Memorandum submitted by the Royal Society
for the Protection of Birds (RSPB) (W08)
EXECUTIVE SUMMARY
— The RSPB supports the broad thrust
of the Strategy Unit's report, "Net Benefits: A Sustainable
and Profitable Future for UK Fishing", as a basis for
putting the UK fishing industry on a sustainable footing.
— 24 of the report's 33 recommendations
are addressed to "Fisheries departments", with just
one addressed to the industry itself. This is a tacit acknowledgement
of mismanagement of the industry.
— Environmental integration is a prerequisite
for a more sustainable fishing industry. The fortunes of fisheries
cannot be divorced from those of the marine environment.
— The lack of emphasis within the report
on aquaculture and the processing sector is a matter of concern.
— We support the report's rejection
of calls to take the UK out of the Common Fisheries Policy, which
would simply require renegotiation of bilateral fishing agreements
with all neighbouring EU Member States.
— We welcome the inclusion in the report
of climate change as one of the key assumptions for stock projections
although adverse impacts on sandeels are overlooked.
— While we support the recommended
further reduction in the whitefish fleet, the report pays insufficient
attention to desired future composition in terms of vessel size
and power.
— We support the emphasis in the report
on effort-based management for mixed fisheries, which is simpler
than seeking to control outputs (ie landings).
— We support progressive regionalisation
of the management functions of the Common Fisheries Policy.
— Implementation of both Strategic
Environmental Assessments and Environmental Impact Assessments
in fisheries would make a major contribution towards an ecosystem-based
approach to fisheries management.
— We welcome the recommendation for
development of Marine Protected Areas and experimentation with
how best to achieve fisheries and multi-use benefits from such
areas. Fisheries "No Take Zones" should be a key component
of this concept.
— We support the recommendation to
provide incentives to improve environmental performance of fisheries
and encourage development of less damaging gear.
INTRODUCTION
1. The RSPB is committed to promoting the
sustainable development of the UK fishing industry, which would
promise not only a more viable and profitable industry but also
a healthier marine ecosystem. Reform is urgently needed to avert
the increasing hazard of stock collapse, damage to critical fish
habitats, and knock-on effects on marine wildlife.
2. The RSPB was a stakeholder in the consultation
meetings leading up to the Strategy Unit report "Net Benefits:
A Sustainable and Profitable Future for UK Fishing",
and is also a member of the Stakeholder Advisory Group set up
to take forward its recommendations.
3. The report explicitly acknowledges the
need to mend a "system broken in many places"
(p 43), namely the imbalance between UK fishing effort and available
resources, and the failure hitherto to sustain commercial fish
stocks and prevent collateral damage to the wider marine environment.
4. Government employment figures for the
UK fishing industry, post-dating those available to "Net
Benefits", show an accelerating downturn. One in eight
full-time fishermen in Britain went out of business last year,
as declining landings and measures to save dwindling fish stocks
took their toll. The number of full-time fishermen in 2003 fell
by over 12% from 10,524 to 9,242, although there was a significant
shift to part-time fishing. The industry is now over a third smaller
than it was 20 years ago.
5. The 168-page report contains 33 wide-ranging
recommendations. In this brief submission, we cannot respond to
all of them (recommendations are also paraphrased here to save
space).
OVERVIEW AND
SCOPE
6. The RSPB supports the broad thrust of
the report. There is good reason to believe the UK fishing industry
can be put on a sustainable footing if many of the report's recommendations
are adopted. On the other hand, failure to act decisively will
help condemn the industry and the marine environment to an even
bleaker future than they already face.
7. Of the 33 recommendations, 24 are directly
addressed to "Fisheries departments" and only
one to the fishing industry itself. This tacitly acknowledges
that the industry has been mismanaged.
8. There is a critical admission of management
failure on p 108: "At present, fishery managers use too
narrow an information base to make their policy advice. Fishery
managers need more information . . . on: the state of the stocks,
the profitability of the industry and economic climate; and the
change in the killing capacity of the fleet and extent of its
utilisation." To this list we can certainly add the environmental
impact of fisheries. It is extraordinary that managers are uncertain
on so many fundamental areas; if they are, and continue to be,
a highly precautionary approach should be adopted.
