Irish Sprat near Extinction due to Unregulated over-Fishing

Sprat, Sardine, Capelin, Anchovy

sprat sardines anchovy capelin

European sprat (Sprattus sprattus)

European sprat Sprattus sprattus

Dáil  Eireann 2020 - industrial sprat fishing report

Irish Sprat near Extinction due to Gross Unregulated Over-Fishing

The conservation status of European sprat - Sprattus sprattus - in Irish waters is again a source of grave concern for conservationists and environmentally aware Irish citizens in general, as along with sand eels, krill and zooplankton in general, sprat forms the basis of the marine food web, converting plankton into protein for marine predators including cetaceans (whales, dolphins and porpoises); grey seals; breeding seabirds - puffins*, gannets, guillemots, razor-bills*, arctic terns, kittiwake*; commercial fish stocks including herring, mackerel, hake and cod and of course is also edible for humans and rich in omega-3 and other  beneficial minerals.
* red-list Species [High conservation concern] - "Birds of Conservation Concern in Ireland 2020-2030". Gilbert G. Stanbury A and Lewis L (2021).

Despite all this, and despite the fact that up to 70% of the food resources for humpback whales migrating through Irish waters during the summer months on route from the feeding grounds in higher latitudes  to the breeding grounds around the Cape Verde islands, consist of sprat as per I.W.D.G. [Irish Whale & Dolphin Group], there is no protection under Irish Law for this endangered species, no European TAC [Total Allowable Catch] which means there is no limited , protective quota for the species; no Landing Obligation; no Management Plan, no Stock assessment for the species and Ireland is reneging on its commitments under the UN sponsored Bonn Convention on the Conservation of Migratory Species of Wild Animals 1979 which it has signed up to in 1983, but not it appears in good faith!

 Some [Awful] Sprat Facts from Marine Institute Stock Book 2021: Annual Review of Fish Stocks in 2021 and Management Advice for 2022 [Hah! Hah!]

Some 8 pages out of a total of 497 pages are devoted to sprat stocks and  make for dismal reading for anyone interested in the ecosystem approach to big fishing quotas or lack of quotas, even though at one point the author notes:
"European sprat is an important species in the trophic web as it links between zooplankton and top predators (fish, birds and marine mammals)". Yet, the author admits that there is "No Management Plan" for sprat in Irish waters and under the heading Landing Obligations admits that landing obligation "Does not Apply (not a TAC species)".
The majority of the catch is taken in area 7 [Kerry Bays], 7aS [Dunmore East] and 6aS [Donegal Bay]".
Landing figures in the Stock Book are confusing and one suspects under-reported and estimated, but even so they show a huge increase in official landings over the last few years from:
3,580 ton in 2018
14,353 ton in 2019
15,172 ton in 2020
- [ from page 428 The Irish Stock book November 2021]
and [possibly over 15,00 ton for 2021
Figures are not yet available for 2021 official sprat landings but anecdotal and on-the-ground evidence shows increased fishing effort in Kerry and Cork bays in particular  once the stay on the ban on vessels >18m from fishing within the 6-mile zone was lifted.
All of this against the ICES [International Council for the Exploration of the Seas] statement in the Stock Book which gives the scientific advice to  the EU to set sustainable fishing quotas under the CFP [Common Fisheries Policy] advice for 2022;
"ICES advises that when the precautionary Principle is applied, (sprat) catches should be  no more than 2,240 ton in each of the years 2022 and 2023".

Present unregulated catches of sprat are running at least 6 /7 times above the ICES advice to the Irish State regarding sustainable catch limits!

It beggars belief why sprat - which along with sand eels and krill and even zooplankton which are further down the trophic food chain -- are so disregarded that they are not at least made part of the TAC [Total Allowable Catch] system of setting sustainable catch quotas, or even that there is not sufficient data available of population density to protect them.
The International Union for the Conservation of nature [IUCN] classifies the conservation of sprat in Irish waters as "Data deficient" which surely is all the more reason why this data needs to be collected urgently and a moratorium put on any further fishing effort as per the precautionary principle until stocks can be quantified  and adequately assessed and a scientifically based, sustainable fishing quota, if  any, ascertained.

The same applies to sand eels  which one fears will be the next forage fish target of unsustainable fishing if left unregulated, especially if sprat stocks are protected and sand eels are not..

