APPENDIX 6
Memorandum submitted by the Chief Executive
of the Sea Fish Industry Authority (K14)
Thank you for your invitation to comment on
the proposed reforms of the CFP. The Sea Fish Industry Authority
(Seafish) is a non-departmental public body established in 1981
and therefore predates DEFRA. Pan-industry experience and involvement
are such that the following comments will be broad in perspective
rather than deep in detail and will tend to be of a non-political
nature.
The stated objectives for the Common Fisheries
Policy (CFP) Review are:
"Reform must lead to a new CFP capable of
providing sustainable development in environmental, economic and
social terms. This will be achieved through measures aiming at
— responsible and sustainable fisheries
and aquaculture activities that contribute to a healthy marine
eco-system;
— an economically viable and competitive
fisheries and aquaculture industry which will benefit the consumer;
— a fair standard of living for those
who depend on fishing activities."
You have asked us to look specifically at six
points and I will address each of these in order.
1. THE EFFECTS
OF THE
PROPOSAL ON
THE FUNDAMENTAL
PRINCIPALS OF
THE CFP
The reforms as published are comprehensive and
capable of meeting the objectives as stated above. Their limitation
is lack of specific detail and it is understood that this is being
developed through consultation in such ways as this. Our concern
however is that quite aside from consultation there is a simultaneous
process of political negotiation at the widest EU level.
The CFP sits within a wider EU agenda for the
complete reform of the Common Agricultural Policy (CAP) and our
fears are that it is the CAP reforms that will command major political
attention and subsequent funding. Already there are intimations
suggesting that some elements of the CFP proposals, such as the
removal of the financial support for any new building of fishing
vessels, already are being undermined or given away in exchange
for political conciliation. Such erosion of certain key elements
undermines the strength and stability of the entire proposals
and it seems likely that UK fishermen will be disadvantaged by
such compromises.
2. TO WHAT
EXTENT WILL
THE PROPOSALS
IMPROVE QUOTA
MANAGEMENT AND
CONSERVATION—AND
WHAT ALTERNATIVES
MIGHT BE
CONSIDERED?
Quota management, total allowable catches [TACs]
and conservation are dependent on accurate base information and
robust science. The complexity of marine eco-systems is such that
we have only a limited ability to model their dynamics and the
influence of anthropogenic inputs. Uncertainty here is compounded
by the likely effects of climate change over the coming years.
Stock assessment scientists also recognise that
their quota recommendations lag behind the supporting data by
about a year. Added to this is the further delay in tracking catch
levels, determining when targets have been reached and then preventing
further fishing mortality through discarding. Seafish endorses
the strengthening of technical measures to reduce by-catches and
discards in mixed fisheries, protect younger fish and vulnerable
species. Measures such as larger mesh sizes, square mesh panels
and discard bans should only be implemented in consultation with
fishermen.
The principle of involving fishermen in generating
reliable catch data, including discards, is a crucial part of
the solution to these difficulties. There are many examples in
other parts of the world, in particular in Australasia and Canada,
where their fishing industries have been providing this information
with increasing confidence for many years. For this principle
of stakeholder involvement to have any credibility in a reformed
CFP, a prior requirement is the elimination of "black fish"
and compliance with the requirement to record fishing information
honestly and accurately. Conservation will not be achieved without
the active support of fishermen and they in turn must not be encouraged,
albeit passively by non-enforcement, or allowed, to perpetuate
a duplicitous system.
In the end, these proposals will depend as much
on compliance and enforcement as on science. No matter how good
the science it will be rendered irrelevant if the actual catch
differs significantly from the allocated quotas. Seafish do not
propose alternative policies because the Green Paper as amended
represents a comprehensive and coherent set of proposals. They
are appropriate to the challenge but their successful implementation
will depend upon maintaining their integrity and providing significant
additional funding for fisheries research and related science.
3. THE IMPACT
OF THE
PROPOSALS ON
THE STRUCTURE
OF THE
BRITISH FISHING
INDUSTRY
Seafish have recently published (June 2002)
an Economic Survey of the UK Fishing Fleet. This concludes that
most sectors of the industry are working below viable economic
cost recovery, and with the exception of the few northern based
large pelagic vessels, the traditional white fish catching sector
is already in a critical condition.
Reducing fishing effort by restricting days
at sea will further reduce incomes in many areas to the level
at which we would expect many to give up altogether. Fleets which
fish for non-quota species, such as in the south west of England,
would be penalised without any consequential benefit for target
stock conservation. Days of entitlement to fish should therefore
be adjusted to reflect local conditions.
These reform proposals suggest that quota will
have to be further reduced to meet sustainability objectives for
demersal round fish stocks. Quota is likely to become a property
right of value within and potentially across nation states. As
tradability of quota increases there is an increasing likelihood
that UK quota will be owned by non-UK interests. "Ring fencing"
quota (quota which can only be bought and sold within defined
regions, eg Grampian, Shetland) is one method to maintain the
traditional fishing rights for vulnerable fishing communities.
Without such protection, and notwithstanding arguments against
any form of market distortion, the impact would be to accelerate
the decline of the remaining fishing fleet working outside of
the 12 mile limit. Further attention should be given to matters
of transitional aid and funding during this process of restructure.
Transitional aid should also be considered as
an answer for two different needs, the catching sector itself
as well as those businesses that service or are dependent upon
it, each with different time bases.
