Memorandum by David Thomson, International
Fisheries Management Specialist
CONSERVATION AND
MANAGEMENT
1. To what extent have the CFP management
measures, and recovery plans been effective in ensuring conservation
and sustainability?
A review of the past 30 years, or just of the
period in question since 2002, reveal that the impact of CFP management
on UK fisheries has been almost entirely negative. Whether we
look at annual stock assessments, continuing fleet decline, or
the stagnation of the economies of the coastal fishing towns and
villages, there is almost no sign of recovery. Neither the fish
stock, nor the harvesting fleets and shore industries, have been
sustained. The decline in fish industry benefits has been especially
hard on the more remote and island coastal communities. These
traditional fishing villages have no comparable resource on which
to base a sustainable economy. Continuing calls for further quota
cuts and additional fleet reduction, are ample evidence that the
whole policy and its related measures are failing, year after
year.
2. What are your views on: total allowable
catches; effort limitation; marine conservation areas; rights-based
management; and technical conservation measures
Total allowable catches are based on the scientists'
best estimates of stock size, plus the judgment of fishery administrators,
and also the lobbying of national governments for a greater share
for their respective fleets. The end result rarely satisfies any
party. It should also be noted that the estimates are based on
two year-old data, and in some cases on bogus statistics, as for
example from the years of false reporting of monkfish east and
west of the 4 degree line,—the result of scientists and
administrator's failure to recognize a reality that reflected
badly on their management. The colossal amount of discards—up
to 600,000 tonnes a year, was never calculated accurately, by
volume or species, and so not included in the estimates of production.
Other governments and fishery regimes take a more flexible attitude
to stock assessment, and consider estimates provided by fishers
and independent observers of the marine environment. UK researchers
have often complained in private about the political pressures
under which their estimates are made.
Effort limitation is a much more reliable tool
than TACs or quotas for managing the operations of the harvesting
fleets. The Faeroe Isles for example has abandoned fishery management
by quotas in favour of effort limitation, which can be achieved
by limiting the number and power of vessels, the gear they may
use, the seasons when they may fish, and where appropriate, the
number of days they may spend at sea.
Marine conservation areas are good in principle,
but suffer from hijacking by interested groups, each with their
own agenda, and often motivated more by a desire for power or
influence. Green and wildlife NGOs know that their involvement
in and potential control of, conservation areas, will add to their
public profile and increase the opportunities to draw income from
the general public and from government. Some of them have no interest
in the welfare of fisher-dependent communities, and a few have
indicated their wish to put an end to most forms of commercial
fishing. The tension between fishing communities and groups promoting
MCAs is a global phenomena. Members of the Indigenous People's
Forum on Bio-Diversity from South Africa, India, Latin America
and Pacific states, and supporting NGOs from UK, USA and Europe,
walked out of the CBD meeting in Rome Italy on 14 February 2008,
protesting that they were marginalized and silenced by the Commission
despite the importance of the recommendations to their lives,
lands and waters, and the critical impact of protected areas on
their rights.
MCAs work best when there is meaningful involvement
by the communities affected who should have a right to veto extreme
measures that would destroy their livelihoods. A few countries
like Japan and the USA have developed useful examples of MCAs
or similar reserves designed to both protect resources and sustain
local economies. They give substantial fishery management authority
to their coastal cooperatives. Fishermen on Scotland's west coast
fear that the proposed Marine Park, if imposed on their area would
simply allow the already bloated seal population to expand at
the expense of the local fleet. The seals there currently consume
four times as much fish as are caught by the local west coast
and islands fishing vessels.
There are three fundamental principles that
WWF and IUCN seek to apply abroad with considerable diligence
when considering possible marine parks or sanctuaries. These principles
are : 1. there must be sound scientific evidence of the need for
such a measure, and also reliable indications that the measure
will have the desired result; 2. there must be full and open consultation
with the local fishers and their communities, whose agreement
must be obtained before proceeding with the venture; 3. if some
fishers or stakeholders are to lose income as a result of the
intervention, then there must be adequate compensation or alternative
employment provided. The UK would do well to apply these principles
firmly to every Marine Park or MCA proposal.
Rights-based management is being developed in
many of the world's fisheries, and can be an excellent tool to
ensure some justice and equity in the allocation of resources
or in ensuring continuing access for vulnerable groups. The main
danger facing the UK from EC / CFP interpretation of rights-based
management, lies in the assumption by some that these very rights
might be bought and sold on an open market. Once that is permitted
the system ceases to be rights-based and becomes market-based,
with fishery sector jobs and community's economic futures being
traded like any other commodity. That is exactly what will happen
if ITQ arrangements are developed to their ultimate end. Several
governments have allocated rights-based access to fish resources,
in perpetuity, to indigenous groups that would be vulnerable if
their rights were to be made a marketable entity. So community
quotas and other special arrangements have been organized in the
USA for native Americans, and in New Zealand for Maori peoples.
