. Overview of responses

A total of 32 responses were received, 28 via Citizen Space (online consultation) and four via e-mail. Responses were received from the fishing industry (94%, of which 66% were from sector and 28% from the non-sector), a management body (3%), a charitable trust (3%), and a County Council (3%).

Of the 32 responses, 13 were identical but were submitted by 13 different respondents. Figure 1 provides an outline of respondents by category.

Figure 1: Analysis of respondents to the consultation by stakeholder segment

3.1 Reserve quota

The views expressed on reserve quota were varied. Some respondents took the opportunity to comment on the challenges and opportunities the allocation of reserve quota brings, providing examples to illustrate specific issues for individual fisheries. A range of options were suggested by respondents on the method by which to allocate reserve quota but no one option was favoured.

3.2 Changes to the English Quota Management Rules

The proposed updates to the English QMR were generally met with satisfaction including on the improved clarity provided by the changes. There were a few calls for a broader update of the English QMR, which Defra will be doing later in the year.

Each question posed in the consultation is explored in further detail in the sections below.

4. Summary analysis of responses to consultation questions

4.1 English reserve quota allocation for 2020

Q. What do you think the advantages and disadvantages of continuing to top slice this quota in 2020 and beyond would be?

Eight responses were generally supportive while 21 (13 identical) were generally unsupportive of top slicing a proportion of the reserve quota for the non-sector. Four respondents did not answer the question, although did express relevant views in other answers, which have been considered. The views expressed by respondents on advantages and disadvantages of the top slice were:

Advantages

• it addresses the uneven access to fishing opportunities between the sector and non-sector
• it supports the non-sector, including providing them with flexibility to target quota species
• it can help to promote sustainable fishing practises due to the smaller scale and lower impact gears used by the inshore fleet

Disadvantages

• some quota is not suitable for the non-sector and therefore the quota may not get used
• the approach is not consistent with that taken by the Devolved Administrations. Scotland, Wales and Northern Ireland do not calculate a reserve quota and allocate everything together via FQAs
• it does not promote sustainable practices or improve the economic productivity of the non-sector
• is it not clear how the reserve quota tonnages are calculated
• the current top slice method seems arbitrary and it is important that the methodology to calculate any amount awarded to the non-sector is clear and transparent
• it could be a disincentive for the sector to comply with the landing obligation

Q. Are there more appropriate methods for supporting the inshore fleet while at the same time ensuring that the whole fishing fleet receives an adequate and fair share of fishing opportunities?

There were 29 responses to this question (13 of which were identical). The 13 identical responses from the sector recommended allocating reserve quota through the existing FQA mechanisms with some modifications, for example, providing more quota to the under 10m fleet through existing arrangements such as underpinning (an arrangement that guarantees minimum levels of allocation for certain stocks).

Three respondents from the sector and a county council, proposed that there be a more collaborative working relationship between the inshore fleet, the quota managers such as the Marine Management Organisation and Producer Organisations (who manage quota for the sector).

Three responses from the non-sector proposed the removal of small inshore vessels from the quota system altogether and instead use other methods such as days at sea or catch recording to manage their effort.

Seven responses across the sector and non-sector proposed a re-distribution of quota through a variety of suggested means:

• using regional pools to distribute quota according to where it will be used
• by having POs hold quota and distribute where needed more evenly to make accessible to non-quota holders
• by recognising the difference between vessels and their catching power rather than just length classes and re-classifying accordingly
• by continuing ‘reasonable efforts to rebalance fishing opportunities towards the majority of the fleet that are small scale and non-sector’ through the top slice in the short term with a more fundamental rebalancing of quota for the under 10m fleet based on amounts that would enable certain profit margins to be achieved
• one respondent suggested an alternate approach of transferring 1% of FQAs from the sector to the non-sector

The majority of responses (16, of which 13 from the sector were identical) proposed more direct support for the inshore fleet through measures other than just quota management. Two suggested that there should be ‘no government transfer of quota at all’ and one responded with suggestions on how to make use of additional quota from becoming a coastal state. These respondents also suggested that:

• the inshore fleet already have sufficient quota in most areas and top-slicing reserve quota could drive uncontrolled expansion of the inshore fleet and overfishing of inshore areas
• private sector FQA holders currently make quota available during each year for inshore vessels by quota trading (swaps) - the UK government could establish a small monetary fund to lease quotas required by inshore vessels if they exhaust their trading capacity for swaps.

