In fact, it is not true to claim, as Charles Clover did recently on the BBC, that the UK/Norway and the EU have set quotas at unsustainable levels, and that quotas are never set below scientific advice. In the case of North Sea haddock, a scientific recommendation to increase the quota by 160% was limited to a 30% increase to protect cod stocks because there is a recognised species interaction. For North Sea whiting, an even more precautionary approach was followed. The scientific advice for a 240% increase was also limited to only 30%. Similar precautionary restraint was in evidence on some Celtic Sea stocks, although most were set exactly in line with the ICES headline advice.
This year’s negotiations were notable for the number of stocks pointed in an upwards direction. This can’t always be the case because there is natural variation in the young coming into the fishery each year and that is governed largely by environmental factors.
So, it is just untrue to say that quotas are increased when the stocks go up but not when they go down. But the big picture is of stocks steadily moving in the right direction, always accepting that there will be some statistical outliers.
It is true to say that the other cod stocks in UK water are at a low ebb but two points, ignored by Blue Marine are salient. There are no directed (targeted) fisheries on these stocks, and so fishing pressure on them is very low. Quotas are set at the lowest possible level consistent with unavoidable bycatch in other important fisheries.
The second point is that the science suggests that there is a distributional shift under way, probably related to changing water temperatures. Cod in the North Sea is moving northwards by 12 km per year. What is the appropriate management response as cod moves out of southern waters and become abundant in northern waters? That is a genuine debate that the fishing industry, fisheries scientists and fisheries managers need to have in the New Year.
Without a catastrophe narrative, NGOs like Blue Marine would find it more difficult to obtain funding. They are wealthy and well-connected and wrong.
Since we right-sized our fleets around the turn of the century through decommissioning, fish stocks across the North-East Atlantic have not just recovered from the mismanagement of the 1980s and 1990s but in some stocks – like North Sea haddock and plaice and western hake, the biomass in higher than ever seen in the historic record.
That is not a story of mismanaged decline, but it is an inconvenient truth for the Johnny-come-latelys who pine for the bad old days when their existence might have been justified.
Quotas for 2023
| Summary of agreed TACs and UK quota for 2023 Negotiation Forum | |||||||
| EU-UK | |||||||
| EU-UK-NO | |||||||
| Coastal States | |||||||
| Stock code | Stock name | Agreed TAC for 2023 (tonnes) | % Change in TAC from 2022 | UK quota for 2023 pre-LO deductions (tonnes) | % Change in UK quota from 2022 | UK quota for 2023 post-third country exchanges (tonnes) | |
| ALF/3X14- | Alfonsinos (3,4,5,6,7,8,9,10,12,14) | 179 | -20% | 5 | -29% | 5 | |
| ANF/07. | Anglerfish (7) | 45724 | 11% | 10196 | 14% | 10196 | |
| ANF/2AC4-C | Anglerfish (North Sea) | 7211 | -20% | 6338 | -19% | 6338 | |
| ANF/56-14 | Anglerfish (West of Scotland) | 4082 | -20% | 1704 | -17% | 1704 | |