Canada's Fishery Minister recently lifted the ban on cod fishing
for inshore fishers using open boats, to ensure these persons
and their out-ports, have a modest livelihood throughout the year.
Technical conservation measures can be good
or unhelpful. Most of them have some side-effects that are unfortunate.
They are most difficult to apply in mixed species fisheries such
as the UK demersal or white fish sector where the size of a legitimate
target fish can vary so much. The mesh size suitable for mature
whiting is smaller than that for haddock, which is smaller than
that for cod, and so on. But if your boat's quota allocation includes
all three species, what do you do ? Fishery administrators then
introduce more measures to address the side effects, such as enforced
discarding, but the end result is an unsatisfactory mix of conflicting
regulations that only frustrate the fishermen while doing nothing
for stock conservation. It should also be borne in mind that most
skilled fishers can get around technical measures. The answer
must be to have the industry fully involved in all the decisions
taken and to avoid any technical measure that does not have general
support from the harvesters themselves.
3. To what extent has current management increased
discard and by-catch? How could these problems be tackled?
I have seen no evidence that measures since
2002 have increased the amounts of discards or by-catch, but certainly
the past three decades, the illogical fixation on single species
quotas in a mixed species fishery, has been the key element that
has resulted in the enforced discarding of over half a million
tonnes of good fish each year, in the North Sea. By any measure
of fishery management assessment, this has been a travesty for
the fish stock, the markets, and the fishers, and has probably
caused more damage to the resource than any degree of excess fishing
pressure.
How can this problem be tackled? First and most
importantly, by scrapping the whole concept of single species
quotas for the demersal and mixed fish/prawn fleets. Do what many
wise fishery administrations have done from Namibia to the Faeroe
Isles, and instruct the fishers to land everything they catch.
Second, ban discarding completely.
Namibia, which unlike Faeroes, still has a basic
quota system, uses an arrangement of levies to limit targeting
of non-quota species. All fish caught must be landed. On-board
inspectors monitor and police that. Any fish landed excess to
quota or not included in the quota, are sold. The proceeds are
returned to the vessel,—minus a levy. The levy is finely
balanced to achieve two purposes : one is that the fishers do
not lose money by keeping, storing, and landing the fish; and
the other is that they make no profit on that part of the catch.
Each year when total landings are assessed and compared with the
previously set TACs or species quotas in Namibia, there is little
disparity, and so the system has been seen to work well.
4. Do fishery policies need to adapt to climate
change?
None of us know yet how climate change will
affect our fisheries. It would be foolish and presumptuous to
adapt fishery management policies before we know what changes
are definitely taking place in the marine environment. There are
indications that some species are migrating northwards. We see
some sub-tropical species in our southern waters, while cold water
fish like cod appear to moving north from their former grounds.
CONTROL AND
ENFORCEMENT
5. To what extent has the CFCA assisted in
improving matters? What are the efficacy of systems in place?
The CFCA systems are too often self-defeating
and alienating the fishers. Too many rules and penalties appear
to the stakeholders to be perverse and illogical. Ill-conceived
laws and regulations bring the whole law into disrepute. Many
fishery officers have expressed their disgust and resentment to
me, at having to punish fishers for failing to follow measures
that are of no benefit to the resource. The CFP has failed to
give the fishery stakeholders a meaningful say in the regulations
drafted. International meetings have noted that illegal fishing
and landings, wasteful discarding, rules beating, and misreporting
can to some degree be a direct result of badly-conceived management
rules. Some such rules may be the product of flawed science, others
of political or factional preferences, and still more of disregard
of advice or ignorance of fishing technology. Many skippers and
observers maintain that the system has made criminals out of otherwise
honest men.
6. What is your view of different penalties
for serious infringements in EU States?
Difficult to control given the intransigence
and resistance by France, Spain, etc
STRUCTURAL POLICY
7. To what extent have Member States adjusted
their fleets to balance capacity with opportunity?
Low-impact small scale fleets have shrunk while
powerful high capacity units have mostly increased in fishing
power if not in number. This has been an indirect result of the
CFP measures which have failed to protect the small scale fleets
which have minimal impact on the resource, and have few negative
effects on the marine environment.
UK has the most productive EEZ of any of the
EU members, yet its fishing fleet has lost more vessels than any
other state,—all in conformity to EC demands to decommission
more and more boats. What is left of our fleet is faced with many
more restrictions than their predecessors,—so instead of
"opportunity", UK fishers are faced with a massive constraint
on their operations.
8. What is your experience of the new fisheries
structural fund, EFF?
No comment
9. What are your views on the possible impact
of WTO-level discussions as regards subsidies in the fishing sector?