4.2 Top-slicing methods.

Table 1 shows the number of responses from the online survey on the top slicing method to be used in 2020. None of the 4 email respondents specified an answer to this question.

Table 1: Number of responses to the top slicing method to be used in 2020

Option	Total
Maintain the current approach (100t + 10%)	4
A fixed percentage approach. If so, 25% or a different percentage and why	0
Allocation based on historic uptake. How do you think information on historic uptake levels should be applied to top slice calculations?	2
Another method, please specify	13
Not Answered	9

Q: If top slicing is used in 2020, which method should be adopted:

Maintain the current approach (100tonnes + 10%)?

There were four respondents who supported the current method, all either active within or representing the non-sector. In the space for further details, one respondent said the inshore non-sector fleet suffered from significant choke issues in 2019 due to the landing obligation which would have tied them up to dock earlier than previous years if it weren’t for the reserve quota. They argued against reduction in the top slice, citing potential social sustainability issues and referencing the requirement outlined in the Fisheries Bill to view social factors in balance with other factors.

Overall 14 respondents from the sector who did not select this option still provided feedback on it, saying that top slicing 100 tonnes plus 10% is arbitrary, unreasonable and ineffective method of top slicing; and that it is a disincentive to fishermen who try to comply with discard free fishing.

A fixed percentage approach. If so, 25% or a different percentage and why?

None of the respondents selected this as their preferred method if top slicing is used. Feedback received on this option from the sector stated that the policy of top slicing a fixed percentage would lead to large amounts of quota being top sliced which the inshore fleet would be unable to utilise and would therefore lead to a negative economic impact on the overall UK fleet. 13 identical responses from the sector had the view that this option also does not take into account the relative economic value of the quota species being top sliced.

Allocation based on historic uptake. How do you think information on historic uptake levels should be applied to top slice calculations?

Two respondents selected this as their preferred method if top slicing is used, suggesting that historic uptake indicates where the non-sector need additional quota. One respondent recommended that the maximum amount top-sliced should align with the status quo of 100 tonnes + 10%. Both of these respondents said that the allocation of reserve quota should “present the minimum disadvantage to both the sector and non-sector”.

Another method, please specify?

In total, 27 respondents provided extra detail around preferences in top slice methodology in the space provided, including nine that had not answered the initial poll:

One non-sector respondent suggested that as part of a move to days at sea for effort management for under 10s, the current approach should be maintained for 2020, and the top-slice reduced by a set amount annually thereafter alongside support to improve selectivity, but that using historic track record would be unfair

13 identical responses from the sector said that if top slicing is to be continued then the policy objectives and calculation method should be made clear and transparent by taking into account:

• a) evidence of historic use of quota by inshore fleet
• b) the economic value of each quota species
• c) the economic impact on the sector of not allocating the reserve quota on the basis of FQAs

These respondents also suggested that any policy of top slicing should be subject to an annual review against the policy objectives. They also provided information that in 2019, 17 out of 29 fish stocks were top sliced and tonnage remaining at the end of the year exceeded the amount top sliced. This quota would otherwise have been used by the FQA holders but this lead to a huge detrimental economic impact to the UK fleet.

These responses also said that timing of the announcement of the top sliced quota also cause ambiguity and uncertainty by undermining sector’s ability to raise finance.

There was a preference expressed by respondents from the sector that no top slice should be given and the entire reserve quota should be allocated through FQAs as an alternative. These respondents also expressed the view that the co-management approach adopted between the Government and fishing industry through FQAs is undermined when quota increases are not granted to FQA holders.

