We are all aware, I think, that the fishing industry is approaching an important fork in the road. The last 15 years has seen many changes; but even now it is reasonably certain that the reform of the Common Fisheries Policy, which will in all likelihood be agreed later this year, contains the possibilities for a radical change in direction.
What is less certain is whether
the positives will outweigh the negatives. Much will depend on the commitment
and vigour of organisations like the NFFO as well as the member states charged
with implementing the reformed CFP.
Although unlikely to be the main
feature of the reform in the media spotlight, the scope for detailed
decision-making on fisheries policy to be made at the regional seas level,
rather than by the European institutions in Brussels is potentially of
momentous significance. All will depend on the details and the commitment of
member states and stakeholders once the legislation is in place but this
potentially decisive departure from the over-centralised micromanagement offers
a real opportunity for a more responsive and therefore effective CFP.
Parallel to this decentralisation of the CFP, the steps
towards an obligation to land all catches of the main target species – the discard ban – likewise means that
fisheries policy and management is likely to be very different from here on.
What is clear is that the industry faces a difficult period of transition
whilst the landings obligation is implemented.
What exactly these two changes,
interacting with each other in future years, will mean for the NFFO’s members
is not easy to foretell. Much depends on how much detailed control it retained
at the centre. Much also depends on the degree to which member states and the advisory councils, at the regional seas level,
take up the opportunities and flexibilities that the new structure provides.
What is abundantly clear,
however, is that if fishermen in the member states want to influence the
outcomes, they will have to put divisions behind them and work coherently and
cohesively to ensure that their voice is heard and taken account of. For
England, Wales and Northern Ireland the NFFO provides that voice and is
committed to working tirelessly for and within a more rational and responsive
management system that is up to the job of facing future challenges.
CFP Reform
When regionalisation of the CFP
was advanced by the NFFO and the Scottish Fishermen’s Federation more than a
decade ago, it was considered by many to be dangerously a dangerously radical
idea that threatened the foundations of the CFP. In that intervening decade,
the continued failures of the top-down command
and control approach – most notably in the EU Cod Management Plan – and the evident success of the regional
advisory councils has meant the concept has moved centre stage although with
different degrees of enthusiasm from different quarters. This shows the
importance of persisting with well-thought through alternatives and using every
opportunity to explain how they could be implemented in practice.
Co-Decision
The European Parliament’s new
powers under the Lisbon Treaty have meant that the Federation, along with other
European fishing organisations, has had to adapt to the new political landscape
if it is to remain influential. This means keeping MEPs briefed and intervening
through hearings in the Parliament and through direct contact with MEPS. As
yet, it is too early to say how co-decision will work in practice. Our fear is
that the Parliament will hold back decentralisation of CFP decision making,
partly because having been recently given new powers they will be keen to
exercise them to micro-manage rather than sharing them with the regional level.
Under-10 Quota Management
It has become quite apparent that
there is a log-jam at government level in making progress in resolving the
quota problems facing some parts of the under-10m fleet. The Federation has
made clear in a number of publications its view that the roots under-10 problem
is multi-faceted and its solutions if they are to work must take account of
those different facets. Simplistic narratives, no matter how they appeal to
some parts of the media and to some MPs will not deliver effective, fair or
balanced outcomes. One of the big mistakes to plague the debate so far has been
to treat all under-10s as if they are the same in catching power or access to
non-TAC fisheries.
In face of the absence of
progress, the Federation has taken the initiative to convene a meeting between
producer organisations and key under-10 groups in the South East to discuss
quota pinch-points and means through which unutilised quota could be
re-directed in real time.
Shellfish
The NFFO Shellfish Committee,
which is comprised of shell-fishermen from all parts of the coast, has worked
hard over the last year to produce a policy which addressed the most urgent
issues facing the sector. The policy whilst maintaining flexibility to meet the
very different needs of varying parts of the fleet and coastal fisheries is
designed to ensure the future sustainability of the crab and lobster fisheries.
The Government’s inertia in responding to this positive initiative has been a
great disappointment and the Federation’s task now is to focus the Minister’s
attention onto this lost opportunity if Government inaction continues.
Deep Water Species
Slow maturing species and
vulnerable marine ecosystems in the waters of the continental shelf edge means
that a particularly careful approach to harvesting commercial fish species is
an absolute prerequisite. This is very different however from the Commission’s
proposal for a blanket ban on bottom-trawling and gill-netting which was
published before the results of a major study funded by the Commission itself
which provides the basis for a much more reasoned and proportionate approach.
The Federation, recognising that these kind of politically-driven, science-free
initiatives threaten all fisheries is working with Defra, the European
Parliament and in the regional advisory councils to refocus on a balanced
approach.
Wind-farms
The success of the Federation’s
collaborative work with the Crown Estate to produce very precise mapping of
fishing activity base on plotter data supplied by skippers themselves has moved
decisions on the location of future wind–farm zones as well as dialogue with
individual developers onto a new plane.
This approach has implications
also for marine protected areas and marine spatial planning generally.
Fisheries Minister Richard Benyon when presented with the results through the
Crown Estate’s MaRs system conceded that it was a “game-changer” not least
because this precision come with a very low price tag compared to the £4.2
million spent on the considerably less precise data used for the four regional
stakeholder projects.
Cables
The Federation this year has
agreed a memorandum of understanding with UKSC, the representative body for the
cable industry. We consider this as an important basis for minimising potential
conflicts in the future not least because of the number of export cables from
wind-farms expected to cross important fishing grounds in the near future.
Regional Advisory Councils
The NFFO accords the highest
priority to working within the four regional advisory councils which are of
relevance to our members’ fisheries: North Sea, North Western Waters, Pelagic
and Distant Waters.
Industry Reputation
The Federation has been dismayed
by the constant flow of hostile and ill-informed criticism in the media. As a
result in addition to working with Seafish and others in the industry we have
taken on communications specialists Acceleris
to redress the balance. We were therefore in a strong position to rebut
Greenpeace’s bizarre series of attacks on the NFFO and on the industry’s unity
more generally. The point however is not really to swat away Greenpeace’s
attentions but to ensure that the industry’s achievements in meeting society’s
changing expectations and delivering sustainable fisheries are fully
recognised, not least in the areas of food security, fisheries science
partnerships and stock rebuilding.
Control Issues
When the new EU Control
Regulation was adopted in November 2009, it was recognised as the last gasp of
the Commission’s command and control ideology, rushed through before EU
co-decision making arrived. As predicted, the fishing industry is now having to
deal with the consequences of this impetuous approach, not least in the arrival
of electronic log-books.
Information technology has much
to offer the fishing industry, as in other areas of society and the economy but
it is quite easy to get things wrong through a rushed process which fails to
take account of the specifics of fishing. The failure of the UK to take the
opportunity to exempt day-boats at the very least until the problems are
resolved in the larger vessels defeats mortal minds. This along with a range of
control issues is being addressed by the Federation through direct discussions
with MMO and Defra and through the RACs.
Marine Protected Areas
The marine protected areas
bandwagon is well underway, with celebrity chefs, media-oriented academics,
environmental NGOs, politicians and journalists proclaiming their arrival,
overstating their likely benefits and studiously ignoring the potential adverse
economic, community and ecological effects of displacement of fisheries from
their customary fishing grounds. The Federation has worked within the MPA
Fishing Coalition to redress the balance and it is pleasing to report that
Defra and the MMO both exhibit a deeper understanding of the issues than those
bodies which for their own reasons support an immediate network of MPAs in UK
waters. We will continue to work with Government for a fully rational
evidence-based and thought-through process.
Fishing Vessel Safety
The high cost of bringing fish to
consumers in terms of lives and injuries to fishermen is usually subordinated
to conservation concerns in the public debates about fishing. The Federation
however, through the work of its safety and training officer, the work of the
Fishing Industry Safety Group, regular circulation of safety information and
MAIB reports to its members and most recently the purchase and circulation of
1000 grant aided low-cost lifejackets, strives to encourage the safety culture
that is the only way of reducing the casualty rate. As safety training and is
the key to progress in this area the Federation whilst open to reviewing all
aspect of how to improve the safety regime is strenuously resisting attempts to
block Seafish levy for training.
