Select Committee on Agriculture Appendices to the Minutes of Evidence


Memorandum submitted by the Sea Fish Industry Authority (T11)


  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 sector only).

  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 sector—and 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 states.

  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

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