11.When the UK leaves the EU and the Common Fisheries Policy, it will become an independent coastal state responsible for managing the marine resources within its Exclusive Economic Zone (EEZ). The UK will leave the EU on 29 March 2019. It has been agreed in principle that a 21-month implementation period will follow before a new EU-UK relationship takes effect from 1 January 2021. It is expected that the Common Fisheries Policy will continue to apply to the UK during this implementation period. The UK Government has set out its vision for post-Brexit fisheries policy in its Fisheries White Paper. Proposals for continued trade in fisheries products are set out in the UK Government’s ‘Future Relationship’ paper, and arrangements for the implementation period are contained in the Draft Withdrawal Agreement.
12.In this Chapter, we will examine the UK Government’s priorities for the future UK-EU relationship, in terms of access to fishing opportunity and trade, and consider how it can secure the best Brexit deal for the Northern Ireland fishing industry. We then look at the possibility of a no deal scenario and what must be done to prepare for this scenario. Finally, we examine problems which might arise during the implementation period, and consider how these can be addressed.
13.A central feature of the debate around the implications of Brexit for the fishing sector is that withdrawal from the EU will enable the UK to manage access to fish in its territorial waters. Many fishermen we spoke to described the UK’s current allocation of fishing opportunity under the CFP as unfair. Alan McCulla, CEO of ANIFPO, told us that 92% of fishermen voted to leave the EU because they do not believe the CFP delivers respect, equality or fairness for their industry.
14.Under the CFP, all EU registered fishing vessels have equal access to the waters that form part of the EU’s EEZ, made up of the amalgamated EEZs of all the 28 Member States (see Figure 2). The principle of relative stability, based on historical fishing patterns during 1973–1978, sets the fixed amount of fishing opportunity available to each Member State. At an annual Fisheries Council, the European Commission proposes a Total Allowable Catch (TAC) for each species of fish, divided where necessary between regions and sub-regions, which is then shared between EU countries in the form of national quotas. Each Member State can decide how its share of the fishing opportunities (TAC) are allocated domestically between vessels flying its flag (see Chapter 3).
15.TACs are determined on the basis of scientific advice about sustainable stock levels and aim to set catch limits which respect the principle of MSY. Although the TAC for a species may change annually due to evolving scientific advice, the percentage share a Member State receives for each stock is fixed under relative stability. In practice, the fishing rights of an individual vessel are determined by the fishing quota it holds. The quota grants access for the vessel to catch a limited quantity of a specific fish stock, within a specified area of sea. These quota allocations can be sold and traded between POs and individual vessels.
16.In 2015, the total EU quota for 73 different fish stocks living in UK waters was 1,920,915 tonnes, of which 585,211 tonnes (30%) was allocated to the UK. During the period 2012–2016, vessels registered in other EU Member States caught fish worth on average £540 million annually in UK waters. UK vessels landed fish worth approximately £110 million from other Member States waters, per year, in the same period. Alan McCulla described how Ireland’s quota for key species in the UK EEZ compares to that of Northern Ireland vessels in Irish waters:
Ireland takes something like 52% of its cod catch from UK waters. Nephrops, langoustines, Dublin Bay prawns, whatever you want to call them, are the most economically important catch to fishermen in Northern Ireland. I believe that Ireland catches something like 40% of its entire catch of langoustines from UK waters. In terms of Northern Ireland, in terms of volume and value we take around 17% of our catch from Irish waters.
17.In 2015, 32% of the total value of fish landed by the Irish fleet, comprising 77,000 tonnes worth approximately 87 million euros, came from the UK’s EEZ. However, during this period the value of fish landed in the UK EEZ by the Netherlands, Denmark and France was almost double this. Harry Wick, CEO of NIFPO, told us:
France and Spain combined claim a total of 25% of our nephrops. Brussels, which is 500 miles away from Belfast, is claiming a share of the haddock caught five miles off the Belfast coast. It is not just Ireland that is the problem.
Similarly, Northern Ireland fishermen Jimmy Kelly said:
If you look at the radar it is Portuguese, Spanish, Faroes, Norwegian in our waters taking our fish. If you go around Donegal and speak to the Killybegs, they are tied up with no quota but yet the Dutch and the Portuguese are fishing 12 miles off the shore. Something needs to change.
18.The Government’s Fisheries White Paper addresses some of these concerns, describing the model used to calculate the UK share of fish, relative stability, as “outdated.” The White Paper argues that it does not “accurately reflect the resources in UK waters”. From 1973–78, the period when relative stability was initially calculated from vessel catch data, the UK fishing fleet concentrated much of its effort on fishing in the waters around Iceland. In 1977, UK vessels were expelled from Icelandic waters when fisheries limits were extended to 200 nautical miles but were unable to expel fishermen from other EU states from UK waters.
19.On leaving the EU, the UK will become an independent coastal state, responsible under international law for managing the marine resources within its territorial waters. The White Paper states:
As an independent coastal state for the first time in over 40 years, access to UK waters will be on our terms, under our control and for the benefit of UK fishermen.
20.International agreements, such as the 1982 United Nations Convention on the Law of the Sea (UNCLOS) and the 1992 United Nations Fish Stock Agreement (UNFSA), set out the rights and responsibilities of coastal states for fish stocks within their Exclusive Economic Zone (EEZ). UNCLOS grants coastal states sovereign rights for “exploiting, conserving and managing” their natural resources and enables states to decide how fish stocks may be harvested, and by whom, within their EEZ.