Conclusion
With the changing political
landscape for European decisions in fisheries; with the misinformation
campaigns used by media savvy NGOs; with an array of pressures from marine
protected areas to maximum sustainable yield that were hardly on the horizon
ten years ago; it is more important the fishing industry strives to speak with
a united voice. The NFFO has earned respect (and not a little heat) for
performing that role creditably. As we move forward it is of absolutely
critical importance that it continues to do so. I hope that we will continue to
advance rational, fair, well thought-through policies. I hope that we will
continue to work with all kinds of groups which share our ambitions. I hope
that we will remain responsive to our grass roots members.
I hope that we will continue to
be listened to not just because we are the largest and most established
fishermen’s organisation in the area that we represent but because what we say
is worth listening to – and most importantly, acted upon.
The RAC recently convened a meeting in Brussels to discuss the many issues associated with the ban – even before the new Regulation has been formally adopted. The European Commission, MEP Ulrike Rodust, representatives from the North Sea member states and scientists, joined RAC stakeholders in putting a spotlight on both the challenges and opportunities ahead.
Chairman of the NSRAC Executive Committee, Niels Wichmann said:
“The workshop has been an excellent starting point to commence the work required to ensure that fishermen can comply with the new regulation. The European institutions have agreed to apply a phased landing obligation and it is our joint responsibility now to implement this new approach in ways that make sense at the level of each fishing vessel.
The purpose of bringing together all the main parties at this early stage was to put a spotlight on what needs to change to bring this about. We need to make sure that the regulations, infrastructure and facilities are in place to allow fishermen to apply a discard ban. What we have seen at the workshop is an open and honest exchange of views and opinions of how this could be practically implemented, for example we need to consider how to handle on board as well as ashore the fish that would have otherwise been discarded.”
“No one at the meeting was in any doubt that the transition to a discard ban represents a major challenge for everyone involved. Much detail still needs to be worked out and we wanted to establish, right from the beginning, that the fishery stakeholders must be centrally involved if we want this measure to be fully effective and for fishing vessels to be economically viable throughout this whole process”.
In addition to a number of fishing industry speakers, contributions were heard from scientists, the European Commission, environmental NGOs, fisheries managers and the European Parliament.
NSRAC members will now work together to build on the outcomes of the workshop, developing advice for the European Commission on number of important aspects of the discard ban including:
- Rules for quota uplift
- How to deal with the potential for ‘choke stocks’ – minor species which could prevent the full uptake of the main quota species
- An exemption for species with high survival rates when they are returned to the sea
- Creating the right kind of economic incentives in the industry to improve catch selectivity
- How cooperative regionalisation policy formation will be used to develop multi-annual management plans or discard plans
The Minister’s has provided an important assurance that he would not apply management measures to MCZs outside 6 miles, until those measures could apply to all vessels (UK and non-UK) operating within those areas. This makes sense both from the point of view of logic and to avoid discriminating against the domestic fleet.
However, as you recognise, designation does lead to duties on the responsible authorities and the new dimension to this issue is the increasingly toxic atmosphere in which some of the more litigious NGOs use the courts, or threat of legal action, to force those authorities to follow the letter of the law. This development potentially removes, or at the very least compromises, the space between designation and the adoption of management measures. This is the space in which we had hoped that it would be possible to navigate a settlement for each site which simultaneously protects the fishing industry whilst achieving the conservation objectives for that site.
For this reason we have come to the conclusion that it would be unsafe to designate further MCZs until the whole process of designing and consulting on appropriate management measureshas been completed. This is the only way that we can be assured that designation will not trigger a sequence of events that lead to inappropriate and premature management measures being applied. As you know, throughout the whole process of establishing a network of MPAs our primary concern has been the potential for displacement of fishing activity from its customary areas, with adverse socio-economic and ecological consequences.
We, I think, are both agreed that a collaborative and evidence-based approach to the designation and management of MCZs is the preferred option, both in terms of achieving ecological objectives and minimising socio-economic disruption. However collaboration is undermined and jeopardised if NGOs consider the courts are a viable tactic to achieve their objectives. This is especially true where such legal tactics are used to force the timetable for the introduction of management measures. Meaningful stakeholder engagement is time consuming. But evidence from elsewhere in the world suggests that it is time worth spending as it leads finally to a more effective environmental protection.
Our concern is that henceforth designation will trigger a chain of events running: designation, legal challenge, rushed implementation of management measures to offset legal challenge, failed consultation leading to inappropriate management measures, fleet displacement, adverse socio-economic consequences and ecological damage outside the designated area. Especially under threat is the possibility of a zoned approach where protection or a specific feature and the continuation of fishing activity within a designated area are achieved through spatial separation.
The only way that we can envisage to avoid this sequence in the current climate litigation focussed tactics is to bind designation and management measures into a single process. The Government could indicate that it is minded to designate a particular area, without a formal recommendation. Discussion would then begin with relevant stakeholders on appropriate management measures and once agreed designation and management measures adopted together.
I hope that this conveys our concerns in this area. We would of course be happy to discuss any aspect at your convenience.
Yours sincerely
MEMO FOR THE EFF PMC MEETING ON 12 JUNE 2013
INTRODUCTION
The experience of NFFO members, not just the NFFO, would seem to suggest that the MMO team dealing with the EFF is currently under-resourced.
In general, this has resulted in negative experiences for NFFO members with respect to:
- The length of time that lapses before a response is received to a query or request for information;
- A tendency for applicants to receive “last minute” notifications relating to information requests and panel meetings;
- Inconsistencies between information provided on the web-site and the actual information required from applicants;
- The lack of standardised documentation.
As a result the perception of the utility of applying for EFF funding, particularly among small businesses, is extremely negative.
POSSIBLE EXPLANATIONS
There would appear to be a number of possible explanations beyond the purely resource related factors.
These could include:
- Pressure to avoid de-commitment leading to an excessive concentration on developing new applications;
- The complexity of the whole application process;
- The initial lack of experienced personnel following the move to Newcastle;
- The precedent setting nature of some proposals;
- The impact of the negative report by the European Court of Auditors
- The lack of standardised documentation;
- The absence of a clear, public statement of audit policy requirements.
In this respect it would be helpful for the PMC to receive details of the average length of time, from initial contact through application, the completion of documentation, project completion, verification and disbursement by category of project (value / life of asset / Axis). It would also be desirable for such figures to cover the trend over time on an annual basis to establish whether matters had improved.
NFFO’S EXPERIENCE
Whilst the NFFO’s experience is chiefly coloured by the PFD project, there are also other projects with which is concerned.
The points that it would like to highlight are:
- Inconsistencies in the information provided relating to both information requirements and matched funding rates;
- Difficulties over pan-UK projects (which effectively do not exist);
- Delays in response to queries (particularly with respect to documentation);
- Disparity between asset life and length of audit trail (e.g. a consumable that would be written off in one year is subject to the same or more stringent treatment as a harbour installation depreciated over 25 years);
- Absence of a de minimis exemption for small value consumables leading to disproportionate audit requirements.
IMPLICATIONS
The net effect of these negative experiences is to underline the impression that the EFF is not designed for the SMEs in the catching sector and that it is not worthwhile wasting time applying for funding.
Given this situation, and the likely shape of EMFF, something needs to be done to simplify the process and speed up response times, or, alternatively, to consecrate more resources to assisting SMEs in the application process (particularly in dealing with discards). Otherwise interest in the EMFF will be minimal.
07/06/2013
The NFFO would be interested in receiving members’ comments on their experience with the EFF application process.
Programme
All NFFO Members Welcome
Wednesday 3rd July 2013
10.30am: Coffee
11.00am: AGM Formal Business
12.00pm: The meeting will be joined by UK Fisheries Minister, Richard Benyon M.P.
