Environment, Food and Rural Affairs CommitteeWritten evidence submitted by The Scottish Government

Executive Summary

The Scottish Government welcomes the Commission’s proposals on the Reform of the Common Fisheries Policy (CFP). The Scottish Government has been clear about the failure of the current CFP and the need for a radical reform.

Our priorities are to decentralise decision making and return more power to fishermen, to develop approaches that will eliminate discards and to protect Scotland’s fishing heritage for future generations.

We will continue to work with closely with many parties (including the UK Government) in order to develop our approach.


1. Scotland is one of Europe’s leading fishing nations responsible for Europe’s sixth largest fishing grounds, ranging across some of the EU’s richest waters, our fishermen land over 60% of the UK quota, and almost a tenth of the total EU marine fish catch. As such the Scottish Government has considerable experience of fisheries management to aid its thinking on reform of the CFP.


2. We agree that Commission has set the right priorities for reform and welcome the continuing focus on ensuring the future sustainability of fishing and aquaculture.


3. The Scottish Government is very concerned about the wasteful practice of discarding and has undertaken a number of steps to reduce it in the Scottish fleet. We are committed to ending discarding, however, we do not believe that a simple blanket ban with no further detail on how to reach discard free fisheries will be effective.

4. Discards exist for a number of reasons, including European legislation, and measures to eliminate them must be taken on a fishery by fishery basis, with the correct balance of incentives and regulatory support if a ban is to be practical and effective.

Social and Economic Viability

5. The Scottish Government is concerned that certain of the proposals, most importantly Transferable Fishing Concessions, threaten to undermine the social and economic viability of the Scottish fleet.

Overcapacity and Transferable Fishing Concessions (TFCs)

6. This a complex issue without a single “right” answer and will change depending on the size of the vessels, the number of trips you expect them to take, what gear they will be using, whether these vessels can switch between different fisheries, the price of fuel and a host of other variables.

7. However, it is clear that TFCs are not meant to answer these questions, but instead are explicitly designed to shrink the EU fishing fleet irrespective of the sacrifices already made. Several key Scottish ports are already at their minimal level of activity and the loss of more vessels from the fleet will fatally impair their viability and the viability of the associated industries.

8. If TFCs are introduced in their current form the rapid consolidation they would induce would undermine the current structure of the Scottish industry with a devastating effect on Scotland’s fishing communities. The Scottish Government strongly resists the mandatory introduction of TFCs.


9. Current fisheries management is characterised by very centralised decision making, down to the smallest details, and gives Member states no room to manage their fisheries.

10. The current proposals suggest that they will reverse this process, but on a close reading of the text it is not clear this is the case, with a large number of decisions being made by the Commission under its “delegated powers”. It is of great concern that the Commission has been unable to provide a non-paper detailing how the proposed system of regionalisation is to work.

11. The Scottish Government strongly believes that genuine decentralisation of decision making is required if this reform of the CFP is to be judged a success.

Science and the Ecosystem Approach

12. We welcome the Commission’s commitment to a science led approach towards fisheries management. However, we are concerned that not all the data the Commission currently requests is collected. We would prefer to see this situation remedied before placing a greater burdens on Member States, particularly as no further support from the Commission is being offered.

Other Priorities

13. Aquaculture will remain a significant priority for the Scottish Government. Currently our aquaculture sector is thriving and we would wish to see this continuing without the development of the same oppressive micro-management from Brussels that has failed wild fisheries management.

14. We will also seeking greater clarity of how interactions between the CFP, Natura 2000 and the Marine Strategy Framework Directive, the Habitats Directive and the Birds Directive will work. We are clear that we do not wish to see the CFP subordinated to other EU policies, however, as the Commission has responsibility for all of these policies, we think it is correct that the Commission should outline how they will interact rather than leave it to Member States.

15. We support the Commission’s intentions to improve international fisheries governance, particularly in waters beyond 200 miles.

Scottish Government Actions

16. We will continue to work with the UK Government and other interested parties, including the Commission, the European Parliament and other Member States to develop our objectives. Within Scotland a Scottish Government/Industry/NGO group has been formed to give advice during the CFP reform process.

17. Additionally the Scottish Government will continue developing its pioneering approach to fisheries management. An approach that has delivered many innovations like Real Time Closures, ever more selective gears, a ban on high grading and slipping as well as our “catch quota” scheme which saw the first use of CCTV on fishing vessels in the UK.

October 2011

Prepared 23rd February 2012