Figure 3: Map of the UK EEZ (highlighted in blue)
Source Institute for Government briefing on the Common Fisheries Policy
The UK will be responsible for determining the Total Allowable Catch (TAC) of the fisheries resources within its EEZ, making use of the best scientific advice available, and ensuring fish stocks can produce Maximum Sustainable Yield (MSY). For shared fish stocks, which occur in the EEZ of two or more coastal states, UNCLOS places an obligation on these coastal states to agree coordinated conservation measures. UNFSA builds on this obligation by providing a framework for cooperation between coastal states for the conservation of shared and highly migratory stocks. The Government acknowledges that “virtually all stocks fished by the UK” are highly migratory species whose conservation and management will require cooperation with other coastal states.
21.UNCLOS also requires coastal states to provide access for other states to any surplus TAC—fish stocks a state does not have the capacity to harvest. When granting access to surplus, a coastal state is required to take into account minimising economic dislocation to states whose nationals have habitually fished in the area. Richard Barnes, Professor of International Law, University of Hull, told us that under UNCLOS other states have “no right to access waters to fish for anything other than a surplus”, and any access to fish is determined through agreement. He added:
The reference to habitual fishing might entitle those states with long standing fishing interests to make a stronger claim to any surplus, but this is only a claim weighed vis a vis any other state seeking access. It is not support of a claim of access per se.
22.The Government’s White Paper reflects this position, stating that, as an independent coastal state, the “UK will have control over access to its waters” and any decisions about giving access to vessels from the EU, or any other coastal states, “will be a matter for negotiation.” Similarly, the European Commission has acknowledged that the consequences of UK withdrawal will be “full control over territorial waters” and a “duty to cooperate on shared stock management”.
23.At the end of the implementation period at the latest, the UK will be able to negotiate fishing opportunity as an independent coastal state and control access by foreign vessels to its territorial waters. Fishermen in Northern Ireland were clear that they hoped Brexit will mean increased quota for the Northern Ireland fleet. Andrew Orr, a Northern Ireland fisherman, told us:
We would like to bring more fish back to our factories and we would like to build the whole industry back up to what it used to be. [ … ] A great opportunity if properly managed and I would say the general opinion about the British Isles as a whole, both north and south, is all quota brought back into the pot.
Harry Wick, CEO of NIFPO, told us that Northern Ireland got a “grossly unfair” deal when the CFP was originally negotiated. He said it was their “heartfelt desire that the balance is redressed in these negotiations and we do not make the same mistake twice”.
24.The Government’s White Paper states that increased fishing quota will be secured through a process of “annual exchanges” with the EU and other coastal states, including Norway and the Faroe Islands. George Eustice MP, Minister of State for Agriculture, Fisheries and Food, described the three key variables for fisheries negotiations:
After Brexit, the UK will determine the TAC for fish in the UK EEZ on the basis of scientific advice provided by domestic fisheries bodies such as the Centre for Environment, Fisheries and Aquaculture Science (CEFAS), in collaboration with ICES. The sections below examine the Government’s proposals for determining quota share and access to UK waters after Brexit.
25.The UK Government has indicated that it wants to replace relative stability with zonal attachment. Minister Eustice told the Environment, Food and Rural Affairs Committee that, while relative stability would be the “starting point” in December 2020, “zonal attachment is the objective”. Zonal attachment is a different method of allocating quota which is based on an assessment of the extent to which a fish stock resides within a country’s EEZ. There is no single agreed definition of how zonal attachment should be measured but a version of zonal attachment is used to determine quota share for 6 key stocks in the EU-Norway fisheries agreement. The White Paper presents preliminary research on zonal attachment using the following data to evaluate whether a fish stock resides in the UK EEZ:
This data is used to draw comparisons between the UK’s 2018 quota share under relative stability and the zonal attachment measures. For example:
Figure 4: The zonal attachment measure for Celtic Sea Cod
Zonal Attachment Measures
26.In January 2017, the University of Aberdeen published a paper that modelled how zonal attachment might change quota shares for fish stocks in the North Sea and West of Scotland. It concluded that “for most stocks the percentage TAC allocated to the UK is much lower than the estimated average percentage of the spatial distribution in the UK”. The study found two stocks where the UK’s TAC allocation is in excess of spatial distribution (North Sea anglerfish and Rockall haddock), three stocks where the UK’s TAC allocation is in line with spatial distribution (North Sea and West of Scotland Haddock and Mackerel) but, for all other stocks assessed, the UK’s current TAC was “less than minimum estimates of spatial distribution”.
27.The Committee heard that for the main species landed into Northern Ireland, over 80% by value and volume is captured within the UK EEZ. Whilst vessels from Northern Ireland can, and do—providing they have quota to do so—fish further afield, the greatest concentration of current effort is in the Irish Sea, West of Scotland and North Sea. The POs highlighted that although around 70% of the Irish Sea is within UK waters, the UK’s share of many of the key demersal TAC (species such as cod and haddock) is less than 50%. The Government has committed to publish further data on the zonal attachment measure for fish stocks in UK waters later in the year. Minister Eustice has also set out his expectations for the pace of change from relative stability:
We will not get there overnight. We have been clear about that, but we want to see year-on-year gains from the moment we negotiate as an independent coastal state. In some stocks, it may be possible to get faster progress than in others, depending on what we agree.