After a brief address the Minister will participate in an open floor session
1.15pm: Buffet lunch
2.00pm: Close of Proceedings
Where have they been?
Haven’t they heard of the ground-breaking Fisheries Science Partnership, which has set the standard for participative scientific advice in Europe, and which the NFFO pioneered along with CEFAS and DEFRA?
Or what about the NFFO’s role in the NWWRAC’s data deficiency initiative, working with ICES?
Or our work with scientists on long term management plans in the Celtic sea, the Irish Sea and the North Sea?
Wasn’t the NFFO a leading member of the North Sea Commission Fisheries Partnership that established a dialogue with scientists at an international level for the first time and led to the establishment of the North Sea RAC?
Hasn’t the NFFO called for the Commission to take into account the latest scientific work on deep sea fisheries?
Once again some rudimentary homework would have saved Greenpeace a lot of embarrassment. The first rule of science is “get your facts right”. As we have said on more than one occasion now, fishermen have a deep interest in objective, rigorous, impartial science – if only to fend off the more outlandish claims of professional doomsayers like Greenpeace.
Richard Benyon M.P.
Minister for Fisheries
DEFRA
Nobel House
17 Smith Square
London
SW1P 3JR
Dear Minister
Fragility of South East Fisheries
The inshore fisheries in the South and South East of England are facing an unprecedented set of adverse circumstances. Many vessels are struggling to survive. An extended period of bad weather has made the first half of 2013 a disaster.
2012 was extremely wet and windy; then the first few months of 2013 were very cold, the coldest, in fact, on record. The result has been that abnormally cold seawater temperatures have disrupted the normal reproductive cycles and migration patterns. Shellfisheries and whitefish fisheries have both been badly affected. Vessel grossings are down in some cases by 70% to 80% and fishermen throughout the region are struggling to pay their bills.
The low level of landings has had knock-on consequences for all businesses linked to fishing, including fish merchants, gear suppliers, electronic companies, and diesel suppliers.
You are not of course responsible for the weather. However, in a number of forthcoming decisions which you are responsible for it is extremely important that you take the current fragility of the fleet’s economics into account. Decisions on TACs and quotas, European marine sites and marine conservation zones, licences for dredging operations, and consents for offshore renewable projects all have the potential to topple fishing businesses in the South East beyond the point of no return. The way that the newly agreed ban on discards is implemented could be critical.
We appreciate that there are competing pressures on you when these kind of decisions land on your desk. It does seem to us however that the economic viability of fishing vessels and their vulnerability to the consequences of government decisions is often not given the priority that it deserves.
Against the background of extreme pressure on the South East fleets that I have described above, I would urge you to be sensitive to this extremely precarious situation and to discuss the implications policy with the industry’s representative bodies, each and every time in the coming months that you are called on to make a decision which potentially affects us.
Yours sincerely
Tony Delahunty
Chairman, NFFO South East Committee
A long-awaited agreement on EU fisheries policy is finally in sight. This is welcome news to all concerned, including politicians, those working in the commercial fishing industry and by environmentalists, too. Yet, some environmentalists appear to have become confused by what this Common Fisheries Policy reform will mean: Greenpeace has got itself excited that it will result in a wholesale redistribution of quota from the offshore larger vessels, which are mostly in producer organisations, to the small-scale fleet of which only some are in POs. From what we have seen of the CFP text, it means nothing of the sort.
Currently it is the member states’ prerogative how quota is distributed internally and it looks like that’s the way it’ll stay. Ministers already have the authority to redistribute quota and have used their powers from time to time by “top slicing” (extracting quota for redistribution before it is allocated on the usual basis) and “underpinning”, where additional quota is redirected to the under-10m fleet when quotas fall below a certain level.
In its appetite for a simplistic narrative of victims and villains, Greenpeace departs from some important realities. A four per cent share of the national quota, which it claims is the extent of the under-10s chunk, is a good hook for Greenpeace’s emotional propaganda; but as always with Greenpeace, the reality is a little different. Most species caught by the small scale fleet, like crab, lobster and bass, aren’t even under quota. We consider that Greenpeace is exploiting divisions and frustrations in the fishing industry for its own ends and, while it asserts itself as on the side of small fishermen, its ignorance of the industry and issues at hand will damage those it claims to represent.
It is important to challenge Greenpeace fictions as they arise and so we would make the following points:
- The size of a fishing vessel is no guarantee that it is fishing sustainably. Large or small, it is what the vessel does that counts.
- Discards are a challenge for large and small vessels equally.
- Small vessels tend to have limited range. Inshore waters therefore come under greater fishing pressure than offshore areas. A mass transfer of quota from the “industrial” fleet to the small-scale fleet would mean two things: a lot of quota going uncaught, as it would be out of range, and an increase in fishing pressure in the vulnerable inshore zone as new vessels joined the fleet. It would be existing inshore fishermen who are the worst hit – a serious own goal.
- To a high degree, large and small vessels are interdependent. As we have seen with the port of Lowestoft, without a fleet of large vessels, port infrastructures are unsustainable and the small-scale fleet withers. The larger vessels provide the continuity in landings necessary to support marketing and ice facilities.
- Greenpeace considers that gill nets are indiscriminate, bottom trawling destructive and long lines have an impact on sharks and seabirds; this leaves the question: how are we going to catch fish to provide food security for our people?
The inshore fleet does face challenges and some of those challenges relate to quota shortage. However, there is not, as Greenpeace asserts, a generalised quota shortage across the whole under-10m fleet. The shortages are felt most acutely amongst the larger under-10s in the South East and these are best addressed by groups of under-10m fishermen working collaboratively with their local producer organisation. Producer organisations have the direct day-to-day experience of sourcing quota as and when it is needed. Recently, the National Federation of Fishermen’s Organisations (NFFO) successfully brokered an agreement between a number of producer organisations and under-10m fishermen in the South East and Thames Estuary, breaking the preceding deadlock. This was a demonstration that the industry has the capacity to work together and to generate solutions.
Clearly Greenpeace’s reading of the recent CFP reform is different from ours. But to be clear, UK ministers have always had the power to redistribute quota through top-slicing and under-pinning and in that regard nothing has changed. Moving on from these reforms, our preference is for the industry to work together to alleviate quota shortages as they arise and the NFFO will continue tackling disputes with this proven approach of cooperation and collaboration.
Barrie Deas
Chief Executive, the National Federation of Fishermen’s Organisations
The final text is of course a compromise between the Council, the Commission and the European Parliament and sometimes exhibits the lack of coherence that comes with that territory.
Regionalisation
All now depends on the enthusiasm and diligence of the main players, but there is now a legal framework for much of the content of fisheries management in the future to be undertaken at regional seas level, with relevant member states working closely with the advisory councils. This is the keystone of the reform, from our perspective.
Maximum Sustainable Yield
Mandatory MSY targets are set in terms of fishing mortality with biomass targets aspirational. This makes sense in terms of the biological realities. There is also recognition of the potential for problems with “choke species” that could prevent uptake of the quotas main economic stocks.
Discards
A landings obligation will impose major transitional stresses on many parts of the industry. Much now depends on whether the legislative changes that provide the industry with flexibility to operate viably within the context of a landings obligation are enacted. For example, scope to return to the sea species with high survival rates is a critical issue both in terms of overall mortality rates and industry practicalities.
Quota
Member states retain their prerogative to allocate quota as they consider appropriate, with some additional reporting requirements on the criteria used (economic, social, environmental).
Fish Recovery Zones
Optional provisions to use closed areas for stock rebuilding purposes are included but it is difficult to see this as a change of any substance, given the caveats and qualifications with which the provision is surrounded. Closed areas should be a management tool when they make sense, not presented dishonestly as a kind of magic wand to wave to solve all problems.
Summary
More detail will doubtless emerge but the overall shape of the reform is now becoming clearer.
