Fisheries Bill

Written evidence submitted by Daniel Whittle (Managing Director) Whitby Seafoods Ltd and Kilkeel Seafoods Ltd (FISH08)

Public Bill Committee Written Evidence: Fisheries Bill

Background to Whitby Seafoods:

We are the worlds largest processor of scampi, selling over a million portions per week.

We buy approximately 1/3 (by live weight, approximately 12000t/annum, equating to £23m/annum) of the UK catch of Nephrops Norvegicus (AKA Langoustine, Dublin Bay Prawns, scampi tails).

We sell almost entirely to UK foodservice (wholesalers, pubs, restaurants) and retail, in both brand and own label.

Given most UK caught fish is exported, and UK consumed fish is imported, we see scampi as a truly British seafood classic, that appeals to young or old and rich or poor.

A lot of our supply comes from the West Coast of Scotland and Northern Ireland, hence our site based in Kilkeel, Co. Down, and particular interest in that area.

We employ over 350 people in our two sites, receiving supply from over 200 boats (we have no ownership of boats).

As a family owned and family run business, we are focused on the long term sustainability of the industry, and those who work within it.

Executive summary:

· There are many potentially sensible pieces of legislation within the bill.

· The bill makes clear the type of new powers available to both UK and devolved governments, but the practicality, efficacy and desirability is dependent on how those powers are used .

· There is insufficient detail on the amendments to licensing to establish whether it resolves particularly acute problems within the industry currently.

· Currently there is a lot of excitement in the fishing industry around new fishing opportunities, but as it sits now, large proportions of the current catch opportunity to goes uncaught due to problems within the industry. Unless there is support to address these issues, its going to be very difficult to maximize the opportunity.

1) Funding:

Funding of MMO and DAERA through fishing, could make sense, if it was associated with payment for new fishing opportunities (e.g. new licenses or quota), but as an additional fee across all landings, this would represent an additional cost that many part of the industry can ill afford.

2) Multiple effort controls

Thought should be given to trying to create an effort control system that is a simple as possible, as it minimizes the risk of unintended consequences, and has the benefit of making it easier for fishermen to comply (complicated rules are harder to adhere to – this is currently evident in prosecution for failure to adhere to technical measures around gear, where often its a case of ignorance of the law rather than genuine intent to break the law).

As the proposal sits now, government could implement three effort controls, namely days at sea, quota and licensing. This would be a significant barrier to efficient use of resource.

3) Licenses

I am hopeful that the devolvement of licensing powers will lead to an improvement in our ill-fitting licensing system. Currently the very high price of licenses acts a significant barrier to new entrants. It also means that money that could be invested in efficiency (leading to lower carbon output, cost and increased profitability) is spent on an arbitrary control measure that has no real actual value. It is also important that nephrops licensing become separated from demersal licensing, as more often than not the two fisheries are unrelated.

Introducing new low cost licenses could lead to significant losses to those who have invested in them recently. Perhaps there could be compensation for this in form of credits in the new licensing system, or share in new quota availability.

4) Maximizing our utilisation of quota:

To the end of November 2018, the nephrops quota is 52% caught (in 2016 it was 76% caught). This species is normally the UKs 3rd most valuable species. Effort has declined on this, not because its an unprofitable fishery. It due to increased opportunity to catch non-quota species (notably squid and cuttlefish), increased whitefish opportunity (particularly in the North Sea) and fixed income from offshore work (guard duty for offshore windfarms and cabling). All this represents high reward for lower levels of effort. This means that significant parts of the current fishing infrastructure is focused on activity unrelated to quota species fishing. My fear is that with an uncontrolled introduction of new fishing opportunity, with no comparable increase in capacity, some areas of the industry will bloom, and others will die, and the total value of fish landed decreases. Fishing effort/capacity needs to be increased before new opportunity is available, or the consequences for large parts of the shore based industry could be dire.

5) Quota for new entrants

If we have the opportunity to address how quota is allocated, we should prioritize making this public resource publicly available. Dedicating increased amounts of this public resource to those who happened to fish in certain areas last century, or have had capital available at the right times in history, is effectively intergenerational bias. Why can current and future generations not be given the same opportunities as those from previous generations? If you go back 30 years, buying a boat, license and quota was something a member of the public with a small amount of capital could do. Nowadays this would be virtually impossible. If new quota could be rented rather than owned, it makes it a level playing field. If licenses were more like a driving license (i.e. the right is removed for poor behaviour, rather than an additional effort control beyond quota and days), we might find our fishing industry is much more sustainable in the long run.

6) Charging

Without detail on how charging is going be implemented, it is not possible to comment on its suitability. For example, if the principle of the charge for landing fish outside of quota is inline with the market value (i.e. there is no benefit to the fisherman to land fish they have no quota for), then the charging concept is sensible. However, if a fishermen does his best avoid catching fish he has no quota for, and lands it because he is legally bound to do so, and is then charged a disproportionate fine for doing so, its no better than the current legislation (i.e. its unworkable and will lead to illegal discarding).

December 2018


Prepared 6th December 2018