It is not clear from this how the Government’s apparently cautious, gradual and negotiated intended move towards zonal attachment will change the quota allocation for Great Britain or Northern Ireland after December 2020 or how long it will take to reach steady state.
28.The National Federation of Fishermen’s Organisations (NFFO) has said that the White Paper “aligns quite closely with what the fishing industry wants and expects.” However, the New Economics Foundation highlighted that the White Paper is peppered with terms like ‘seek to’, ‘intend to’ and ‘will consider’, which suggest that policy change is “conditional on certain Brexit outcomes” in the negotiations. It is notable that in an earlier version of the White Paper, leaked to Politico, the Government’s stated aim for quota shares was simply described as “to update relative stability”.
29.The White Paper states clearly that any decisions about giving vessels from the EU, or any other coastal states, access to UK waters will be a matter for negotiation. However, there is no detail on the criteria that will be used to determine access or the extent to which access will change after Brexit. On this point, the fisheries Minister said:
What we cannot say is that we will have an exclusion zone and that no-one can come into our waters. There will be a sense of saying that we will grant some access, but it might not be the same sort of access that they are used to [ … ] There may be some trading of access in order to get a fairer share, for instance.
The Prime Minister has indicated that the Government will ensure “we don’t see our fishermen unfairly denied access to other waters” as a consequence of taking back control of UK waters. For example, the UK currently benefits from access to Norwegian waters to fish for arctic cod in exchange for granting Norway access to blue whiting in the UK EEZ. Access agreements such as this often require the balancing of differing interests within the UK fleet. In this example, the English fleet tends to benefit from access to arctic cod while the Scottish fleet loses access to blue whiting.
30.Material published by the European Commission shows that securing “continued reciprocal access to waters, resources and markets” is a key priority for the EU. Donald Tusk, European Council President, has explicitly linked tariff-free access to the single market with maintaining existing access for EU boats in UK waters. The European Council’s draft negotiating guidelines for a future trade deal state:
Trade in goods, with the aim of covering all sectors, which should be subject to zero tariffs and no quantitative restrictions with appropriate accompanying rules of origin. In the overall context of the FTA (free trade agreement), existing reciprocal access to fishing waters and resources should be maintained.
George Eustice has said that the UK is “equally explicit that this is unacceptable and we want to move to a zonal attachment methodology”. The NFFO describe the EU’s attempts to make market access conditional on fisheries access as a “nuclear option” to which the UK government must not capitulate. We discuss trade aspects in greater detail in the next section.
31.The Committee supports the Government’s commitment to move away from the current inequitable allocation of fishing opportunity under relative stability and welcomes its publication of evidence in support of the zonal attachment measure. However, the White Paper does not say whether the Government intends to negotiate quota increases in line with these projections. Nor does it set out the criteria on which the UK will determine access for foreign vessels to UK waters after Brexit. We recommend that the Government clarify, in its response to this report, how it intends to exercise its rights under international law to secure a significant redistribution of fishing opportunity in UK waters. We further recommend that the Government sets out its projections for how quota allocation based on zonal attachment will differ from that of relative stability for the Northern Ireland fleet and the criteria that will be used to permit access by foreign vessels to fishing opportunity in UK waters after Brexit.
32.The future EU-UK trading relationship is important for the fishing industry because the UK exports a large proportion of the fish it catches to the EU and imports the majority of what is consumed domestically. Under current arrangements, there are no tariffs on intra-EU trade in fish or fish products. The UK’s membership of the single market also means that the level of non-tariff, or ‘regulatory barriers’, to trade is “very low”. Non-tariff barriers can restrict trade by requiring exported products to meet certain conditions such as; the requirement to provide proof of origin, the imposition of quotas to limit the amount which can be sold in a market or restrictions on how a product is marketed.
33.During 2014–2016, Northern Ireland exported on average £45 million worth of fish while importing £16.9 million, creating a trade surplus of £28 million. Trade with the EU made up 94% of Northern Ireland’s international fish exports and 82% of its international fish imports during this period. The domestic market is also crucial for the Northern Ireland fleet, with NI and GB representing the market for over 60% of the fish landed by the NI fleet. The latest figures available for 2016 show that the NI fishing industry had a turnover of £79.7 million of which:
34.It is important to note that the Northern Ireland fleet also lands fish into ports outside the UK. In 2016, the Northern Ireland fleet landed fish worth £5.1 million into ports in Ireland, in addition to the £28 million exported from Northern Ireland, creating a total of £33.1 million in 2016. Alan McCulla told us that the catch landed into Ireland is mostly “mackerel and herring” which is brought to Killybegs for processing. He said:
We do not want to lose those markets, but neither do the processors in Killybegs want to lose that fish. It becomes an important component of their industry that is, further down the supply chain, classified as an Irish export, when in fact it was fish caught by UK fishermen.
35.Harry Wick underlined the importance of Great Britain as a market for NI fish, and told us that disruption to trade between Northern Ireland and Great Britain had the potential to “cripple” the industry:
A lot has been said about the north-south border and the threat that might pose, but in actual fact, the main threat is an east-west border. If we look at the numbers, £47 million of our product goes directly to the UK; £6 million of our product crosses the north-south border. In my opinion, it is imperative that we safeguard the larger proportion of that money.