| ARU/1/2. | Greater silver smelt 1,2 | 59 | 0% | 25 | 0% | 25 | |
| ARU/3A4-C | Greater silver smelt North sea | 809 | 0% | 13 | 0% | 13 | |
| ARU/567. | Greater Silver Smelt (Western) | 8124 | -30% | 454 | -30% | 454 | |
| BLI/12INT- | Blue Ling (International 12) | 77 | 0% | 1 | 0% | 1 | |
| BLI/24- | Blue Ling (North Sea) | 27 | 0% | 7 | 0% | 27 | |
| BLI/5B67- | Blue Ling (Western) | 10952 | 1% | 2611 | 3% | 2541 | |
| BOR/678- | Boarfish (Western) | 22791 | 0% | 1450 | 0% | 1450 | |
| BSF/56712- | Black Scabbardfish (Western) | 1813 | -6% | 103 | -6% | 103 | |
| COD/07A. | Cod (Irish Sea) | 165 | -20% | 73 | -20% | 73 | |
| COD/5BE6A | Cod (West of Scotland) | 1210 | -5% | 913 | -2% | 898 | |
| COD/5W6-14 | Rockall Cod | 74 | 0% | 52 | 2% | 52 | |
| COD/7XAD34 | Cod (Celtic Sea) | 644 | 0% | 63 | 3% | 63 | |
| DGS/15X14 | Spurdog (Western) | 10889 | 3933% | 4825 | 4024% | 4825 | |
| HAD/07A. | Haddock (Irish Sea) | 2648 | -13% | 1440 | -12% | 1440 | |
| HAD/6B1214 | Haddock (Rockall) | 4078 | -30% | 3430 | -30% | 3430 | |
| HAD/7X7A34 | Haddock (Celtic Sea) | 11901 | -21% | 2142 | -16% | 2142 | |
| HER/07A/MM | Herring (Irish Sea) | 7309 | -14% | 6870 | -11% | 6870 | |
| HER/5B6ANB | Herring (West of Scotland) | 1212 | -65% | 791 | -65% | 791 | |
| HER/7EF. | Herring (Western Channel and Bristol Channel) | 558 | -40% | 279 | -40% | 279 | |
| HER/7G-K. | Herring (Celtic Sea) | 869 | 0% | 1 | 0% | 1 | |
| HKE/2AC4-C | Hake (North Sea) | 2883 | 5% | 1339 | 13% | 1339 | |
| HKE/571214 | Hake (Western) | 46335 | 5% | 9374 | 6% | 9374 | |
| JAX/2A-14 | Horse Mackerel (Western) | 13400 | -78% | 1258 | -78% | 1258 | |
| JAX/4BC7D | Horse Mackerel (Southern North Sea and Eastern Channel) | 8969 | 0% | 3074 | 9% | 3074 | |
| L/W/2AC4-C | Lemon Sole and Witch (North Sea) | 3140 | -27% | 2042 | -26% | 2042 | |
| LEZ/07. | Megrims (7) | 21348 | 13% | 4285 | 17% | 4285 | |
| Stock code | Stock name | Agreed TAC for 2023 (tonnes) | % Change in TAC from 2022 | UK quota for 2023 pre-LO deductions (tonnes) | % Change in UK quota from 2022 | UK quota for 2023 post-third country exchanges (tonnes) | |
| LEZ/2AC4-C | Megrims (North Sea) | 2723 | -1% | 2621 | -1% | 2621 | |
| LEZ/56-14 | Megrims (West of Scotland) | 5499 | -1% | 2296 | 2% | 2296 | |
| LIN/03A-C. | Ling 3a | 144 | 0% | 11 | 0% | 11 | |
| LIN/04-C. | Ling (North Sea) | 2577 | -18% | 2046 | -17% | 2046 | |
| LIN/6X14. | Ling (Western) | 12371 | -18% | 4598 | -17% | 3298 | |
| NEP/07. | Nephrops (7) | 18353 | 8% | 7371 | 10% | 7371 | |
| NEP/2AC4-C | Nephrops (North Sea) | 22073 | -9% | 19120 | -9% | 19120 | |
| NOP/2A3A4. | Norway Pout (North Sea) | 58412 | -2% | 11439 | 12% | 11439 | |
| PLE/07A. | Plaice (Irish Sea) | 2039 | -26% | 1042 | -26% | 1042 | |
| PLE/56-14 | Plaice (West of Scotland) | 592 | -10% | 360 | -10% | 360 | |
| PLE/7DE. | Plaice (English Channel) | 6775 | -26% | 2020 | -26% | 2020 | |
| PLE/7FG. | Plaice (7fg) | 402 | -77% | 103 | -77% | 103 | |
| PLE/7HJK. | Plaice (7hjk) | 132 | 16% | 22 | 16% | 22 | |
| POK/7/3411 | Saithe (Celtic Sea) | 2541 | 0% | 383 | 0% | 383 | |
| POL/07. | Pollack (7) | 6410 | -20% | 1506 | -17% | 1506 | |
| POL/56-14 | Pollack (West of Scotland) | 125 | -20% | 46 | -19% | 46 | |
| PRA/2AC4-C | Northern Prawn (North Sea) | 990 | 0% | 218 | 0% | 218 | |