Some (4) Ways to Save and Conserve Irish Sprat Stocks

                              1. Legal Route:

Because they are such a keystone species in the Irish marine food web all environmental NGOs in Ireland support the recent attempt to ban fishing vessels >18m. from pair trawling for vulnerable sprat shoals in inshore Irish waters, including bays and estuaries, and inside the 6-mile limit. The ruling from the Appeal court to the lifting of the 6-mile exclusion area for vessels >18m. is still awaited, which said that trawler owners did not get a fair procedure and were not consulted properly about the exclusion. Obviously from an environmental point of view the protection of Irish sprat stocks must be the priority and some regulations have to be brought into the fishery..
However, at the same time, fishermen (big and small) must be treated fairly and nobody should be penalised or "out of pocket" while new procedures  or regulations are put in place. There was a 3yr. adjustment period envisaged for large trawlers in the original legislation but as the number of larger trawlers involved is small and the total value of the estimated catch is relatively small at 3.3 million for 2020 [Irish Stock Book], surely some kind of mechanism can be worked out whereby if these  trawlers agree to stop fishing for sprat within the 6-mile limit they should be compensated for giving up the fishery by giving them the estimated value of the catch for 3  yrs, or the estimated value of the recommended tonnage for those 3 yrs. Both sides must keep talking to each other [the State and fishermen's representative(s)] and obviously if not, then, the State must appeal any adverse ruling to the highest courts in the land and then to Europe as otherwise the ECJ [European Court of Justice] will not hear the case if all domestic legal avenues have not been tested.

The best solution might be to allow inshore fishermen wiith vessels <18m. to catch the annual recommennded sustainable catch quota (as per ICES) of 2,240 tons and compensate vessels >18m for exclusion from the 6-mile zone for the first 3 years for the equivalent value of the annual sustainable catch.

A moratorium should be placed on the fishery until a sustainable solution is found.

2. Bonn Convention on the Conservation of Migratory Animals [CMS Convention}

The CMS Convention was set up "to conserve, terrestrial, marine and avian migratory species throughout their Range".

Ireland is a ratified party to the UN sponsored Bonn Convention on the Conservation of Migratory Species of wild Animals 1979 [CMS Convention] since 1983, The CMS aims to conserve the habitats and migratory routes and ranges of migratory animals. IWDG have recently estimated that sprat in Irish waters comprise up to 70% of the food resources of many humpback whales using the west and south coasts of Ireland as a feeding station. During the last number of years since IWDG first photo identified HBIRL001 for the Irish Humpback Whale Catalogue back in September 1999 the number of photo-identified humpback whales in Irish waters has increased to 113 individuals - [23.01.2022]
Under this Convention, which the Irish State has signed, we are obliged to protect the habitat and food resources for these migratory animals which is totally necessary for them to build up their fat reserves for their long journey south where they may not eat for up to 2 months in the breeding grounds. There is a fledgling whale watching industry along the west and south coast of Ireland based on these migratory cetaceans which supports local communities, many decimated by the collapse of the fishing industry and now worth a lot  more to the local community than the €3.3 million which the present sprat fishery is worth - until it too inevitably collapses due to unregulated, unsustainable over-fishing.
Sprat is also the main food resource of many of our breeding migratory seabirds including the red-listed puffin, kittiwake and razor-bill and the amber-listed fulmar, Manx shearwater, gannet, Arctic tern, black guillemot and common guillemot among others. [ "Birds of Conservation Concern in Ireland 2020-2026" Irish Birds 9: 523 - 544] Gilbert Get al.
We should honour the commitments the Irish State made under the CMS Convention as a fully signed up Party and as a Range State to protect and help to conserve the migratory species that use Ireland and its surrounding seas, especially our inshore waters (within the 6-mile limit), bays and inlets and estuaries.
Perhaps some of our environmental NGOs have the knowledge, skill set and advocacy know-how to make a "petition" to the CMS committee to protect this valuable and necessary resource for migratory species of wild animals?

                             3. Marine Protected Areas [MPAs]

Natura 2000 and the Habitats and Birds Directives are closely related implementing tools for the CMS Convention, the implementation of which are requirements for member states under European law and Ireland can be taken to the European Court of Justice [ECJ] for non-designation in National Law and non-protection of these areas. Ireland has just finished setting out terrestrial SPAs but not of course the pro-active practical implementation of protection measures for endangered species like farmland birds etc. With just 2.5% of our required 10% marine environment designated as Marine Protected Areas (and projected designation requirement of 30% by 2030) we are the laggards of Europe in this environmental respect. As Mr. Ciobanu-Dorlea, senior official at the EU Directorate-General for Environment said at the Environment Ireland Conference in Dublin this week (18/19 January, 2022):
"This represents one of the poorest records across the Natura 2000 network in Europe"

The designation of this 10% of the marine environment as MPAs was supposed to have been completed by 2020!