36.The Government’s ‘Future Relationship’ paper proposes that the UK and EU establish a free trade area for goods which would eliminate tariffs, prevent customs or regulatory checks at the border and apply a “common rule book” for agriculture, food and fisheries products. Donald Tusk has proposed “a trade agreement covering all sectors” with “zero tariffs on goods.” However, this offer was explicitly linked to the UK maintaining existing access for EU vessels in UK waters. Richard Barnes, Professor of International Law at the University of Hull, told us that the EU “will maintain pressure” on the UK to permit access to UK waters for the EU fleet as part of a wider deal on access to EU markets. Similarly, Dr Appleby, Associate Professor at the University of the West of England, described negotiations on access to fish as an “entirely political question”. He told us:
It depends on the relative bargaining strengths of both parties and the good will between them. The EU negotiators have made it plain that access for EU vessels to UK waters is required for access to the EU market, but it is equally possible that access to UK waters will be negotiated for anything from the EU data market to its space programme. It is important to recognise that the UK did not vote to leave the CFP (where it has theoretical advantages in negotiations) but the whole of the EU (where those advantages are not as clear).
37.Conversely, the Government has repeatedly argued that access to the single market and access to fishing opportunity in the UK EEZ are separate and distinct matters. George Eustice said:
You will be aware that the EU has said only one thing on fisheries so far. There have not been detailed discussions on fisheries to date. They have made a very simple statement: that they would like to link a trade deal with access to fishing. That is a position we disagree with, and we have been absolutely explicit that we disagree with it in the White Paper.
Negotiations between the EU and UK are ongoing and consequently it remains unclear how the UK’s trade in fisheries products with the EU will change after Brexit. Here we consider how the imposition of tariffs and increases in regulatory trade barriers could affect the Northern Ireland industry.
38.The level of tariffs that will be applied to fish products will depend on the outcome of the EU-UK negotiation on future trade relations. The EU currently operates a variety of different tariff models for trade in fisheries products with other countries:
In assessing the impact of different Brexit scenarios for the NI fishing fleet, the value of any redistribution of quota share for UK fishermen should be balanced against the cost implications of tariffs and regulatory barriers to trade.
39.Trade with the EU is significant for the fisheries sector in Northern Ireland. In 2016, Northern Ireland exported fish worth £33.1 million to the EU and imported £13.8 million from the EU. Despite having a reduced tariff rate, Norway—which has the closest trade relationship with the EU for fish products—still pays tariffs on 70% of fish sent to the EU market, totalling 1 billion Norwegian kroner (£91.5 million) a year. Northern Ireland’s POs told us they want “the freest possible trade with Europe” and that the imposition of tariffs could carry “significant consequences” for the industry. They said:
The Government should seek the trade arrangements with the lowest tariff barriers and impediments to trade possible: but not at the cost of undermining the UK’s standing as an independent coastal state.
40.It is also notable that many shellfish species are not subject to EU quotas and so fishermen who target this catch could face losing income as a result of the imposition of tariffs whilst gaining no benefit from increased quotas. In 2016, non-quota species such as crab and scallops represented 21% of the total value of fish landed by the NI fleet. While there has not been a specific assessment of the impact of different outcomes on the NI fishing sector, a study which modelled different Brexit outcomes, commissioned by Marine Scotland, found that:
Fleet sectors targeting non-quota species (crab and scallop) and the salmon aquaculture industry, which do not stand to gain from zonal attachment quota increases, suffer the negative impacts of higher tariffs and NTMs [non-tariff measures] without the benefits of an increase in production. Therefore, they experience a contraction in output value with the imposition of EU-Norway type tariffs (and non-tariff measures), and a greater contraction with MFN [most-favoured nation - WTO] tariffs and non-tariff measures.
The New Economics Foundation noted:
Tariffs would impact every fleet segment, as the majority of UK fish is exported (76%) and the majority of that is destined for the EU (75%). For fishers holding quota, quota gains can offset the application of tariffs in terms of overall economic performance, but not for those fishers–including the majority of the small-scale fleet–who do not hold quota.
41.Finally, a no deal scenario would mean that the UK is no longer bound by the CFP and that UK-EU trade would be subject to World Trade Organisation (WTO) rules. Harry Wick told us that “while no deal is not a disastrous situation, having a good deal is much, much better”. Figure 5 (below) shows the EU’s tariff rates for trade in fish and fisheries products with countries who do not have a preferential trade agreement (full tariff under World Trade Organisation MFN rules).
Figure 5: EU tariff rates by fish species under WTO
Source: UK Trade Policy Observatory, Fishing in Deep Waters, 21 July 2018
The UK Trade Policy Observatory, an independent expert group, modelled possible economic outcomes for the UK fishing industry under different deal and no deal scenarios. The study claimed that the imposition of WTO tariffs would have “non-negligible effects” for UK exports and that “a no deal Brexit leads to the biggest negative impacts” for UK exports. With regards to the redistribution of quota share, it highlighted that implementing a zonal attachment measure could have a substantial impact on the EU fishing industry which might see its exports reduce by 13%. It concluded:
If the UK chooses to act unilaterally, it would almost certainly lead to EU retaliation of some sort, either within fisheries or in other policy areas such as trade or market access. The potential gains for the UK are substantial, but there is a need to balance the gains and the potential impacts across the different parts of the industry and it will need to be mindful of the implications not just for fishing and fisheries, but also the UK’s broader relations with the EU.
