Memorandum submitted by the Sea Fish Industry
ISSUES OF GREATEST IMPORTANCE TO THE UK FISH
This paper summaries the Sea Fish Industry Authority's
views and draws from those expressed in the Fish Industry Forum's
report: "Strategies and Requirements for the UK Seafood Industry".
Many of the points are consistent with evidence previously submitted
by the SFIA to the Agriculture Committee, in 1998-99, and incorporate
more recent developments. Points raised, focus on the important
issues within the UK fish industry and measures that need to be
taken to resolve such issues, they relate to the UK "fish"
industry, not "fishing" industry (which implies catching
1. The UK market for fish and fish products
is currently buoyant, as evident from the market research summaries
enclosed with this paper. The future prospects are bright, provided
that: (a) the industry, especially its processing sector, remains
profitable; (b) that there are sufficient resources for re-investment,
including investing in promotion of fish's benefits to consumers;
(c) that the marine environment can be well managed, especially
in respect of reduced pollution; and (d) that any health issues
relating to fish are objectively assessed and are communicated
responsibly to consumers, balancing risks against benefits.
2. The UK fish industry operates in a global
market, with 69 per cent of supplies for the vital domestic processing
sector now sourced from abroad (this compares to 57 per cent in
1995). Availability and continuity of competitive raw material
supplies are obviously essential for the viability of UK processing
and its on-shore employment. In the short term, free trade and
lowering of import tariffs are the main requirements for the secondary
processing sector. In the longer term, sustainability of global
wild stocks/supplies and development of aquaculture are the priorities.
Recent forecasts (FAO) predict that worldwide demand for fish
up to the year 2010 is likely to outstrip supply.
3. For international traders, such as our
secondary processors and also supermarkets groups, the factors
referred to in paragraph 2 might seem more important than the
recovery of the UK registered fleet's share of supplies. For primary
processors, that is clearly not the case and for our secondary
processors there is an inherent risk that they would, in time,
lose out to lower cost producers abroad, ie that the UK market
would increasingly import processed fish products instead of fish
for UK processing. Developing UK aquaculture and sustaining a
viable UK fleet, with the ability to land more fish into UK ports,
should therefore be a strategic priority for the whole of the
UK processing sectorand for preserving on-shore, as well
as off-shore, employment.
4. Whether globally or in the fishing grounds
accessible to the UK registered fleet, the overriding need is
to establish fisheries management systems that will ensure sustainability
of stocks. The 2002 Review of the CFP provides the opportunity
to address its well-documented shortcomings. The question is not
whether changes should be made, but "which changes?"
The following paragraphs, 5 to 12, cover approaches to fisheries
management which should be considered as priorities.
5. Decentralisation of Fisheries Management
(ie Zonal/Regional Management), is a concept which the SFIA and
the Fish Industry Forum support. Examples of devolved management,
where local fishermen/organisations are working to solve local
problems, can be found in the Irish Sea and Shetland.
6. Reducing discards and the protection
of spawning and juvenile fish are key elements in achieving sustainable
stocks. The limitations of TAC's in a mixed fishery are well known.
The implementation of further gear regulations (eg for square
mesh panels) and the merits of closed areas/seasons, limited entry,
and days at sea controls should all be further investigated, with
the involvement of fishermen and/or their representatives. The
Norwegian "no discards" policy should also be thoroughly
investigated so as to resolve whether it, or an appropriate adaptation,
could be beneficial and practical within the CFP.
7. There needs to be effective management
and conservation of inshore waters. As such, an amendment to the
CFP to exclude common access from baselines to 12 nautical miles
should be pursued. The introduction of Regulating Orders should
be developed further. For the shellfish sector, in particular,
there is a need to develop a management scheme which will balance
conservation requirements against improved access to the resource,
including ownership and long-term security.
8. The process of setting annual Total Allowable
Catches (TAC's) is a rather blunt instrument, and has undoubtedly
inhibited fishermen from both longer term planning and the successful
adoption of measures to restore stocks. As such, the merits of
multi-annual, multi-species TACs should be considered further.
9. Sustainability will only be achieved
if the correct balance is struck between fleet capacity/effort
and stocks. Government proposals aid to the industry through decommissioning
grants are welcomed, although the implications need to be well
thought out. The shortcomings of previous decommissioning schemes
are well documented (eg selecting tenders on a straight £/VCU
basis), and alternatives should be examined. One of the options
could be changing the parameters used for bid analysis to Gross
Tonnage (GT) and Power (kW), and extending the criteria to include
activity levels by incorporating GT days and kW days (UK tonnage
measurement are not consistent). To help tackle the phenomenon
of "technological creep" the introduction of an age
parameter in future decommissioning tender analysis should be
considered. The SFIA has put forward ideas on this and these should
be followed up.
10. For the longer term, introduction of
property rights should be considered as part of the CFP reform,
not least because they can harness economic self-interest to stock
conservation and to the policing of regulatory measures. Property
rights have effectively been created de facto through the trading
of licences and the introduction of Fixed Quota Allocations (FQA's).
Perhaps the time has come to formalise, within the CFP, the rules
for Individual Transferable Quotas (ITQ's), including the "ring-fencing"
of their transferability to within specific geographic areas and/or
PO's. The extent of such "ring fencing" is a sensitive
political issue, in which potential economic and organisational
advantages from rationalisation ("corporatism") need
to be weighed up against the social and motivational benefits
of small family businesses in the catching sector.
11. The UK fleet is ageing and is less efficient
than it should be (especially in England). It is difficult to
see how the fleet can be expected to be competitive within the
EU, if competitors receive subsidies that it is denied. To improve
safety and efficiency of the domestic fleet, the SFIA has advocated
a structured "scrap and build" programme (as recommended
to the Agriculture Committee in 1998-99). The outcome should be
a smaller but competitive and profitable fleet.
12. Enforcement. It is imperative that any
EU fisheries management regime is applied and enforced equitably
across all member states. Equally this must be done, and recognisably
done, for EU regulations applicable to the on-shore fish industries.
The UK fish industry feels strongly that government should provide
equity of treatment and fair competition for all sectors, by making
financial assistance available and implementing regulations on
a not less favourable basis than the practice in other EU member
13. There is increasing commercial pressure
from the food industry for supplier quality standards and traceability.
It is important to promote the improvement of fish quality and
traceability, in order that the industry obtains the maximum return
from a limited resource.
14. Reducing Waste. Less than half (by weight)
of the UK supply of fish is consumed as food. There needs to be
a co-ordinated research programme to establish higher value uses
for fish waste, most of which is now sold for fishmeal and which
has to be disposed of, at a cost, wherever transportation to fishmeal
factories is not available. The SFIA has initiated waste reducing
and utilisation projects, which need more external funding.
15. Structural change is underway throughout
the industry. There is a need to improve quality and transparency
of data and it is essential to conduct research to identify and
quantify the social and economic impact of policy options. It
is up to government and regional/local agencies to determine the
scope for diversification and the balance of support for new and
traditional businesses in fisheries dependent areas. Restructuring
of the industry will create recruitment and training needs for
which the SFIA, as National Training Organisation (NTO) for the
UK fish industry, should be involved and grant supported.
30 April 2001