4.3 Stocks and choke

Q. Which stocks should or should not be omitted from top slicing?

Omitting all stocks (i.e. not top slicing reserve quota for any stocks) was proposed by 16 respondents from the sector (13 identical responses).

Other respondents suggested different species and stocks which should be excluded from any top slicing because they were either not suitable for the non-sector or top-slicing would significantly increase the choke risks for the sector. Suggestions were:

• Cod with no area specified
• Endangered species
• North Sea - Haddock, Saithe, Whiting, Hake, Plaice, Monkfish, Megrim and Lemon Sole
• Subarea VII – Whiting
• Division VIIa – Whiting, Plaice, Dover Sole
• Division VIa – Haddock
• Division VIb – Haddock
• West Scotland - Saithe, Monkfish, Megrim, Hake

One respondent from the non-sector said no stocks should be omitted.

Suggestions for stocks which should be included in any top slicing policy were:

• stocks such as North Sea Whiting, where the reserve quota is needed for the non-sector fishery to exist
• North Sea – Megrim, Sole, Turbot and Brill
• Division VIIb-k – Haddock
• Division VIId-e – Plaice

Q. Based on information currently available to you, when in 2020 would you experience choke due to the stocks in your previous answer, if you did not receive additional allocated quota?

Stocks reported to be choking in the sector at the time of the consultation included:

• Division VIId – Cod
• Division VIIe – Cod
• North Sea – Whiting, Cod and Haddock (January-February 2020 for some vessels)

Other stocks were identified as high choke risks in the future:

• Division VIIa – Cod, Whiting, Dover Sole in July for IoM scallop fishery
• North Sea – Cod, Haddock, Saithe and Whiting “later in year”
• Whiting with no area specified in September

Q. What impacts, other than choke, would result from these stocks being omitted or not from top slicing?

17 sector respondents referred to the potential for lost fishing opportunities due to top slicing, indicating that some quotas are unsuitable for the inshore fleet as they are unable to steam to the locations where the stocks reside, or are unable to operate the gear necessary to catch the species. Hake was repeatedly raised as an example as it occurs in deep, offshore waters which are often unsuitable for smaller inshore vessels to fish safely.

13 identical sector responses pointed out that little or no increase in the number of full-time equivalent employees in inshore fishing were observed in the Seafish UK fishing economic reports since top slicing has been introduced.

Q. Please specify what measures your fleet or vessel(s) have already taken to improve selectivity for these stocks. If no selectivity measures have been adopted, please explain why?

Respondents provided a range of answers to this question:

• One respondent suggested that the inshore fleet were more selective as many used static gear or small scale mobile gears
• 20 respondents (13 identical from the sector) indicated that they used selective gear including large mesh sizes and sleeve meshes to allow juvenile fish to escape gear
• 17 respondents (13 identical from the sector) said they used spatial selectivity in targeting of fish, for example avoiding small fish and pursuit of low bycatch fisheries
• Two sector respondents use Remote Electronic Monitoring (REM)

4.4 Reserve quota feedback

Q. Is there anything else you think we should consider in determining the 2020 reserve quota policy, including any feedback you have on the 2019 reserve quota policy communications and guidance?

Respondents provided a range of general feedback on the 2019 reserve quota policy, most of which is summarised in the sections above. Additional views not covered above were:

• top slicing reserve quota for the non-sector has helped them comply with the landing obligation
• the reserve quota for some species was held in a pool in 2019, only to be later released via FQAs when no opportunities to use it as sustainability incentive were forthcoming - this was viewed as problematic and costly for businesses in terms of lost opportunity
• respondents from both the sector and non-sector were critical of the use of reserve quota for choke management - sector respondents said that choke risk is already managed by the private sector through existing mechanisms of quota trading and a non-sector respondent said that choke scenarios are no different between sector and non-sector
• measures for selectivity such as increased mesh size, and the use of measures for the FDF scheme meant a loss of marketable fish to one respondent
• two respondents suggested that Remote Electronic Monitoring should be rolled out more widely to create equivalence and equalise opportunities with the FDF scheme vessels, with one suggesting the scheme should be suspended until equivalent schemes are brought in by the Devolved Administrations and the EU

4.5 English Quota Management Rules (QMR)

Q. Do you agree with the proposed changes provided in the draft? Please provide the reasons for your answer.

19 out of 32 respondents agreed with the proposed updates in the English QMR to reflect the reserve quota policy.