Professor Barnes told us:
In terms of a no deal, the biggest impact would be access to markets. We are potentially looking at the imposition of customs duties, which depend on the particular species. We have mentioned prawn, at a tariff of about 16% or 18%. [ … ] There is a degree to which the fishing industry could absorb the costs of that. There is a high demand for fish products, which may result in the increase in costs being defrayed across the industry as a whole. They may be able to withstand that in the larger sectors of the economy, rather than the smaller-scale processors. That is potentially a problem for Northern Ireland, where the processing is very small and most of the businesses are under 25 (employees). You have cash flow issues there. If you then start to generate increased costs without being able to adapt, you are at risk of going under. The larger operators are better able to deal with that.
42.The EU also enforces a range of regulatory and administrative controls on the import of fish from non-member states which, depending on the terms of the UK-EU relationship, could apply to UK fisheries exports after Brexit. Regulatory controls could include:
43.Euan Beaton, President of MacDuff Shellfish, a large shellfish processing business, explained how non-tariff barriers could affect trade:
When I started the business with my mum and dad, we were a very small business, we needed a health certificate with every consignment we dispatched. We had to run all over the county trying to get this piece of paper and get the vet to sign and stamp it. It was really difficult. God forbid that we go back to that set of circumstances again. We also do not want to be holding fresh fish up in Calais or Dover.
Jimmy Kelly told us:
My whelks go to the Republic. We will need a vet’s certificate to get them across the border because they are shellfish. It is the same with certain other types of shellfish. We are going to have to take that pain on the chin, but if the Government support us, allow the quota and start reinvesting in their industry.
44.Dr Lynn Gilmore, Northern Ireland Manager at Sea Fish, a non-departmental public body set up to improve efficiency and raise standards in the fisheries industry, also raised concerns about delays at the border:
Non-financial tariffs are a great fear of the industry, because with seafood you are dealing with a fresh product. It is in even sharper focus when you look at the aquaculture and eels sectors, which in many cases are exporting a live product. Any friction at borders is a huge concern to the industry, both in terms of the additional cost and access to market, and in terms of the ruination of stocks through hold-ups at borders.
Andrew Kuyk, Director General of the UK Seafood Industry Alliance, highlighted the importance of goodwill in the future EU-UK relationship to help solve these potential problems:
There is port health, border inspection posts. Again, at the moment, for intra-EU trade those are not necessary, but if we become a third country we may need to have those. The point you made, Chair, is that it is not just what the rules say on paper; it is the spirit in which they are implemented and enforced. If there is mutual co-operation, that is quite different. If people are going to insist on a much higher level of physical checking, or if the stamp is in the wrong place.
45.The Government’s ‘Future Relationship’ paper proposes a common rule book for agriculture, food and fisheries products which covers “only those rules necessary to provide for frictionless trade at the border”. To obviate the need for checks, under the common rule book the UK would “make an upfront choice to commit by treaty to ongoing harmonisation with the relevant EU rules”. However, it is not clear from the paper which of the many EU rules which govern trade in fish and fish products will be within the remit of the common rule book. For wider food policy questions, such as marketing and labelling, the paper states:
It is not necessary to check these rules are met at the border, because they do not govern the way in which products are produced, but instead determine how they are presented to consumers. These rules are most effectively enforced on the market, and as such it is not necessary to incorporate them into the common rulebook. [ … ] For these rules, there are existing precedents of equivalence agreements covering testing and approval procedures. For example, the EU has reciprocal equivalence arrangements or agreements for organic production rules and control systems with a number of countries: Canada, Chile, Israel, Japan, the Republic of Korea, Tunisia, the US and New Zealand.
The EU has yet to make a formal response to the UK’s ‘future relationship’ proposals. However, EU chief negotiator Michel Barnier has questioned the idea that a common rule book, under which the UK only aligns with those standards that are checked at the border, provides a basis for allowing for free movement of goods.
46.The UK and EU have also agreed that, if it is not possible through the wider UK-EU deal, a “backstop arrangement” will be put in place to protect North-South cooperation and avoid a hard border between Ireland and Northern Ireland. The EU has suggested that this would require “a common regulatory area,” comprising the EU and Northern Ireland, in which the EU rules for health, safety, production and marketing would apply to Northern Ireland fisheries. The UK has not accepted the EU’s proposals for a backstop, and has instead suggested a temporary customs arrangement. The UK’s proposal does not address regulatory standards. The UK Government has been clear that its preferred option is for trade on the island of Ireland to be covered by the wider UK-EU trade deal.
47.The EU is an important export market for the Northern Ireland fishing sector. Negotiating a good deal for the Northern Ireland fishing industry is therefore not just about attaining increased quota but also securing continued access for Norther Ireland’s fisheries products to EU markets. Any future agreement with the EU should secure reciprocal tariff-free trade in fish and fisheries products, mutual recognition of standards, and a streamlined export process for perishable fisheries goods. The consequences of high tariffs will be particularly acute for those fishermen in Northern Ireland who catch non-quota shellfish species. These fishermen stand to incur the costs associated with increased tariff and non-tariff barriers without gaining the benefits of renegotiated quota. We recommend the Government set out, in its response to this report, which rules pertaining to fisheries trade would be included within the common rulebook.