9. The fishing industry clearly perceives
this report as serving to promote the viability and economic returns
from the industry, to "boost fleet profits" (Fishing
News 3 September 2004, p 4). In the same article, the National
Federation of Fishermen's Organisations played down any wider
"conservation" rationale for the report. Undoubtedly,
different stakeholders will prioritise different strands, but
the RSPB regards environmental integration as a prerequisite for
a more sustainable fishing industry, and the report endorses this:
Recommendation 2: The overarching aim of fisheries management
should be "to maximise the return to the UK of the sustainable
use of fisheries resources and protection of the marine environment".
In our view it is self-evident that much of the industry's demise
lies in the spurious separation of extractive fisheries from their
interaction with the wider marine environment. In any case, the
commercial fish stocks themselves—as a vital part of the
food web—cannot be divorced from the marine ecosystem at
large.
10. We have concerns about the scope of
the report, whose stated emphasis is the catching sector (p 18,
#2.3). It is surprising that greater emphasis was not given to
aquaculture, but the reason presumably lies in the assertion (p
28, #3.1.3) that "it seems unlikely that significant quantities
of these [farmed] species [halibut, cod etc] will
be farmed in the next five years. " We challenge that
interpretation—the British Marine Finfish Association estimated
recently that, within ten years, fish farms in the UK (principally
Scotland) will be producing up to 30,000 tonnes of cod, 8-10,000
tonnes of halibut and 5,000 tonnes of haddock. By comparison,
the UK's North Sea cod quota for 2004 is less than 11,000 tonnes.
11. Likewise, insufficient attention is
paid to the processing sector. Questionable assumptions are made
in the statement (p 18, #2.3) " . . . the report does
not focus on the majority of the secondary processing industry,
as this is generally profitable and is primarily dependent on
imported fish stocks, which appear to be sustainable in the timescale
under consideration". The misplaced certainty that our
importing strategy is sound is repeated on p 36 (#3.4.1): "UK
imports mainly come from sustainable stocks and are unlikely to
fail in the future . . . ". Doubt is immediately cast
on this assertion by the large-scale importation of (Marine Stewardship
Council certified) hoki to the UK from New Zealand to make up
the whitefish shortfall in Community waters. A recent stock assessment
has shown no sign of the declining hoki stock recovering and the
New Zealand "Fisheries Ministry says there are
serious concerns about its sustainability" (WorldFish
Report No 217, 19 May 2004).
12. Chapter 3: Current situation and
challenges. A strong theme here is a fair and balanced examination
of the Common Fisheries Policy's (CFP) pros and cons, and an evaluation
of how reforms square up to the challenges facing the UK fishing
industry. The approach is pragmatic and unprejudiced and results
in a transparent analysis which, in our view, stands up to scrutiny.
13. The RSPB supports the Strategy Unit's
rejection of calls from some quarters to take the UK out of the
CFP, given that this would, among other things, create the greater
obstacle of having to renegotiate bilateral fishing agreements
with all our neighbouring Member States (p 117).
14. Chapter 4: Future scenarios for
the UK sea fishing industry. We welcome the inclusion of climate
change as one of the key assumptions for stock projections. The
report finds "No evidence . . . to support the view that
the cod fishery is limited by sand eel availability and so this
possible ecosystem interaction was not included in any future
scenarios". This may well be the case, given that cod
are at a low ebb and currently exerting little predatory pressure
on sandeels. However, the report appears to be unaware of work
showing that sandeel recruitment is also suffering from rising
sea temperatures in the southern North Sea, and this may well
become a significant factor in the future productivity of predatory
fish like cod.
15. Recommendation 4: a minimum 13%
reduction in the whitefish fleet beyond the 2003 decommissioning
scheme. However, the desired outcome of "right-sizing"
the fleet in terms of segment structure and size has not been
factored in. There is a general goal of a leaner, more sustainable
and profitable fleet but no consideration of whether this is to
be achieved through aspiring to a fleet comprising a few high
tech vessels or many small ones (although the issue of "killing
power" is invoked in #9.5.2). Arguably, decommissioning a
few of the large, modern whitefish vessels and allowing natural
attrition of the older ones would be a more effective and less
painful (in social and economic terms) "right-sizing"
strategy for fishing communities.
16. This recommendation further indicates
that the industry would benefit from tying up a further 30% of
the whitefish fleet for about four years, but that "this
should not be supported by public funds". However, no
realistic funding strategy is suggested instead (p 128), so in
practice such a tie-up is purely hypothetical.