Q. What, if any, further updates to the QMR should be made?

Suggestions for further updates included:

1. Objectives of any reserve quota policy should be stated in the QMR - 13 identical responses suggested that if top slicing of reserve quota for the non-sector is to continue, the objectives of the policy it should be made clear in the QMR. Additionally, the QMR should contain a requirement for an annual review on the effectiveness of top slicing in achieving its desired policy goals.

2. The method of calculating reserve quota should be clearly set out in the QMR - 13 identical responses suggested that the QMR should include a clear and transparent method of how the reserve quota is calculated each year (as is the case with the underpinning arrangements). Linked to responses on the approach to allocating reserve quota (set out in more detail above) these responses also asked that maximum limits for top slicing, based on historic track records, be set out in the English QMR.

3. Wider consultation - 3 respondents suggested that Defra should conduct a wider review of the English QMR later in the year after the Fisheries Bill has passed, and that if a wider update to the English QMR is needed, there must be a full and meaningful consultation with industry.

4. Changing terminology - We also received suggestions about revising sectoral terminology, referring to ‘fishing opportunities’ rather than ‘quota’ and similar points.

5. Other policy changes - a number or respondents used this opportunity to raise points on other policies:

• a) 3 respondents suggested there should be a reconciliation of FQA units, and that this be done every 2 years. There were also comments about the FQA Register. These fell outside the scope of this consultation but we will take them into account as part of any future work on the FQA Register.
• b) 1 respondent suggested that quota should be made freely available to new entrants to encourage young fishers into the industry.
• c) 1 respondent also highlighted their concern that vessels in Producer Organisations with no quota are in the worst position and should be rented quota from the pot for free each year.

Q. What other comments or observations do you have about the English Quota Management Rules?

In response to this question, there were comments on the following themes (the number of responses received is included in brackets):

• do not top slice reserve quota for the non-sector (13 identical responses)
• any actions should avoid destabilising the FQA system (13 identical responses)
• the objectives of reserve quota must be considered carefully if it is to be continued (14, out of which 13 were identical)
• further consultation on wider updates to the English QMR is needed (3)
• more support is needed for over 10m fleet (2)
• parity between DAs (1)
• don’t move towards using FQAs for under 10m fleet (1)
• consider using zonal attachment in setting Total Allowable Catches (1)

5. Government response

5.1 Allocation of reserve quota in 2020

Defra has given careful consideration to all the consultation responses and has taken them into account in considering the allocation of English reserve quota for 2020. Defra is grateful to all respondents for participating. Defra has also been mindful that the 32 responses may not represent a comprehensive cross-section of all parts of the industry.

Revised approach to top slicing

Defra has concluded that a top slice, calculated on the basis of revised principles and a new methodology, should continue to be allocated to the non-sector for some stocks in 2020. Defra has taken into account responses to the consultation to the effect that the top-slice provides the non-sector with important fishing opportunities. However, we agree with other consultees (generally those from the sector) that the previous approach to top-slicing has in some cases allocated quota to the non-sector that has not been used, either for landings or trade, which may have been used by the sector had it been allocated to them via FQA units. Accordingly, Defra intends to allocate English reserve quota in 2020 so as to:

• continue to support the non-sector by allocating a top slice of reserve quota, but in a way which reflects where it has been useful to them in the past
• provide a level of support to the non-sector that is similar to the support provided by the previous methodology
• use a top slicing method based on evidence about how the top slice has been used since 2016
• avoid allocating reserve quota to the non-sector where they have not historically used it
• no longer apply a blanket 100% top slice to stocks with a small reserve quota pool, in order to better distribute these often higher value stocks