48.In a no deal scenario, in which trade in fisheries products is subject to the EU’s common external tariff, the gains implied by the exclusion of EU fishermen from the UK’s EEZ would be offset to an extent that is both unclear and uneven across the sector.
49.As set out in paragraphs 32–48, the best outcome for the Northern Ireland fishing industry would be for the Government to secure a deal with the EU that prevents the imposition of tariffs and costly administrative barriers to trade. However, recent statements made by political leaders in the UK and the EU demonstrate that no deal remains a possible outcome of the UK’s negotiations with the EU. On 12 July 2018, Secretary of State for Exiting the EU Dominic Raab said that in the Government’s view “no deal would be better than a bad deal” although the Government is aiming for the “very best deal”. He also confirmed that the Government had decided to “step up” its planning for a no deal scenario. In a similar speech on the 11 July 2018, EU chief negotiator Michel Barnier told businesses that they should “prepare for the worst-case scenario of a no deal which would result in tariffs under WTO rules”.
50.Minister Eustice set out three possible outcomes from the ongoing Brexit negotiations:
The scenario we are aiming for, obviously, is that we get a withdrawal agreement and heads of terms on a future economic partnership by the autumn, which Parliament can then endorse, and everyone is happy. One variation on that might be that people would agree the withdrawal agreement, but that a future economic partnership remains elusive, and therefore there is a transition period but then something akin to no-deal Brexit at the end of that. The third option would be that there is no deal at all, so there is not even an agreement on the withdrawal agreement, and in that situation, yes, we would need to have all the powers in place in a fisheries Bill by the end of March next year.
51.The European Union (Withdrawal) Act 2018 converts around 100 pieces of EU legislation, which make up the CFP, into “retained EU law” on the domestic statute book. Over time, the Government intends to replace retained EU law with domestic legislation such as the fisheries Bill. George Eustice said that the fisheries Bill will be introduced “towards the end of this year” but acknowledged that if there is no implementation period “we would obviously have to advance it”. In the event of no deal, an expedited fisheries Bill would need to take effect from 30 March 2019. However, as discussed in paragraphs 24–31, the Government’s White Paper on the fisheries Bill contains little detail on how the UK intends to control access for foreign boats in UK waters or how quota share will be redistributed. When we asked the Minister about contingency planning for no deal, he told us:
We have had the MMO working on issues such as enforcement, and working out what day one capacity would need to be in such a scenario. It has done a lot of work around what additional capacity it might need to process more catch certificates for our exports. It has also done work on other IT systems and other resourcing that we would need to consider.
52.We consider below the steps the Government must take to prepare the industry for a no-deal scenario, should it prove unavoidable.
53.As a non-member state, the UK will be required to provide catch certificates in order to trade fisheries products with the EU. Any country wishing to trade with the EU must have its fisheries management system approved by the EU and any fish imported into the EU must be accompanied by a catch certificate. A catch certificate is a document which certifies that a fish has been caught legally and is being sold in accordance with applicable laws, regulations and international conservation measures. We heard that currently the UK has to produce relatively few catch certificates as the majority of its export trade is with the EU.
54.In the event of a no deal Brexit, the UK would have to dramatically increase production of catch certificates to cover all fisheries imports and exports with the EU. In 2016, the UK exported £1.17 billion of seafood to the EU and imported £1.04 billion from the EU. The Department for Agriculture, Environment and Rural Affairs (DAERA) told us:
There will also be the need to process more import catch certificates. This will be a significant issue for Northern Ireland given that the factories source a high percentage of their inputs from ports all over Ireland. Nephrops represent a large proportion of those imports.
55.On 19 January 2018, the Department for Environment, Food and Rural Affairs (DEFRA) secured £16 million in special funding from the Treasury to finance six projects which support the UK’s “day 1 readiness for exiting the EU”. Development of a new IT system for processing catch certificates was one the six projects listed. Claire Moriarty, Permanent Secretary at DEFRA, described providing catch certificates as a top priority project which is “constantly front of mind” because it carries large risks. She added that representatives from DEFRA had met with fisheries stakeholders to explain what would happen in a no deal scenario, and the “maximum additional work for the sector”.
56.In May 2018, the Public Accounts Committee reviewed DEFRA’s preparations for Brexit and concluded that “in light of DEFRA’s poor track record in implementing new IT systems” there are “substantial risks” around delivery of the IT projects. The European Commission has notified its fisheries stakeholders about the requirement to provide catch certificates in the event of a no deal Brexit. Trade with the EU made up 94% of Northern Ireland’s fish exports and 82% of its fish imports during the period 2014–2016, and ensuring these exports are not disrupted by requirements for catch certificates could therefore be a key priority for the sector.
57.In the event of no deal, catch certificates will be required for Northern Ireland’s fisheries imports and exports trade with the EU. The Government must be in a position to process catch certificates for all of Northern Ireland’s trade with the EU by 30th March 2019. We recommend the Government set out, in its response to this report, DEFRA’s timetable for piloting and delivering a new IT system capable of providing catch certificate for all UK fisheries trade with the EU in the event of a no deal scenario.