It is important however, to remind ourselves that in fisheries management, the law of unintended consequences is never far away and that legislation is one thing and successful implementation is something else. In this context, the arrival of a significant element of regional control over the substance of fisheries management is vitally important. Hopefully there will now be scope to adapt to changing circumstances more rapidly than the old discredited form of centralised control through blanket measures.
Time will tell.
Dear Will Hutton
I presume that like many commentators who have written about the reform of the Common Fisheries Policy you use the term “industrial” as a synonym for “evil”.
Consider this:
1. The size of a fishing vessel is no guarantee that the vessel large or small is fishing sustainably. It is what the vessel does that counts.
2. What makes you think that only large vessels discard? (See above).
3. Small vessels tend to have limited range. Inshore waters therefore come under greater fishing pressure than offshore areas. A mass transfer of quota from the “industrial” fleet to the small-scale fleet would mean two things: a lot of that quota would go uncaught as it would be out of range and secondly, there would be an increase in fishing pressure in the vulnerable inshore zone as new vessels joined the fleet. Existing inshore fishermen would be the worst hit – a serious own goal.
4. The UK, like many other European countries, has a diverse fleet in terms of target species, method of fishing and size of vessel. To a high degree, large and small vessels are interdependent. As we have seen with the port of Lowestoft, without a fleet of large vessels, port infrastructures are unsustainable and the small scale fleet withers. The larger vessels provide the continuity in landings necessary to support marketing and ice facilities.
5. Although not the subject of media attention, the most important part of the CFP reform is a move away from centralised control towards regional management by cooperating member states. An over-centralised, top-down command and control approach has been the root failure of many EU conservation initiatives.6. You berate the UK for supporting a 5% discard de minimis but Norway which has had a discard ban in place since 1987, and which has much less mixed fisheries than the EU, still has discards scientifically estimated in the region of 15%. In mixed fisheries, flexibility is the key to minimising discards.
This Federation represents all fishermen and sizes of vessels. We are working with producer organisations and groups of under-10 metre fishermen to address quota shortage issues where they arise.
I know that in your article you were making a general point about press coverage of the EU but using fishing as the simplistic pantomime villain in the kind of narrative which we are now all too familiar, and of which your comment last Sunday is an example, is really unhelpful.
Yours sincerely
Barrie Deas
Chief Executive
Fisheries directors from North Sea member states are scheduled to meet in Copenhagen next week to flesh out how regional cooperation in the North Sea will work in practise. And in Dublin a meeting convened by the North West Waters RAC will work on how a regionalised CFP could reinvigorate moves to put cod recovery in the Irish Sea on a more positive footing.
There are a number of aspects of the political agreement reached in Brussels, and announced with great fanfare last week, that remain unclear on the details – so far no consolidated text has appeared. Nevertheless, we know enough to see that permissive powers for regional cooperation between member states, working closely with regional advisory councils, have been agreed, even if the route for implementing regional seas recommendations will tread familiar legislative paths.
Much will depend on the enthusiasm and skill with which member states and RACs approach regional management.
The early engagement by fisheries directors and the RACs in the regionalisation process are therefore positive signs. The NFFO has said for some time that the key to effective management decisions is getting fisheries managers, fisheries scientists and fisheries stakeholders into a room together, working collaboratively. The steps being taken in Copenhagen and Dublin represent in their different ways important aspects of the new approach.
The Dublin meeting, which will be attended by fisheries stakeholders, representatives from the member states and fisheries scientists, will hope to put in place the Irish Sea “Cod Audit”, first called for by the industry in 2006.
The stock development of cod in the Irish Sea is apparently bucking the positive trends seen widely across the North East Atlantic and the priority must be to identify the reasons why. A review of the science and management measures is therefore the first step in putting things on the road to recovery. At present we don’t know whether it is ecosystem changes, something in the fishery, or shortcomings with the assessment that lies at the heart of the problem. The Dublin meeting will hope to kick start the review process and is as significant in its own way as a stakeholder-led process, as the Copenhagen meeting is at government level.
Similar initiatives involving regional cooperation are already underway in the Baltic and it is clear that within the CFP a decisive step away from over-centralised, top-down, micro-management has been taken. The challenge now is to ensure that this momentum continues and that well thought-through regional management plans will soon emerge to replace the one-size-fits-all measures currently in place. Those in the centre – the Commission, the Council of Ministers and the European Parliament have a duty to nurture these young shoots, to ensure that regionalisation delivers its full potential.
The conference is hosted by the Norwegian Government, in cooperation with the Secretariat of the Convention on Biological Diversity (SCBD), the United Nations Environmental Programme (UNEP), the United Nations Development Programme (UNDP) and the Food and Agriculture Organization of the United Nations (FAO).
In the past we have seen many conservation initiatives emerge from such high level conferences and so it is absolutely essential that fishermen’s views are heard where and when it counts.
The NFFO was able to reinforce the point that sustainable use of the marine environment rather than a purist environmental agenda should be the goal for fisheries managers, environmentalists, and the fishing industry together.
We were also able to make the point that passing legislation is one thing but successful implementation of conservation measures is something else. The history of the Common Fisheries Policy until recently has been one in which all the emphasis has been on the former, with insufficient attention to the latter.
Measures are most successful when they are considered legitimate by the people to which they apply. Achieving this in fisheries requires a collaborative approach through industry participation in the design of measures and good information on which to base the measures. The Federation was able to describe to the conference the many positive initiatives than make this collaboration a reality. Including:
- Fisheries Science Partnerships
- The work of the regional advisory councils
- Precise mapping of fishing activity using fishermen’s own electronic plotter data
The full text of the NFFO’s presentation is reproduced below:
Trondheim Conference on Biodiversity
Marrying fisheries and environmental concerns
A Fishing Industry Perspective
Barrie Deas
National Federation of Fishermen’s Organisations
Good afternoon.
My task today is to provide you with an appreciation, from a fishing industry perspective, of the concerns and challenges that an ecosystem approach raises in terms of the integration of fisheries and environmental policy.
The fishing industry broadly recognises and accepts that fisheries must be embedded within a fully functioning ecosystem if it is to have a long term sustainable future. The pressures on commercial fish stocks (exploitation rate) must be managed but equally, the pressures on non-target species and habitats also must be contained.
I think that it is true to say that the principles and broad objectives in this regard are largely agreed. But the means of achieving them are often not agreed. And it is this that I would like to concentrate on today.
My experience is principally derived from the European Union’s Common Fisheries Policy but also the management fish stocks that are shared and jointly managed with countries like Norway.
Common Fisheries Policy and Environmental Protection
Many of you will be aware that fisheries management involves a challenging mix of biology, economics and politics. Within this context the CFP has become a byword for policy failure. Good intentions have repeatedly been difficult to translate into effective action. Although fishing mortality on a broad swath of socks has now been brought down’ this has been done in a rather chaotic and brutal way.
As society’s expectations have changed about what is acceptable (and not acceptable) in terms of the environmental impact of fishing, there has often been a clear disconnect between aspiration and delivery.
However, over the last fifteen years, I think that it is true to say that a shared analysis and emerging consensus has emerged towards resource management generally which understands that a top-down, command and control policy approach is unlikely to succeed. Trying to manage multiple, diverse, fisheries across many degrees of longitude and latitude through prescriptive micro-management is likely to fail to deliver its objectives. So we have learnt the hard way that passing a piece of legislation is one thing. Successful implementation is something else.
In addition other lessons have been learnt which in recent years has required a shift in focus from:
- Managing commercial fish stocks on a single stock basis,
- Towards a broader understanding of the dynamics and challenges of managing mixed fisheries,
- To managing fisheries by taking into account species interactions
- To a full ecosystem approach which understands fishing in its broadest context.
Some progress has been made but most scientists and policy makers, and certainly the fishing industry, recognise that even in the first steps towards these objectives, this work are in their infancy.