In order to achieve this, the top slice, where it is applied, will be determined using a method based upon average historic use^{[footnote 2]} of the top slice from 2016-2019 use of the top slice is summarised in Table 2:

• for stocks with 100t or less of reserve quota, if the non-sector is highly dependent upon the top slice (defined as where historic use of the top slice by the non-sector is greater than 75%), all the reserve quota will be allocated to the non-sector
• for stocks with 100t or less of reserve quota, if the non-sector is not highly dependent on the top slice, the top slice will be the reserve quota multiplied by the proportion of reserve quota historically used by the non-sector
• for stocks with more than 100t of reserve quota, the top slice will be 25% of the reserve quota multiplied by the proportion of reserve quota historically used by the non-sector - 25% has been chosen as the starting percentage because, when adjusted for historic use, we estimate it will provide the non-sector with an overall amount of reserve quota of a value equivalent to that which they would use under the status quo
• reserve quota will be allocated in full via FQA units to the sector and non-sector where there has been zero historic use of the top slice from 2016-2019

Table 2. Historic use of the top slice by the non-sector 2016 to 2019

Stock	Average % historic use of the top slice by the non-sector 2016 to 2019
Angler 7	0
Cod 7a	0
Cod 7d	0
Haddock 7a	57.54
Haddock 7bk	100.00
Hake 67	69.78
Ling 4	48.96
Ling 6-10,12,14	3.68
Megrim 7	0
Nephrops 7	8.92
NS Anglers	0
NS Cod	81.57
NS Haddock	64.05
NS Hake	0
NS Lems and Witches	0
NS Megrim	0
NS Nephrops	75.00
NS Plaice	0
NS Saithe	53.32
NS Sole	86.78
NS Turbot and Brill	0
NS Whiting	33.33
Plaice 7a	0
Plaice 7de	100.00
Plaice 7fg	0
Pollack 7	100.00
Sole 7a	14.12
Sole 7d	47.55
Sole 7e	100.00
Sole 7fg	46.74
Whiting 7bk	36.80
WS Anglers	71.68
WS Haddock 6a	61.46
WS Haddock 6b	99.01
WS Megrim	0
WS Nephrops	0
WS Saithe	87.05

Note that a distinction has been made between stocks with more than 100t of reserve quota and those with 100t or less because the previous top slice policy allocated these differently. A method based on the historic use of these reserve quotas must account for this. Applying the historic use percentage in the same way to all reserve quotas would lead to either very small top slice allocations of reserve quotas below 100t, or very large allocations of top-slice quotas above 100t.

The North Sea Fully Documented Fisheries scheme

The North Sea Fully Documented Fisheries scheme has proven the utility of Remote Electronic Monitoring (REM) cameras over the last 9 years and extending it into 2020 would continue to form a useful long-term dataset showing the full breadth of all catching within these fisheries. Defra will therefore continue to support this scheme by allocating the total amount of reserve quota for North Sea cod, saithe, haddock, whiting, and turbot and brill to a pool that will be released to vessels participating the in North Sea Fully Documented Fisheries scheme. We acknowledge the consultation responses that indicated the late release via FQA units of unused quota for FDF and other stocks held in the pool caused various problems for the sector. For 2020, no stocks other than those in the FDF scheme will have their reserve quota held in a pool. And, in order to provide meaningful incentive for the FDF scheme, the reserve quotas for FDF stocks will not be released via FQA units if unused.

Choke management

Reserve quota could be used to help alleviate the pressure of choke species. In the past this has meant alleviating choke in the sector by not top slicing for the non-sector. However, the existing quota trading mechanisms already achieve this goal and we consider that management of choke on a domestic level is best achieved through quota trading. We have taken account of significant feedback from the consultation that using reserve quota was not considered as the best way to manage choke.