58.The UK has around 11,000 miles of coastline and an EEZ which is approximately 300,000 square miles. If the UK withdraws fishing rights for non-UK vessels—which is most likely under a no deal scenario—it must be capable of preventing illegal fishing within its EEZ. Minister Eustice described the current arrangements for enforcement of the UK’s EEZ in the following terms:
We have the fisheries protection fleet, which has three vessels. The Inshore Fisheries Conservations Authorities do a lot of inshore work on policing. There are several dozen vessels available to them. We have things like coastguard vessels. We also do a huge amount these days by remote vessel monitoring. [ … ] if they see suspicious behaviour or a vessel in a place it should not be, they alert the fisheries protection fleet.
59.Control and enforcement of fisheries legislation is currently a devolved matter. Lord Gardiner of Kimble, Parliamentary Under-Secretary of State, DEFRA has said that “it is for each Devolved Administration to decide how best to develop an enforcement solution to prevent unauthorised fishing”. In Northern Ireland, the Sea Fisheries Inspectorate (SFI) is responsible. It has three Port Offices based in the three main fishing ports of Ardglass, Kilkeel and Portavogie and mobile fishery officers. DAERA told us:
Sea going ability is provided through an inshore Fisheries Protection Vessel, based in Bangor County Down, and a large Rigid Inflatable Boat which can be transported anywhere round the coast when it is required. The SFI does not presently avail of the services of the Royal Navy, nor does it currently use aerial surveillance.
Oversight of control and enforcement activities within the UK is provided by the UK Fisheries Enforcement and Control Group that comprises policy leads from each Fisheries Administration. Further support is afforded by the European Fisheries Control Agency, with which the Government has said it will consider cooperation post-Brexit.
60.The Committee heard concerns that the UK does not currently have the capacity to police its waters. Former head of the Royal Navy, Lord West of Spithead, said that a lack of vessels will “create a crisis post-Brexit unless something is done urgently”. Alan McCulla, CEO of the ANIFPO, told us that although the UK’s satellite surveillance systems are impressive there is a “lack of assets within the UK” which can be deployed to do a “proper policing job.” Mike Cohen, Chairman of the NFFFO, said that there is “no doubt” we would need more funding and resources for enforcement.
61.Lord Gardiner of Kimble said the Government was undertaking an assessment of the scale and volume of sea-based patrol capability which will be required after the UK leaves the EU. The results from this assessment have yet to be published. In March 2018, the Royal Navy received the first of five new patrol vessels with the next four vessels expected to be delivered “at around six-month intervals” over the next few years. The Government has also set up the Joint Maritime Operations Co-ordination Centre (JMOCC) to manage cross-agency patrol capabilities, information sharing and aerial surveillance. However, the JMOCC is described as a “coordinating authority” which relies on deploying existing vessels.
62.In the event of no deal, the UK must have sufficient assets in place to prevent illegal fishing within its EEZ by 30 March 2019. We recommend that the Government publish its assessment of the assets required to police the UK’s EEZ after the UK leaves the EU and provide details of the amount of funding and number of ships available to the Joint Maritime Operations Coordination Centre to prevent illegal fishing in UK waters.
63.The Draft Withdrawal Agreement, endorsed by the European Council on 23 March 2018, established that the UK will remain in the CFP during the implementation period up to 31 December 2020. Under the terms of the Draft Withdrawal Agreement, the UK, as a non-member state, will not have a place at the negotiating table for the annual fisheries negotiations in December 2019, and its influence on EU fisheries governance bodies will be reduced. Article 125 of the Draft Withdrawal Agreement details special arrangements for fisheries during the implementation period:
64.Although relative stability quota share will be maintained during the implementation period, the process for setting annual TACs is complex, with many layers of consultation and decision-making which provide opportunity for influence and negotiation. The European Commission seeks scientific advice from several different bodies when formulating new fisheries regulations and proposing TACs for the annual fisheries negotiations:
65.Stakeholders expressed concern that the terms of the Draft Withdrawal Agreement, and the UK’s absence from the December 2019 Fisheries Council, could leave UK fishing interests open to disadvantage during the implementation period. Harry Wick said the UK would be “very, very vulnerable” because it won’t have “any influence or control” over decisions made by the EU which affect the UK fishing industry. He told us:
We do not know what “consulted” means. Does “consulted” mean we are being told it is happening or does it mean we have a say in what is happening? We need some granularity in that definition of “consulted”.
66.The Northern Ireland PO’s used the following example to illustrate why a state’s presence at the Annual Negotiations to advocate on behalf of its fleet is important. At the 2017 Fisheries Council, the POs presented evidence that stopped the introduction of a European Commission proposal to increase the size of the holes in nets used by nephrops fishermen. Alan McCulla explained:
When we presented that evidence, the Commission backed off. That does not mean to say that specific proposal went away. In fact, I know it is still lurking in the background. When we leave the European Union at the end of March next year, we are concerned that this process will continue. The detail still has to be explained to me as to what influence the UK team will have with the Commission to try to make sure that meaningful measures, and not just cosmetic measures, are introduced for fisheries in the Irish Sea.