The other strand in this picture arises from EU environmental obligations (in particular the Marine Strategy Framework Directive and the Habitats Directive) which place obligations on member states to achieve good environmental status including protection for vulnerable marine sites and species. The wheels are now turning to implement this legislation by agreeing and applying operational programmes.
Within these programmes, there is still some room for discussion about how the concept maximum sustainable yield can be applied in mixed fisheries; and whether a stock structure within a dynamic system can be measured, let alone controlled. Nevertheless, there is, I think, a broad consensus that it is wise to fish stocks in the region of MSY. Likewise there is broad agreement that it is sensible to ensure that a good proportion of fish reach sexual maturity. Similarly, there would be few who think that the integrity of the seabed is not a matter of concern.
In other words there might still be some manoeuvring about precise definitions on these questions but not the fundamentals.
It is not therefore the destinations that have been controversial but rather the means for achieving those objectives.
CFP Reform and Environmental Sustainability
The EU Court of Auditors has not been the only body to criticise (mistakenly in my view) the failure of EU fisheries policy as just a failure of political will. I think the Prof. Elstrom was correct when she said that resource management is much more likely to succeed when those resources are in the hands of those which depend on them. Of course, in the context of a resource like European fisheries, in which the scale can be large and where ownership is shared between different countries, this type of management is much more challenging than in a small scale unit where all the players are known to each other. But there have been significant developments. I would like to discuss three:
- Regional advisory councils (stakeholders organised at the regional seas scale)
- Fisheries science partnerships (where scientists work closely with the fishing industry)
- Modern communication technology (from CCTV to plotter data linked to seabed mapping)
Regional Advisory Councils
The scale (regional seas), the composition (all relevant stakeholders) and purpose (to provide decision-makers with informed advice on fisheries management issues – puts RACs in a strategically pivotal position to shape policy formation – even more so with the greater regionalisation anticipated within a reformed CFP.
Fisheries Science Partnerships
FSPs of all shapes and sizes have blossomed over the last 15 years and fishermen and their representatives can be found engaged with scientists at the highest levels of ICES, likewise scientists, working collaboratively aboard fishing vessels, is quiet common now.
Modern Communication Technology
It is now possible to find fishing vessels in a number of member states which have voluntarily installed CCTV cameras to monitor catches and to confirm that discard levels are minimal. Whilst avoiding a big brother approach, it is possible to use various different kinds remote sensing to provide fully documented fisheries and to therefore as a quid pro quo, remove much of the prescriptive micro-management through insanely detailed legislation that have hampered our efforts.
What all this amounts to is a revolution in governance. It is a revolution that is only partially complete and it is both possible that it can regress or it move forward rapidly.
It is my contention that this revolution lays the foundations for a much more effective integration of fisheries and environmental objectives because fundamentally it leads to different types of collaboration at different scales and spatial levels and therefore the realization of Olstrom’s ideals.
For example:
- Using very precise electronic plotter data provided by the skippers of fishing vessels fishing activity can be mapped with great accuracy. This is of critical importance to ensure that marine protected areas are in the right place to protect vulnerable marine ecosystems and features. (But it requires a high degree of cooperation to obtain this commercially sensitive data)
- Collaboration can address data deficiencies and strengthen the accuracy of fish stock assessments and therefore their credibility in the eyes of fishermen (RAC initiatives)
- Progress can be made in reducing discards by aligning economic incentives with management objectives and working collaboratively, fishery by fishery (This requires close collaboration)
- Regional management offers the possibility, not just to apply measures that are tailored to the characteristics of the fleets, but to adopt an adaptive and responsive approach in which errors can be quickly rectified ( Fundamentally, regional management should be about the close collaboration of three groups: fisheries managers, fisheries scientists and fisheries stakeholders)
- Multi-annual management plans developed collaboratively with stakeholder involvement throughout
So far as commercial stocks are concerned, in many ways we are moving to reversing the burden of proof in fisheries. If a vessel operator can demonstrate that its total catches are all accounted for and those catches are within the permitted mortality, there is scope to remove some of the for the immense burden of legislative micromanagement which burdens fishing and so often generates perverse outcomes -A win/win outcome.
But I believe that a collaborative approach can go beyond a relatively narrow fisheries management role and be equally relevant for example, for the designation of marine protected areas, where, as we have learnt displaced fishing activity can do more harm than good if not carefully managed.
Environmental Policy and Governance
The point I have been labouring here is that after two decades in which initiative after initiative in resource management in European fisheries delivered much less that hoped for, progress is now being made in putting fisheries management on a more rational basis.
The key is governance arrangements and the question posed in terms for the integration of fisheries and environmental legislation, is whether we have to learn through the same difficult process or whether we can fast forward to more successful delivery arrangements.
Olstrom’s concept of nested or concentric rings of responsibility seems particularly relevant here. Setting broad objectives and standards set at the European level through the democratic but cumbersome co-decision process has an undeniable logic and coherence. As an industry our (bitter) experience suggests that all content and delivery detail below this, on should be left to the regional level, or if possible lower levels; with the higher level limited to playing a monitoring or supervisory level.
Integrated multi-annual management plans, will provide the vehicle for fisheries management in the future and also for the integration of fisheries and environmental policy. But if these are simply laid down from on high we will face the same implementation problems as the current CFP has had to confront.
Regional management should help. Cooperation between member states with the close involvement of the regional advisory councils, in the development of long term plans is the key. And where stocks are shared, new ways of working ways of working with Third Countries like Norway, at regional seas level must be found.
But although getting the governance arrangements right is absolutely fundamental to an effective fisheries policy it is not the only challenge:
Fisheries scientists will be required to deliver advice not just on mixed fishery basis but taking into account multi species interactions. There will have to be trade-offs between environmental protection and the economic viability of the fleets; there will have to be trade-offs between the quotas set for different stocks to achieve an overall balance (which will be controversial because of the economic interests attached to the respective stocks).
Understanding Maximum Sustainable yield as a range of values on the effort /yield curve rather than as a fixed point will make these kind of trade-offs easier; as will addressing potential choke species by limiting the main TACs to only the economic driver species, with by-catch placed under a basket quota, in the way we do now with “Norway Others”.
We hope that taking this kind of approach, Good Environmental Status will be achieved in a pragmatic, incremental, proportionate and balanced fashion.
The danger however must be is that this will pragmatism will be overtaken again by the temptation to see central legislative control, backed by sufficient political will, as the solution. Having just been given co-decision powers there must be a temptation for the European Parliament to flex its muscles to resurrect micro-management.
And all this does not forget that aspects of these policies must be negotiated with Third Countries like Norway, especially in relation to setting TACs. In this regard the North Sea RAC has already made approaches to the Norwegian Fishermen’s Association to lay the foundations for future cooperation on the development of comprehensive long-term management plans which incorporate environmental concerns. The meeting was held only a few streets away from here and established shared concerns and issues.
This is a good example of the potential of a collaborative bottom up approach by comparison with the top-down command and control approach.
I leave you with this graph which illustrates the dramatic fall in fishing mortality (fishing pressure) across all of the main species groups in the North East Atlantic, with a clear turning point around the year 2000, after 70 years of incremental increases. There will be many intertwined causal factors to explain this trend. But certainly as far as the European Union component of these fisheries is concerned, I believe that the beginnings of a move to more effective models of governance, the development of fisheries science partnerships and the wider application of long-term management plans are important contributory factors.
Management measures will only be fully effective if they are perceived as legitimate by the stakeholders. This is not an optional extra. The history of the CFP has been a crisis in legitimacy. Having learnt this lesson in relation to the management of commercial fish stocks it is important that we use its insights in the complex task of building a fully integrated ecosystem approach.
IFCAs and the MMO are commencing consultations with respect to conservation features deemed highly vulnerable to certain types of fishing activity for coastal waters sites (<12nm of the coast). The approach is being pursued by the management authorities in cases where assessments have not previously been completed and management applied following site designation.