17. Recommendation 5: the introduction
of individual tradable rights (ITQs). The rationale for ITQs
is inadequately explained and justified. With the exception of
the Netherlands, the countries visited by the Strategy Unit team
to study their ITQ systems have much simpler governance problems
than the UK's multi-national fisheries, so their suitability for
achieving the stated goals in the UK context are not proven, although
we accept the point that ITQs are best suited to relatively clean
fisheries (pelagic, Nephrops).
18. Recommendation 7: aim to achieve
Marine Stewardship Council certification for all major stocks
by 2015. The RSPB supports certification linked to consumer
choice as an aid to promoting sustainable fisheries. However,
the proposed certification would need to incorporate the sort
of goal-setting, adaptive approaches mooted in #8.3.4 to enable
an iterative approach of the many seriously degraded fisheries
in the UK and the Community towards Marine Stewardship Council
accreditation. Given the shared nature of many such stocks, this
would also need to be done in conjunction with EU partners.
19. Recommendation 11: explore introduction
of effort-based management for mixed fisheries. We have long
been supportive of this shift. It is generally much simpler to
manage a fishery by input controls (effort) than outputs (landings),
the latter being much more susceptible to generating discards,
black fish and misreporting. As noted on p 103, the introduction
of VMS (Vessel Monitoring System) greatly facilitates regulation
by effort control, and indeed may be regarded as a prerequisite
for it.
20. Recommendation 14: create a system
of UK Regional Fisheries Managers. The RSPB sees merit in
this proposal to mirror the shape of the emerging Regional Advisory
Councils (RACs).
21. Recommendation 15: reform inshore
fisheries management and ensure a role for recreational fishing
interests. The structure, governance and funding of inshore
fisheries management needs radical reform, and we will be responding
in detail to the separate Defra review on these issues, as we
have done to SEERAD's "Strategic Review of Inshore Fisheries"
in Scotland.
22. Recommendation 16: assist regional
and inshore management by forming a Stakeholder Advisory Group.
We support this recommendation in principle, although the more
decentralised the governance of UK fisheries becomes, the greater
will be the number of separate fora. This will pose genuine difficulties
of buy-in from stakeholders in terms of limited staff, time and
resources. Nevertheless, the RSPB (which is already a member of
the North Sea RAC) strongly supports progressively regionalising
the CFP's management functions (Recommendation 21), and
anticipates and welcomes collaboration between fisheries departments
and stakeholders (Recommendation 22), as well as synergy
elsewhere at EU level (Recommendation 24).
INTEGRATING FISHERIES
INTO THE
BROADER MARINE
ENVIRONMENT
23. We strongly endorse the case for root
and branch environmental integration in this sector. The report
acknowledges that "The fishing industry has a large negative
impact on the wider marine environment" (p 23) and identifies
as a "key challenge" for the industry; "providing
a clear framework for balancing the different uses of the marine
environment and preserving long-run ecosystem integrity"(p
24).
24. Recommendation 29: introduce Strategic
Environmental Assessments (SEAs) of inshore and offshore fisheries
by 2006, as the first stage for Environmental Management Systems.
[Also Recommendation 25—implement Sustainability Impact
Assessment of fisheries policy and practice at EU level] We
strongly support these recommendations. Implementation of both
SEAs and Environmental Impact Assessments (EIAs) (see below) in
fisheries would be a major contribution towards an ecosystem-based
approach to fisheries management. At present, responses to environmental
harm inflicted by fisheries are reactive, and place the burden
of proof on the "whistle-blower". This contrasts with
the proactive process in other industries, both marine and terrestrial,
already subject to SEA and EIA.
25. For Strategic Environmental Assessment,
there are admittedly challenges in identifying "plans and
programmes" in the case of fisheries, but these are not insurmountable.
SEA would be suitable for, eg, assessing the likely impacts of
closing a large area, or conversely opening a hitherto closed
area. As the text indicates, a key delivery mechanism and geographical
scale for SEAs could be the regional seas envisaged for RACs,
or sub-divisions of such areas.
26. Given that SEA is progressively being
undertaken in several marine industry sectors, it would make sense
to link these processes to generate common knowledge and understanding,
and to assist policy coherence and conflict resolution, notably
in spatial planning.
27. Recommendation 30: carry out EIAs prior
to the introduction of a new gear to a fishery or the start of
a new fishery. The RSPB is strongly committed to this proposal
and has long advocated its inclusion in the CFP. In this context,
it is important to define what is meant by a "new fishery".
It should mean a significantly new fishing practice in an existing
or new area or, in some cases, an existing fishery practice in
a new area.