67.Northern Ireland’s POs also expressed concern that it is “in the EU’s interests” to damage UK catching capacity as much as possible to ensure greater surplus stock in the UK EEZ after Brexit. As discussed in paragraph 21, UNCLOS places an obligation on coastal states to provide access to other nations with regards to surplus fish stocks which it lacks the capacity to harvest. Secretary of State for Environment, Food and Rural Affairs, Michael Gove MP, has emphasised that “any attempts by the EU to operate in a way that harmed the UK fishing industry” would breach the obligation of good faith in the Draft Withdrawal Agreement. Steve Peers, Professor of EU and Human Rights Law at the University of Essex, has said that the UK proposed the addition of a good faith clause because it is “concerned about being bound by EU legislation adopted during the transition period without its involvement”.
68.The European Scrutiny Committee noted that “significant caveats apply to the good faith provision” and there is no detail about how it will operate in practice. We asked Minister Eustice to explain how the UK can utilise the good faith obligation, he told us:
This is a common feature. I know some people would say, “Does that mean anything?”, but such clauses are a common feature of international agreements, and there is a good faith clause there that we would be able to fall back on, should the EU take an action clearly done in bad faith, calculated to attack our interests.
69.Minister Eustice told the Committee that “in practice, not much will change” during the implementation period because the UK has agreed to abide by “a carbon copy” of the CFP. The UK will continue to send experts to advise the Commission on the scientific basis for setting TACs and “take part in other forums” which influence the Commission’s thinking. Nigel Gooding, DEFRA Deputy Director, said the UK will be involved in discussions and able to influence decisions “right up until the last point”, it just won’t be present in the Council chamber.
70.The European Scrutiny Committee highlighted that the Draft Withdrawal Agreement makes no provision for the continued role of UK representatives in EU fisheries forums and asked Minister Eustice to clarify the following points:
Whether the UK would be invited to relevant meetings of the STECF and the Fisheries and Aquaculture Expert Group and, if so, how the UK would assess whether it was being invited to all of the appropriate meetings and for all of the appropriate agenda points
The Minister responded that UK experts provide valuable advice on STECF and “there is a strong case for continued UK participation.” The Government said it is in discussion with the EU to secure “a clear process” for how UK engagement on these bodies will work. However, the European Commission has announced that UK stakeholders will no longer be eligible for membership of the fisheries advisory councils during the implementation period. British members will instead attend meetings as “active observers”, which means the Advisory Council advice will formally reflect the views of only EU 27 Member States during the implementation period.
71.The annual EU Fisheries Council, usually held in December, is where Fisheries Ministers from across the EU come together to decide the Total Allowable Catch (TAC) for each commercial fish species in EU waters. Scientific assessments of fish populations are used to determine how much fish can be harvested sustainably without affecting the supply of fish in the future. However, scientific stock data is not the only factor under consideration at the negotiations. The Government describes the process as follows:
At these meetings the latest scientific advice is used as a starting point and considered alongside other relevant factors such as the economic impact on the EU fishing industry of any decision, relevant conservation factors and new technical measures. Some key factors in recent years have been things like the phased introduction of the landings obligation, where the change in the patterns of activity of fishing vessels through the use of more selective fishing gears and fishing behaviours have been taken into account in the final decisions on the levels of quotas for the following year.
72.The NFFO consider negotiations at the December Fisheries Council as the “end point of a process which takes most of the year.” In anticipation of the 2017 Fisheries Council, the NFFO discussed its use of the following strategies to influence the Commissions’ decisions on TAC: challenging the data contained in the ICES recommendations, proposing different approaches for TAC decisions and making alliances with fisheries representatives in other Member States with shared interests. The final decision on TACs is taken by Fisheries Ministers on the basis of scientific advice and in consideration of factors such as the need to balance mixed fisheries, avoid discards and manage socio-economic concerns. Analysis undertaken by the New Economics Foundation, comparing ICES recommendations with the final decisions on TACs taken by Fisheries Ministers, found:
Our historical analysis of agreed TACs for all EU waters between 2001 and 2016 shows that, on average, 7 out of every 10 TACs were set above scientific advice. Whilst the percentage by which TACs were set above advice declined throughout this period (from 42% to 12%), the proportion of TACs set above advice did not.
73.Minister Eustice has acknowledged the political nature of the negotiations at the Fisheries Council:
Under the current CFP, the EU has a legal obligation to follow maximum sustainable yield as the guide when setting TACs. It therefore starts out with the position that ICES has set out. The science tends to dominate the allocations, but that is not to say that there is not also political discussion around that table, and the EU will obviously try to achieve a consensus.
74.While informed by scientific advice, the decisions which determine Total Allowable Catch at the annual Fisheries Council are inherently political. The agreed Total Allowable Catches represent the culmination of a year’s worth of research and careful negotiation from interested parties across the EU. The absence of UK representation around the table at the December 2019 Fisheries Council, and in other fisheries governance bodies which influence the Commission’s decisions, could result in disadvantage to the UK fishing industry.
75.The Committee welcomes the commitments, contained within the Draft Withdrawal Agreement, on protecting British interests during the implementation period. However, the vague language and general terms which sufficed for the Draft Agreement will not be acceptable in the final text. We recommend that the final text of the Withdrawal Agreement, or accompanying documentation, clarify:
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34 Under the a state has the right to establish a territorial sea up to a limit of 12 nautical miles measured from the baseline. The EEZ is an area of sea beyond and adjacent to the territorial sea that extends up to 200 nautical miles from a country’s coast. The EU EEZ comprises the EEZs of all member states in the 12–200 nautical mile zone. European Commission,
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Published: 15 September 2018