This is in line with a revised process for English waters initiated by Defra last September which followed the threat of legal challenge from the NGOs ClientEarth and the Marine Conservation Society. The intention is to introduce management measures for features deemed highly vulnerable, so called “red” risk features, by the end of 2013. For those deemed as “amber”, more detailed assessments are planned with any associated management introduced by the end of 2016. Details of the revised approach can be found on the Marine Management Organisation’s website at:
http://www.marinemanagement.org.uk/protecting/conservation/ems_fisheries.htm
Dale Rodmell, Assistant Chief Executive of the Federation said: “The process must allow for evidence to be brought forward in order to corroborate the locations of features so that management boundaries do not unnecessarily impinge on fishing areas.”
“It is vital that management makes practical distinction between areas with the types of ecology that would be vulnerable to any new fishing incursions from those areas that have been fished extensively and have ecology that continues to exist in the presence of that activity. In such cases, fisheries that may have existed for decades or more must be recognised and special care taken to avoid unnecessary impacts to livelihoods.”
“NGOs who claim to be supporters of the livelihoods of inshore fishermen or wish to understand the local issues at a specific site ought to be able to recognise the reasonableness and common sense of such an approach and refrain from any abstract legal response to European Directives that are widely regarded as containing significant flaws.”
The collapse of the distant water fleets, in the wake of the cod war with Iceland, was echoed a generation later further up the coast in Bridlington, Scarborough and Whitby with a decline in vessel numbers associated with the failures of the Common Fisheries Policy (CFP).
However, the agreement reached by the Council of Ministers in Brussels in the early hours of Wednesday (15 May) represents an important staging post on the tortuous passage to CFP reform. While the discard ban has dominated the debate around the CFP reforms, the much more important issue for fishermen working at sea on a daily basis is the now achievable goal of decentralising decision making from Brussels to a regional level.
Until now, there hasn’t been significant recognition of the importance of regionalisation but we welcome the Council’s acknowledgement that the current system of prescriptive micromanagement has failed. We see this as a vital first step to promoting decision making which is fairer and more flexible for each member state on a regional level whilst still ensuring seafood remains a sustainable, traceable food source.
Yorkshire confidence is rising, as evidenced by the new fuel efficient, 26 metre trawler Our Lass being built at the nationally successful Parkol yard in Whitby for President of the National Federation of Fishermen’s Organisations, Arnold Locker and his son James.
After successive years in which quotas were cut and cut again, last year saw a 15% increase across all the main whitefish stocks for the second year in succession as the whitefish stocks of cod, haddock, coley and plaice have rebuilt. The recovery of plaice has been nothing short of meteoric, beyond anything seen in the historic record. Scientists confirm that since 2002 there has been a “dramatic reduction in fishing pressure” right across the North East Atlantic and whitefish, including the North Sea stocks, are rebuilding rapidly. The experience on the Yorkshire coast reflects these general trends.
Shellfish fishermen have been keen not to repeat the experience of the whitefish industry and point to the fact that they have had one huge advantage: every crab or lobster returned to the sea survives to be caught later as a bigger animal. The lack of a discards problem supplemented by minimum landing sizes gives the shellfish sector an advantage, but the fishermen are not complacent and discussions are underway with the Government on sensible conservation measures that have the backing of the industry. Organisations like the Holderness Coast Fishermen’s Association, part of the NFFO, take conservation and working with fisheries scientists very seriously.
In fact there has been a remarkable transformation in the relationship between fishermen and fisheries scientists over the last ten years. Once there was a mutually hostile attitude driven by falling quotas and adversarial attitudes, now scientists can often be found aboard commercial fishing vessels as part of the Government funded Fisheries Science Partnership. There is a new respect for the kind of knowledge held by fishermen which is used to strengthen the more conventional fish stock assessment methods.
Fishing has always been a fluctuating business as the fortunes of target species waxed and waned and markets did likewise. A boom in whelks in the 1990s has been followed by remarkable years in the crab and lobster fisheries, with Bridlington becoming the preeminent crab and lobster landing port in England. One of the biggest fears within the fishing industry on the Yorkshire Coast is the loss of access to traditional fishing grounds through competition for space by a range of offshore activities and marine protected areas. Offshore wind-farms, oil and gas, aggregate dredging and displacement of fishing activity from marine conservation zones can affect a fisherman directly or indirectly by knock-on effects. It’s not as though fishermen think that they have a monopoly on the sea or the seabed, it’s the sheer scale of some of the projects and the Government’s belief that fishermen can just move aside. The NFFO is a strong supporter of MPAC, the Marine Protected Area Fishing Coalition, which aims to give fishermen a voice in the design and location of marine protected areas.
Yorkshire owned and crewed vessels can now be found fishing in the Norwegian sector of the North Sea and landing into the Scottish port of Peterhead. Migration to the best fishing grounds and landing into the best markets is nothing new.
Fishermen from Yorkshire were involved in establishing the NFFO in the 1970s to deal with the looming Common Fisheries Policy and they remain a strong presence on the national stage. The NFFO’s President is from Whitby, the Chairman of its Shellfish Committee is from Bridlington. Fishermen from Yorkshire can often be found at international meetings in Norway, Brussels, Amsterdam and Copenhagen. Fishing has become highly political and it is only by ensuring that the regional voice is heard in the corridors of power that its future can be secured.
The agreed form of words gives the Irish Presidency a mandate to finalise negotiations with the European Parliament on the final shape of the reform package. Unless the European Parliament creates new obstacles, there could be a political agreement on the reform within days, although the formal legal text could take a further three months to finalise.
The Council endgame focused on two items which the Parliament, under enormous lobbying pressure from the green NGOs, had picked out as signifiers for the depth of the reform: Biomass MSY and rules to cover exemptions from the discard ban (de minims). There was also a struggle over the provisions permitting the content important decisions to be made are regional seas level.
Regionalisation
The key to the whole CFP reform lies with the shift from a top-down, centralised approach to regional decision-making, although it would be difficult to discern this from a media which has been primarily focussed on the discards issue. A shift to a decentralised and therefore more flexible and adaptable management regime is the prize now within our grasp. Much remains to be done to bring regional decisions into effect but the Council has paved the way for what may turn out to be a revolutionary change.
The Commissioner conceded at the beginning of the Council that the Commission’s lawyers’ version of decentralisation where the Commission itself would receive additional delegated powers would not fly. The main model of regionalisation within the CFP will be that of member state cooperation at regional seas level described in the Council’s previous General Approach.
Biomass MSY
This arcane issue became an problem for the Council when the Parliament insisted that it was not sufficient to bring fishing pressure (fishing mortality) down to levels consistent with rebuilding fish stocks to maximum sustainable yield; it would be necessary to require binding targets with timetables to ensure that MSY levels were reached. This is tantamount to telling nature to conform to the EU’s wishes, as many non-human factors can and do affect recruitment. The Council has quite rightly rejected this as based on biological illiteracy and has replaced it with some aspirational words. Of course, the purpose of reducing fishing mortality is to build fish stocks but the type of binding requirements wished for by the Parliament are exactly the kind of rigidity that caused so much difficulty in the EU Cod Management Plan.
Discards Ban
It has been clear for some time that the Commission, Parliament and Council want a landings obligation, broadly similar to that operated by Norway that would lead in due course to the elimination of discards in EU fisheries. The issue for the Council was to create sufficient flexibilities to allow this to happen across a wide range of fisheries. Issues such as quota uplift, the removal of CFP rules that currently generate discards, yearend quota flexibility and counting minor species against principal quotas to remove choke stocks, all appeared to be uncontroversial. Heat was generated between the Council and the Parliament and within the Council itself on the issue of the de minimis – the amount of fish that fleets could continue to discard. Bearing in mind that even Norway (which first applied a landings obligation to cod in 1987 and has much simpler fisheries than the EU, with fewer species) still discards significant tonnages. The issue here is how to create a pragmatic approach that secures a dramatic reduction in discards without ham-stringing the fishing industry with unworkable rules. Time will tell whether the Council have got the balance right. Essentially, the de minimis will only come into effect if all the other discard reduction initiatives within a multi-annual management plan, or a discard plan have failed and oversight of the conditions in these circumstances have been handed to the Commission.