Perhaps an appropriate way to address this deficiency is to enlarge and re-designate or co-designate as MPAs present marine SACs and SPAs to include inshore bays and estuaries out to the 6-moile limit including in Cork, Kerry and the Shannon Estuary and  enforce a legal ban on the  fishing for sprat and sand eels within these newly designated areas until required Management Plans are in place for vulnerable fish stocks and migrating animals and birds.
The Irish State is breaking European Law at the moment by not having suitable Management Plans in place for the existing marine SACs and SPAs and obviously not enforcing any ban on unsustainable and damaging fishing practices within the marine SACs and SPAs.

                               4. The Irish Wildlife Acts 1976 to 2021

It is a well known fact that the Irish Wildlife Act 1976 and various amendments up to 2021 provide little protection for marine fish [as opposed to freshwater fish] and invertebrates. Some trophy fish are protected, though ones usually associated with fresh water habitats such as Atlantic salmon, silver eels (on their way to the Saragossa sea) and lampreys. Recently, Jennifer Whitmore of the Social Democrats introduced a Bill in the Seanad to amend the Wildlife Act to protect basking shark. So perhaps this is the way to go in order to gain protection for Irish sprat and sand eel stocks.

The alternative seems to be watching the unregulated, unsustainable fishing of the stock to virtual extinction as  well as  the resulting demise of many of our red and amber listed seabird species including puffins, guillemots, razor-bills,  arctic terns and kittiwakes which rely on these  sprat shoals to  successfully rear their young and the disappearance of humpback whales from our shores and the end of many of the marine based industries and associated jobs that have grown up organically from their presence off our shores.

It may be possible to get a Bill introduced in the Seanad - as Dr. Jennifer Whitmore did, to her credit, for our basking shark - or it may be necessary to get the relevant Minister in charge of Fisheries Mr. Charlie Mc Conalogue, T.D. Minister for Agriculture, Food and the Marine, or the Minister of State for Biodiversity Senator Pippa Hackett, or the Minister of State with responsibility for Heritage Mr. Malcolm Noonan T.D. to introduce a Bill to

Amend the Wildlife Act 1976 to protect Irish stocks of European sprat (Sprattus sprattus) and also Irish stocks of sand eels , both the Greater sand eel (Hyperoplus lanceolatus) and the Lesser sand eel (Ammodytes tobianus) out as far as the 12-mile limit.

. The best way to  do this may be to introduce a Bill to amend the 5th Schedule of the Wildlife Act 1976 to 2021 as amended, to include both sprat and sand eels as protected species due to their importance as the base of the marine food web  and as "keystone" species whose absence would collapse the viability of animals higher up the marine trophic food chain, including migrating whales and dolphins and migrating, breeding seabirds.and also commercial fish stocks.

This may be the best way of avoiding further lengthy and prolonged court cases or having to appeal to the ECJ or the UN (for wilfully and knowingly - both as a signed Party State and as a Range State -  contravening and disregarding the CMS Convention).

Either way, the justifiable concerns of >18m trawler owners  engaged in the fishery must be taken on board and they must be consulted adequately and compensated adequately for potential lost earnings for the introduction of a sustainable fishing regime based on future sustainable fishing quotas for sprat, if any.

Such a settlement would be a small price to pay for the protection of such a vital part of the marine food chain and combined with a similar protective status for sand eels would ensure the viability of our migratory breeding seabird colonies and the continued valuable presence of our migratory large whales to local communities.

In the meantime, there needs to be a moratorium put in place on fishing effort for European sprat in Irish inshore waters, based on the precautionary principle, in order to preserve our sprat stock for future generations of (commercial) fish stocks, seabirds, cetaceans and the livelihoods of coastal communities - all depending on a healthy marine food web to survive and thrive.

Appendix 1

More than half of sprat landed in Ireland since 2019 was by vessels >18m.
- S.F.P.A. [Sea Fisheries Protection Authority]

Appendix 2

Uses of Sprat Fishery [S.F.P.A.]

66% - Fishmeal*
20% - Unknown use
10% - Human consumption (direct & indirect)
4% - Other (bait, industrial, waste)
* (Fishmeal is used for farmed salmon, dogfood, cat food, mink and pig farms - author]

Appendix 3

Price per ton paid to fishermen for sprat in 2021

Average price per ton for 2021 was €200 / €220 per ton

- [ based on value of fishery at €3.3 million and tonnage of official catch at approx. 15,000 tons for 2021]

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