28. Environmental Impact Assessment should
also be applied to existing fisheries in existing areas where
there is a presumption of likely damage but where this has not
previously been tested; an obvious candidate is the deepwater
fisheries to the north and west of Scotland.
29. Experience with RSPB/BirdLife projects
has demonstrated benefits of implementing linked SEA and EIA initiatives.
For example, SEA streamlines the EIA process and yields baseline
data which can reduce EIA costs. SEA can also filter out the most
damaging projects, removing the need for detailed, expensive and
controversial EIAs later on.
30. Recommendation 31: develop an experimental
programme of Marine Protected Areas focusing initially on areas
which provide benefits to multiple users. The RSPB welcomes
this, noting that Marine Protected Areas (MPAs) per se
are not a new concept. The UK is already signed up to this goal
in the wider context of the OSPAR Convention (Bremen Joint Ministerial
Statement 2003 commitment "to complete by 2010 a joint
network of well-managed marine protected areas that, together
with the Natura 2000 network, is ecologically coherent").
This is also in line with the Government's Marine Stewardship
initiative to protect and manage the marine environment better.
Lastly, the Review of Marine Nature Conservation (report to Government
26 July) recommended (Key R8) that "An ecologically coherent
and representative network of marine protected areas should be
identified and established, and appropriate and proportionate
measures applied to ensure their conservation needs are met".
This included a supporting recommendation to consider the scope
of legislation required to guarantee these ends.
31. While we can appreciate the desire to
prioritise areas which yield benefits to multiple users, high
priority in the context of this report should be placed on the
identification and piloting of "fishery No-Take Zones"
(NTZs) as a key component of the MPA concept. Seeking areas providing
multiple benefits should not be a sine qua non for additionally
seeking areas which strictly benefit only commercial fisheries.
32. The No-Take Zone tool, however, must
be used within a broader integrated management regime to avoid
issues such as displacement of fishing effort to sea areas outside
NTZs. Resolving this is likely to require policy coherence with
other EU Member States.
33. Recommendation 32: provide incentives
to improve environmental performance and encourage development
of less damaging gear. This is essential for implementing
an ecosystem-based approach. In pushing for this, the UK Government
is in tune with other EU Member States (notably Ireland and the
Netherlands). In June 2004, the Fisheries Council invited the
Commission to evaluate the potential for provision of financial
and non-financial incentives to encourage fishermen to move towards
more environmentally-friendly fishing methods.
34. The report (p 94) suggests various funding
options for generating payments to fishermen. The Commission's
new European Fisheries Fund (formerly FIFG) for the next
budgetary round (2007-13) has the in-built potential to facilitate
such incentives. The RSPB is currently commissioning a study to
identify opportunities for realigning EU fisheries funding in
this way, especially for the UK's inshore sector, where such incentives
would be particularly beneficial.
35. Recommendation 33: in the medium
to long-term, consider integrating fisheries management tasks
inside a marine environment agency, if such bodies are established
under other legislation (eg possible devolved Marine Acts).
The RSPB welcomes the commitment towards better integration of
fisheries management into wider stewardship of the marine environment
although the mechanism for achieving this needs wide debate.
36. Defra's concurrent Review of Marine
Fisheries and the Marine Environment in England and Wales (the
"Bradley report") has recommended the establishment
of a "marine management agency", apparently the same
as "marine environment agency".
37. The potential creation of a single marine
agency deserves close scrutiny, requiring detailed proposals from
Government to open up a constructive debate. The first issue to
consider is the best governance structure for delivering integrated
management, and whether better co-ordination between existing
agencies or a new marine agency would best achieve this. In evaluating
these options, a key issue will be whether adequate powers (of
environmental protection, enforcement etc) are vested in any new
agency. It is a second-order question whether the legal basis
for this should be a single Marine Act or coherence among separate
areas of legislation.
38. Other issues concern the ability of
such an agency to strike a balance between: fishing and other
sectoral users, resolution of cross-border devolved competence,
and the scientific and technical input required in support of
such an agency.
39. The Strategy Unit recommendation is
to "consider" establishing a single marine agency
in "the medium to long term". In our view the
UK no longer has the luxury of looking so far ahead to remedy
the increasingly dysfunctional state of marine use, with its growing
challenges of multiple sectors, conflicts of spatial planning
etc. Even if a single marine agency is seen as the ultimate solution,
as a contingency we need to adapt the existing structures and
functions now—in the short term—to address
these challenges properly and mitigate further attrition of the
fishing industry and the marine environment.
23 September 2004
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