(a) The level of aid and the ways in which
it is targeted need to reflect the short term reduction in effective
effort that is required. That reduction is predicated on a series
of target bio-mass levels for the various stocks. These are projected
to build over a five to seven year period and will then offer
new opportunities for exploitation. The UK should therefore be
careful to maintain sufficient latent capacity to capitalise on
the rebuilt stocks.
(b) A further decline in the UK catching
sector will not only impact primary processing business, but also
on other onshore support sectors. During the whole of the transitional
period care will also have to be exercised to ensure that regional
service infrastructure—for example in gear supply, safety
equipment, repair, maintenance, training and so on—does
not collapse through lack of demand.
A review of these aspects should help to ensure
minimal disruption to coastal communities. Without it there is
a real risk that effort reduction will have an unnecessarily disproportionate
impact.
4. ADEQUACY OF
PLANS FOR
SOCIAL HELP
Defra's Strategy for the Conservation and Sustainable
Development of our Marine Environment Safeguarding our Seas comments
in chapter 7 "the green paper rightly recognises that the
current system is failing to provide an adequate living for many
fishermen through its failure to conserve fish stocks for present
and future generations".
Seafish endorses all the principles in this
strategy but note Defra's wider objective to protect the social
infrastructure of communities dependant on the fishing industry.
The UK primary fish processing industries are
clustered around the ports of landing and their dependence on
the UK fishing fleet is direct and significant. Further decline
of the UK catching sector will drive many of these smaller primary
businesses and local employers out of the industry. Research currently
being carried out by Seafish indicates that for every job lost
at sea, an additional 1.2 jobs will be lost onshore.
The secondary processing industry which already
depends heavily on imported fish, is at risk from competition
from imports to provide finished processed products rather than
simply raw material. This latter risk is yet to be determined,
but the threat to local fishing communities has been reinforced
recently by the closure of a Nephrops processing factory in Kilkeel
and the collapse of Albert Fisher Group based in many sites throughout
the north or England and Scotland.
The entire processing industry is one of very
low margins and as such the threat of small economic changes are
multiplied into very serious local community problems. Plans for
social help are not explained in sufficient detail comment on
their adequacy or otherwise.
5. FLEXIBLE SYSTEMS,
SHORT TERM
ADJUSTMENTS TO
QUOTAS AND
REACTION TO
CHANGES IN
FISH BIOLOGY
Proposals for the establishment of Regional
Advisory Councils for fisheries management are welcomed. Details
of these have still to be clarified but it is clear that structures
will have to vary so that each can accommodate prevailing conditions.
Our concern is that whilst the Commission is willing to allow
the decentralising of competence they have made no public commitment
to the devolution of power that subsidiarity would require. This
is necessary in order to give credibility to the concept of a
real transition towards regionalisation. Without such an expression
of commitment the new advisory bodies may not attract the support
of key players or engender responsible participation.
Each regional body will need to agree a basis
for generating and interpreting scientific knowledge and to recognise
the range of appropriate technical measures available for certain
pre-determined situations. This seems to be covered in principle
but our concerns are that this is one of the areas where UK fishing
industry interests are most likely to be subsumed by lack of national
political support.
6. EMPHASIS ON
PROPER ENFORCEMENT
OF THE
CFP
The proposed action plan to eradicate illegal,
unreported and unregulated (IUU) fisheries is welcome, as is recognition
of the obligations of member-states to ensure the effectiveness
of management measures applied equitably and to similar standards
throughout the EU.
The biggest single problem restricting agreement
to improve the industry is a lack of well-established, dependable
statistics on which management decisions can be made, and within
which the problem area of black fish has been recognised.
Proposals to register first buyers and sellers
of fish would be a significant first step towards eliminating
sales of black fish, and the noise now reverberating to Defra's
consultation on these proposals is evidence that concern that
this might indeed be the case is widespread. However, applying
these in isolation to other pan-EU management regimes again would
prejudice UK fishing interests.
One particular UK fishing sector showing anomalies
which must be rectified before further changes are considered
is that of the Scottish Nephrops. Quota management for
this prawn/scampi species was introduced relatively recently and
at levels that seem to have been influenced strongly by the precautionary
principle. Current levels are recognised by industry and scientific
advisors alike as not reflecting the best available stock information.
This species is not under threat at present levels of exploitation
and quota must be adjusted upwards to reflect what is now being
caught before any further controls are introduced. Nephrops fishermen
must be trusted to respond responsibly and enforcement regulations
applied rigorously thereafter.
CONCLUSION
We trust that the above remarks are helpful.
It is inevitable that "noise" will increase proportionately
as both CFP and quota negotiations approach December deadlines.
We conclude by urging that attention should be focussed on:
— maintaining the coherence of the
Green Paper's proposals during negotiations, resisting any moves
towards partiality or sectoral bias;
— recognising the fragility of much
of our fisheries, their associated infrastructure and their dependent
communities;
— retaining exclusive coastal state
access to the six mile zone;
— coastal states must have powers to
enforce EU-approved national management measures equally to any
and all vessels fishing through "historic rights" within
the six to 12 mile zone;
— maintaining the principle of relative
stability;
— sustaining the benefits of relative
stability by discouraging free trade in fishing entitlements;
and
— engaging the catching sector as constructive
partners, true stewards of the marine environment and a part of
the solution.
Restructuring by chaos would represent the worst
of all possible worlds.
27 September 2002
| 