Conclusion
If the reform package follows the lines agreed by the Council there will still be rigidities and perverse outcomes within the CFP. However the agreement, particularly with regionalisation, has built in both a safety net and means to improve the management regime over the next few years. A more adaptable CFP should mean a better CFP. Time will tell.
UK Fishing Bodies Launch Initiative To Promote Safety At Sea
Leading names within the UK fishing industry have united to promote greater safety at sea by providing more than 6,000 subsidised ‘personal floatation devices’ to fishermen across the UK.
While overall, accidents within the industry have reduced over the last 15 years due to better training and equipment, life as a fisherman remains one of the most dangerous of professions, with ‘person overboard’ incidents still being the main cause of death.
The joint initiative is being run between the NFFO, which represents fishermen’s groups, individual fishermen and producer organisations in England, Wales and Northern Ireland, and the Scottish Fishermen’s Federation (SFF). Additional funding has been provided from the European Fisheries Fund (EFF), Marine Management Organisation (MMO), the Northern Ireland Department of Agriculture and Rural Development (DARD) and Seafish. In Scotland, the initiative will be funded by a donation in excess of £130,000 by the SFF via the Scottish Fishermen’s Trust, along with £10,000 from the UK Fisheries Offshore Oil and Trust Fund, and significant additional support from the Scottish Government.
The project involves issuing fishermen with compact ‘personal flotation devices’ (PFDs) which have been carefully selected as they are lightweight, easy to wear and provide protection without impeding the movement required by an active fisherman on deck.
According to the NFFO and SFF, traditional lifejackets, which are much bulkier than PFDs and are constantly inflated, can be cumbersome and perceived as constituting a hazard to safe operations. This means they are often only worn in an organised vessel abandonment situation and not all the time, which can prove fatal in the event of someone going overboard. The project aims to encourage the wearing of PFDs all the time at sea, to combat the threat.
Chairman of the National Federation of Fishermen’s Organisations, Paul Trebilcock, said: “Working in the fishing industry is traditionally seen as very dangerous, and this is the latest in a range of initiatives we have delivered to enhance safety levels for those working on the front line, where most accidents occur. We try to encourage people to take ownership of safety on deck by ensuring they always have correct, well maintained equipment and that their training is to a high standard.”
Derek Cardno, SFF Safety Officer, said: “This exciting initiative is all about raising the overall safety awareness in the industry and we encourage as many fishermen as possible with the correct certification to participate in the scheme and, without cost being an issue, ensure they are equipped with high quality personal flotation devices.”
The different organisations involved in the project are using a range of distribution methods to ensure as many fishermen as possible receive the PFDs. The NFFO initiative dictates that the PFDs stay with the boat to which they are donated, ensuring the longevity of the project and spreading its benefits to generations of fishermen to come. Meanwhile, those distributed by the SFF are given to individual fishermen encouraging them to take control of their own safety.
Since the NFFO Training Trust was formed in October 1999, £845,531 has been donated to fishermen in training grants and safety equipment.
The purpose of the meeting was to lay foundations for future cooperation on the development of common long term management plans for fisheries jointly managed by the EU and Norway.
Second generation management plans will go beyond a simple set of harvest control rules and quota setting protocols, to include both economic and environmental features of the North Sea demersal fisheries. The strengthened regional dimension to decision-making within the reformed CFP, and the understandings reached at the Svalbard Seminar about the centrality of stakeholder involvement, both point towards the need for much greater dialogue between fisheries stakeholders in the EU and their counterparts in Norway. The NSRAC, therefore, took the initiative to meet the principal representatives for Norwegian fishers on their home territory to get things started.
The meeting identified a large area of overlap where NSRAC and Norwegian concerns and interests coincided. How to manage mixed fisheries within the context of commitments to fish at or above maximum sustainable yield was top of both lists of priorities.
The Norwegian experience of implementing a discard ban (beginning in 1987 with cod) was discussed against the background of the EU’s proposal for the phased introduction of a landing obligation beginning on 1st January 2014. It was concluded that some aspects of the Norwegian experience were very relevant to EU fisheries but others were not. It was noted that the Norwegian discards ban was a step in a process which started with awareness of selectivity and a package of incentives. The ban was only implemented after a process of some years. Opposed to this the EU process will have the discards ban as a starting point. It was agreed that the Norwegian context was very much simpler than the EU, not least the fewer number of species involved.
Both the NSRAC and the Norwegian fishers had had parallel experiences of a radical shift in the industry’s relations with fisheries science and fisheries scientists over the past 10 to 15 years. A variety of factors were relevant but the same picture of closer cooperation emerged. The NSRAC was particularly interested in the Norwegian reference fleet, through which sampling onboard commercial vessels is used to complement and strengthen the more conventional ICES stock assessments.
Both parties recognised that whilst transparency and cooperation were a common goal, the annual reciprocal fisheries agreement between EU and Norway was based on a complex set of negotiations that would sometimes place constraints on the flow of information. Nevertheless, the RAC and Norges Fiskarlag were both of the view that much could be achieved by finding new ways to cooperate. It made no sense to work on long term management plans separately only to present the finished article for endorsement. That was a recipe for misunderstandings, conflict and confusion.
The RAC and Norwegian Fishermen’s Association will now consider the form through which cooperation will take place in the future. But the foundations have been laid for what hopefully will be a productive and constructive relationship in the future.
Federation presses for workable rules
The Council of Ministers meeting in Brussels on 13th and 14th June could turn out to be a pivotal point in the reform of the Common Fisheries Policy. Amidst signs of a willingness by the European Parliament to make meaningful concessions to reach agreement, and the Irish Presidency ‘s determination to forge a deal, the odds now appear to be in favour that the Council will agree a revised negotiating mandate.
However, important issues remain to be settled, not least on regionalisation, the discards ban and maximum sustainable yield. The European Parliament, which has no responsibility for implementing the agreed measures, has tended to be rather doctrinaire on these issues, whilst the member states and even the Commission, do seem to have some awareness that legislating is the start of a process not the end.
An NFFO delegation will travel to Brussels for the Council and will brief Fisheries Minister, Richard Benyon, on the industry’s priorities throughout the negotiations. Above all, the Federation will stress that what is agreed must be workable and practical. Obliging fisheries managers and fishermen to achieve MSY biomass targets when these may be influenced as much by nature as by fishing is to fail to understand the basics of fisheries science.
Likewise, unless practical and realistic ways of implementing a landings obligation are made available, the result will be a confusing car crash of regulation which could produce as many perverse as positive consequences. This has been the central lesson from the last 20 years of the Common Fisheries Policy. Although, it has not been one of the CFP reform issues hogging the media spotlight, effective regionalisation of decision making is the key to a move to a more responsive, adaptable and therefore effective policy.
Member states cooperating at regional seas level, working closely with the regional advisory councils on the content of multi-annual management plans, offer a much brighter future than the top-down approach that we have struggled under to date. It is crucially important that the reform provides an adequate legislative permissive form for this to happen, even if the decisions then have to be endorsed by the cumbersome co-decision process, or powers delegated to the Commission.
The Committee:
Reviewed progress on engagement with eastern Irish Sea wind farm developers and proposed draft terms of reference for the West of Morecambe Fisheries Fund industry advisory group.
- Reviewed the status of other sources of funding available to the north west industry.
- Reviewed the status and progress on Marine Conservation Zones and European Marine Sites including responses to the proposed Fylde Offshore and Wyre and Lune MCZs.
- Resolved to explore opportunities to enable regional community quota management for the under 10 fleet with Defra and the MMO.
- Approved an application to support an ice plant project for the Barrow and Furness Fishermen’s Association.