Reserve quota calculation

Defra notes the consultation responses saying that there was a lack of clarity in how the reserve quota was calculated for each stock in 2019. In 2020, as in 2019, Defra has calculated the reserve quota amounts by multiplying the English quota by the discard rate for each stock from 2018, as reported by ICES, where available. Where these were not available, equivalents based on ICES unwanted catches of these stocks were used.

Reserve quota beyond 2020

This reserve quota policy applies to 2020 only. We will continue to review our approach to reserve quota taking into account any future changes to our discard policy and quota management after the end of the transition period.

5.2 Changes to the English QMR

The government is grateful to the respondents for providing their views on the updates to the English QMR, the majority of which were met with support. The English Quota Management Rules have now been updated with the proposed changes as well as minor changes suggested by respondents (e.g. no longer referring to the Common Fisheries Policy as “new”).

The government has taken into account the views expressed by some consultees that further information should be included in the English QMR on the allocation of reserve quota and top-slicing. The English QMR now expressly refers to the reserve quota policy, explains how reserve quota was allocated from 2016-2019 and explains that a new method will be used from 2020 onwards. Further, it provides a link to the gov.uk page where this consultation response, and the allocations of reserve quota for 2020, can be found.

The government also recognises the need for a broader update of the English QMR in the near future. 

6. Annex I – List of all organisations who responded to the consultation on English reserve quota policy in 2020 and updates to the English Quota Management Rules (in alphabetical order)

Andrew Marr International

Anglo-Scottish Fish Producer Organisation

Coastal Producer Organisation

Cornish Fish Producer Organisation

Cornwall and the Isles of Scilly Local Enterprise Partnership

Cornwall Council

Eastern England Fish Producer Organisation

Fishmongers Company Charitable Trust

Jubilee Fishing Co Ltd

Lockers Trawlers LTD

Manx Fish Producers Organisation

Marine Management Organisation (MMO)

North Atlantic Fish Producer Organisation

New Under Ten Fishermen’s Association

Peter & J. Johnstone Limited

South West Fish Producer Organisation Ltd

Waterdance Limited

Yorwarth Fresh Fish

7. Annex II - Breakdown of responses per question

Question	Sector	Non-sector	Charitable Trust	Council	Management body	Total
What do you think the advantages and disadvantages of continuing to top slice this quota in 2020 and beyond would be?	21	7	1	1	1	31
Are there more appropriate methods for supporting the inshore fleet while at the same time ensuring that the whole fishing fleet receives an adequate and fair share of fishing opportunities?	20	8	1	1	0	30
If top slicing is used in 2020, which method should be adopted	11	6	1	1	0	19
If top slicing is used in 2020, which method should be adopted: - Preferred top slice method detail	19	7	1	0	0	27
Which stocks should or should not be omitted from top slicing?	19	6	1	0	1	27
Based on information currently available to you, when in 2020 would you experience choke due to the stocks in your previous answer, if you did not receive additional allocated quota?	19	5	0	0	0	24
What impacts, other than choke would result from these stocks being omitted or not from top slicing?	18	4	0	0	0	22
Please specify what measures your fleet or vessel(s) have already taken to improve selectivity for these stocks. If no selectivity measures have been adopted, please explain why	18	6	0	0	0	24
Is there anything else you think we should consider in determining the 2020 reserve quota policy, including any feedback you have on the 2019 reserve quota policy communications and guidance?	19	6	0	1	0	26
Do you agree with the proposed changes provided in the draft? Please provide the reasons for your answer.	17	6	1	1	0	25
What, if any, further updates to the QMR should be made?	16	4	0	0	0	20
What other comments or observations do you have about the English Quota Management Rules?	16	5	0	1	0	22

1. “Sector” refers to fishing vessels that are members of Producer Organisations. ↩

2. Historic use refers to the average percentage of the top slice used from 2016-2019 for landings and for quota trades by the MMO. Trading may increase the overall use when quota is traded out, or decrease it when traded in. Landings use prior to inward trade is accounted for by using the highest percentage use figure out of landings only or landings plus trades. ↩