Subsidies in the fishing sector are an emotive
issue which is often subject to claims that have little factual
basis. While agriculture is heavily subsidized in Europe, fisheries
are not (and should not) be subsidized. But we see a growing number
of programmes and quangos established, each with a claim to manage
part of the industry, and all wanting to be paid for by the industry,
since their services are "a subsidy"! Far better to
have our fishing industry manage and finance these services,—and
select which ones they really need. Why should government undertake
advertising on behalf of the fish merchants and processors? That
is an example of something the industry can do itself. Fish product
development and fishing gear development are also things the industry
can do quite well.
The main work on global fisheries subsidies
and fleet over-capacity, was written by Dr Francis Christie, for
FAO and the World Bank. He was aware that his papers did not address
the situation of the smaller scale inshore and coastal fishing
fleets of the world, so he asked Dr John Kurien to investigate
the subject further. Prof. Kurien's paper, which can be found
on the internet, concluded that the most heavily subsidized fishing
fleets were the large scale industrial fishing units. Apart from
a modest fuel subsidy in some countries, most small scale fleets
operate with little financial aid from their governments. Many
fear that the WTO will take a sledgehammer to crack a peanut,
and may fail to discriminate between the different fishing fleets,
each of which has its own particular raft of taxes, facilities,
and technical support programmes. WTO recommendations may also
favour the large scale, high-impact commercial fleets over the
small scale coastal sector.
Ref: Kurien, John; 2006, Untangling Subsidies,
Supporting Fisheries: The WTO Fisheries Subsidies Debate, ICSF.
DR F. Christy's calculations which are the basis of much of the
WTO position can be found in Appendices 2, 3, 4, and 5 of the
FAO State of Food and Agriculture 1992 report, Rome 1993.
A shorter summary of Kurien's paper, Over-capacity, Over-fishing
and Subsidies, is available from the USA secretariat in NMFS
of the Pacific Fisheries Forum. The shorter version was presented
at the 2006 Forum in Hanoi.
One should also take a hard look at EC fishery
subsidies which are continuing and which mostly benefit Spain
and France, and which have often been used to support EC fleets
in their operations off West Africa and elsewhere,—usually
with tragic results for the local fish stock and fishing communities.
Senegal is a country whose fishing grounds and fish stocks are
of great interest to European fleets. But their intervention there,
while agreed to by Senegalese Ministers, and assisted by the EU,
has seriously hurt the local fishing fleets and reduced some stocks
to a level of concern.
GOVERNANCE
10. What is your view on the future evolution
of Regional Advisory Councils?
No comment
11. How do you consider EU fisheries should
ideally be governed?
How appropriate and feasible do you consider
a regional model to be?
EU FISHERIES
GOVERNANCE: IS
A REGIONAL
MODEL APPROPRIATE?
It could be, but only within strict limitations.
Fisheries governance above all should be transparent, based on
clearly stated objectives, and be participative, involving fully
the fishing communities and the fishing industry stakeholders.
Too often, consultations have been empty PR gestures with no genuine
attempt to listen to those affected. (The writer has seen fishermen's
leaders publicly insulted by government representatives at supposed
consultation meetings). Fisheries governance should also be open
to review and critique by competent, independent bodies.
There are a number of international examples.
These include the SADC and ASEAN countries which have agreed regional
fishery management policies. The USA has similar arrangements
with Canada, Mexico, and the small states of the Caribbean and
the Pacific. None of these countries have yielded their EEZs to
any central management like the EU CFP. There are also the three
main regional Tuna Commissions of the Indian, Pacific, and Atlantic
Oceans, plus two in the Americas. (see www.tuna-org.org ).
In each of those cases, the participating governments
retain full control over their 200 mile EEZs and their own fleets
and their national fishery management systems. But they meet annually
to agree on common approaches to the management of shared stocks.
That works very well, guaranteeing cooperative management but
preserving sovereign rights.
In contrast the EC/EU, under the Lisbon treaty
will have unlimited control over all "marine biological resources"
(the part referring to joint EU/national control of fishing does
not reflect the reality). Marine biological resources extend by
definition from whales and basking sharks to the last frond of
seaweed. This control, to be exercised from the desk of the Fisheries
Commissioner in Brussels, will extend from the Baltic through
the north-eastern Atlantic, North Sea, Mediterranean, Aegean and
Adriatic seas to the Black Sea. It takes little account of the
vast differences in regional fish species, different fishing methods,
local consumption patterns, local fisheries culture and local
social and employment structures. That kind of centrally-controlled
regional model is a recipe for inflexible and undemocratic management
from a distance that is insensitive to local needs and local situations
requiring tailored responses to particular issues.
The best fishery management system by far is
one that is locally based and which the local stakeholders largely
operate themselves with government taking only a supervisory role
and providing the overall policy. Some examples can be found in
the USA and Japan, where specific fisheries form their own rules
and enforce their own members. The UN Agencies and several bilateral
organizations and NGOs assist a number of developing countries
to adopt this model. In no part of the world that I know, has
any group of fishing states considered or adopted a centrist EU
type model that requires them to give up their sovereign rights
over their national fisheries.
19 February 2008
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