- Reported on the status of the North West discards trial project that the Committee is conducting with Cefas, and on the Committee’s work to secure appropriate gear selectivity measures suited to the over 10 Irish Sea English nephrops vessels under the Cod Recovery Plan. Chairman of the Committee Ron Graham said: “The Committee continues to provide the focal point to address the myriad of issues, threats and opportunities facing the North West English fishing communities. It is only through a coordinated and collective approach that we can secure change for the benefit of our local industry, whilst successfully defending our interests.” (Photograph: West Coast Committee Chairman, Ron Graham)
The most recent tranche of money from the Trust to ANIFPO will support the following projects:
- Installation of multi-media & IT equipment to aid the delivery of training courses (to assist online training for fishermen and upgrade visual training aids)
- Assistance with the delivery of 45 Safety Folders (to follow through on commitment made to MAIB following Zenith tragedy)
- Provision of a pilot personal health and training course x12 (to assist fishermen in the prevention of back/strain injuries)
- Delivery of a ‘train the trainer’ course for 7 people (to increase the number of available Seafish approved trainers in NI)
Since the NFFO Training Trust was formed in October 1999 £845,531 has been donated to the fishing industry via grants for fishermen’s training and safety equipment.
Under-10m fishermen from Harwich, West Mersea, Ramsgate, Folkestone, Dungeness, Rye and Selsey met in London with representatives from nine producer organisations.
Barrie Deas, Chief Executive of the National Federation of Fishermen’s Organisations, said:
“The meeting was a response to the failure to make headway on the under-10m quota question and to move beyond the name- calling and confrontational climate that has dogged the issue and in my view hampered a solution.”
“It was an opportunity for the industry to demonstrate that it has the capacity to work together and to generate solutions that have apparently been beyond Government. The discussion was focused on getting out of the quagmire through cooperation, collaboration and using the right tools for the job.”
The agreement that has emerged from the meeting has a number of important elements:
- A focus on the real quota pinch-points in both the North Sea and Eastern Channel: skates and rays, sole, cod, and at some times of year lemon sole and plaice. There is a recognition that the problem with Channel cod lies beyond domestic quota management rules and so any solution likewise lies elsewhere
- A recognition that all under-10s are not all alike: The higher catching under-10s need access to significant amounts of quota, whereas there are many vessels targeting non-quota species that work well most of the time within the existing pool system
- The success of the Ramsgate/Dungeness quota pilot in providing the participants with more flexibility, ability to plan the fishing year and additional quota through swaps and transfers, illustrate the benefits of this type of group arrangement, even if the basic track record quotas do not look that promising
- The producer organisations made the point that with professional quota management advice and support the pilot vessels could have been in an even stronger position and offered their assistance to under-10m groups affiliating with POs
- An offer by the POs to provide affiliate status to under-10 groups which approach them for support. This support would take the form of assistance with quota swaps and transfers and other aspects of professional quota management that PO members currently benefit from
- The identification of available quota within the system that could be accessed for the benefit of the affiliated under-10s
- The issue of latent capacity is a real one: Substantial increases in monthly pool allocations would inevitably draw in fishing capacity that is currently dormant or at a very low level, with no overall benefit for the existing vessels operating in the pool
- It was agreed that the NFFO should put its weight behind representations to Defra/MMO for the continuation of the Ramsgate pilot which is due to end shortly.
Barrie Deas added: “Our perception, from an early stage was that the problems facing the under-10m pool were largely because the pool arrangement was not designed to accommodate the high-catching under-10s. Drawing this category of vessel into a collaborative arrangement with the POs, and working on a group basis, should certainly benefit those vessels but it should also leave the pool in a more stable position.
“Hopefully, the meeting has laid foundations for an improvement in the quota situation for the under-10s in the South East, where it is acknowledged that the problem is at its most acute. This was a very positive, constructive and above all forward looking meeting. There are now options where there were very few before, as well as a model of how to improve your lot as an under-10 if you are highly dependent quotas species: Get into a quota group; work closely with a PO of your choice; work with the quota managers in the POs to maximise the quota available to your group.”
“It was clear from the meeting that the producer organisations have a considerable interest in ending the turbulence in the under-10m sector and there was concrete evidence at the meeting of their willingness to assist the under-10s.”
We have had our issues in the past with WWF, when its Brussels European office has overridden the good work of their field officers in the RACs to make ill informed pronouncements on TACS and quotas. But within the RACs, WWF has earned respect for its consistently positive, constructive and informed contribution. The high calibre of its field officers has allowed the organisation to carry much more influence in shaping RAC advice than its numbers would suggest.
As well as playing its role as an NGO in challenging the fishing industry to step up to the mark on sustainability, WWF has played an important role in defining RAC approaches to long-term management plans, regionalisation of the CFP, the significance of an ecosystem approach and marine spatial planning to name but a few. Without this considered input, RACS will be poorer, just at a time when their role is about to be enhanced under the CFP reform.
We have no knowledge of WWF’s funding or the internal politics that may lie behind the decision to withdraw from the RACS. But what has become apparent is that there is now a large body of environmental NGO lobbying activity that takes place away from the formal consultative bodies aimed directly at the Commission and the European Parliament, with the aspiration of shaping the CFP from the top down. We have previously observed the breathtaking sums of money channelled through charitable foundations to secure such outcomes.
It may be that WWF has concluded it is more cost-effective to lobby the Commission directly and to target MEPs, than it is to work collaboratively with the fishing industry and other stakeholders, via the RACs. What we do know from experience however is that the bodies which choose to work outside the collaborative, RAC framework tend to have top-down mindsets which generate an adversarial atmosphere. Greenpeace have never made any secret of their contempt for working cooperatively and are much happier flinging poorly researched tirades from a distance – ultimately making no meaningful contribution. Even more thoughtful bodies, such as the Pew Foundation, carry a large office with many staff in Brussels, all working to influence the Commission and the European Parliament, yet staying well clear of the RACs, which by definition require stakeholders to engage with each other.
It seems to be a sign of the times that NGOs are putting their resources into lobbying the Commission and European Parliament as a more cost effective way of wielding influence – but this will directly undermine the collaborative stakeholder approach that lies at the heart of RACs.
The Commission in particular must ask itself some searching questions: has it, by providing regular access to environmental NGOs at a very high level, systematically undermined the RACs? After all, these NGOs do not maintain Brussels offices for fun. Apparently, at the same time that the fishing industry has increasingly shifted its representative efforts to the regional level, these NGOs have apparently built up their capacity to fill a vacuum in Brussels.
It may be that the focus on CFP reform has given Brussels lobbying more relevance, even though the reform itself leads to a decentralisation of the CFP and a greater emphasis on regional seas decisions. But the arrival of co-decision and the enhanced role of the European Parliament suggests something much less healthy – a new concentration of power and influence in Brussels.
If this materialises it will not be long before the fishing industry reconsiders its position and concludes that it too needs a stronger voice in Brussels – and we are back to where we started – a top down system of command and control that generates mountains of legislation but fails every test of good governance.
The Irish Presidency is straining every sinew to secure a CFP reform deal. But after a sluggish start to the “trialogue” negotiations between the Council, the European Parliament and the Commission, there are fears that it could run out of time before it has to hand over to the incoming Lithuanian Presidency. The Irish Minister claimed from the chair that the process had been energised with fresh commitments to progress from all sides. However, as CAP reform is also on the agenda and will occupy the June Council, the reality is that a deal has to be put together at the May Council. Even the Lithuanians consider that they don’t have the capacity to handle CFP reform. In any event they will have the European Maritime and Fisheries Fund to deal with on their watch.
The danger in all of this is a Presidency desperate to secure a deal will snatch at any deal on offer, rather than the right deal for fish, fishing and fishermen.
The Council primarily involved a table round in which the member states confirmed or reconfirmed their positions on the main themes in the reform. The UK underlined the importance of a move towards regionalisation of the CFP. An NFFO delegation attended the talks and at meetings with Fisheries Minister Richard Benyon, both before and after the Council, and stressed the importance of a focus on practical implementation issues when framing the reform legislation.