| RJE/7FG. | Small-eyed Ray (7fg) | 86 | -30% | 43 | -25% | 43 | |
| RJU/7DE. | Undulate Ray (English Channel) | 3192 | 1264% | 1051 | 1301% | 1051 | |
| RNG/5B67- | Roundnose Grenadier (Western) | 2317 | 0% | 112 | 0% | 112 | |
| RNG/8X14- | Roundnose Grenadier (8,9,10,12,14) | 1545 | 0% | 4 | 0% | 4 | |
| SBR/678- | Red Seabream (Western) | 105 | 0% | 11 | 0% | 11 | |
| SOL/07A. | Sole (Irish Sea) | 605 | -23% | 140 | -23% | 140 | |
| SOL/07D. | Sole (Eastern Channel) | 1747 | -27% | 347 | -26% | 347 | |
| SOL/07E. | Sole (Western Channel) | 1394 | -23% | 861 | -23% | 861 | |
| SOL/24-C. | Sole (North Sea) | 9152 | -40% | 1323 | -35% | 1323 | |
| SOL/56-14 | Sole (West of Scotland) | 57 | 0% | 11 | 0% | 11 | |
| SOL/7FG. | Sole (7fg) | 1338 | 0% | 421 | 1% | 421 | |
| SOL/7HJK. | Sole (7hjk) | 213 | 0% | 36 | 0% | 36 | |
| SPR/7DE. | Sprat (English Channel) | 9200 | 218% | 6859 | 218% | 6859 | |
| SRX/07D. | Skates and Rays (Eastern Channel) | 1537 | 3% | 240 | 3% | 240 | |
| SRX/2AC4-C | Skates and Rays (North Sea) | 1764 | 0% | 1202 | 1% | 1202 | |
| SRX/67AKXD | Skates and Rays (Western) | 9797 | 3% | 2937 | 5% | 2937 | |
| T/B/2AC4-C | Turbot and Brill (North Sea) | 3747 | -32% | 715 | -30% | 715 | |
| USK/04-C. | Tusk (North Sea) | 228 | 0% | 92 | 0% | 92 | |
| USK/567EI. | Tusk (Western) | 4294 | 0% | 1272 | 1% | 892 | |
| Stock code | Stock name | Agreed TAC for 2023 (tonnes) | % Change in TAC from 2022 | UK quota for 2023 pre-LO deductions (tonnes) | % Change in UK quota from 2022 | UK quota for 2023 post-third country exchanges (tonnes) | |
| WHG/07A. | Whiting (Irish Sea) | 721 | 0% | 428 | 1% | 428 | |
| WHG/56-14 | Whiting (West of Scotland) | 2636 | 46% | 1692 | 48% | 1692 | |
| WHG/7X7A-C | Whiting (Celtic Sea) | 9650 | -10% | 1077 | -9% | 1077 | |
| COD/2A3AX4 | Cod (North Sea) | 21652 | 63% | 9882 | 67% | 9882 | |
| COD/07D. | Cod (Eastern Channel) | 1261 | 63% | 117 | 65% | 117 | |
| HAD/2AC4. | Haddock (North Sea) | 58402 | 30% | 37261 | 31% | 37261 | |
| HAD/5BC6A. | Haddock (West of Scotland) | 6507 | 30% | 5245 | 30% | 5245 | |
| HER/2A47DX | Herring (North Sea bycatch) | 7716 | -6% | 140 | -6% | 140 | |
| HER/4AB. | Herring (North Sea) | 396556 | -7% | 72563 | -4% | 72563 | |
| HER/4CXB7D | Herring (Southern North Sea and Eastern Channel) | 396556 | -7% | 5162 | -5% | 5162 | |
| PLE/2A3AX4 | Plaice (North Sea) | 132922 | 6% | 35184 | 6% | 35184 | |
| POK/2C3A4 | Saithe (North Sea) | 53374 | 19% | 6186 | 23% | 6186 | |
| POK/56-14 | Saithe (West of Scotland) | 5538 | 19% | 2456 | 28% | 2456 | |
| WHG/2AC4. | Whiting (North Sea) | 34294 | 29% | 21410 | 33% | 21435 | |
| MAC/2A34. | Mackerel (North Sea) | 782066 | -2% | 1610 | 0% | 1610 | |
| MAC/2CX14- | Mackerel (Western) | 782066 | -2% | 209204 | 0% | 209204 | |
| WHB/1X14 | Blue Whiting (Northern) | 1359629 | 81% | 106034 | 82% | 106034 | |
| HER/1/2- | Herring (ASH) | 511171 | -15% | 9983 | -15% | 9983 | |
Annual Fisheries Negotiations
Since October, the UK, as an independent coastal state, has been engaged in a series of negotiations towards annual fisheries agreements for 2023. These sets of talks have continued more or less in parallel and have partly informed each other in the different strands in the annual round of fisheries negotiations. The UK/EU Fisheries Agreement for 2023 has just been signed, but other negotiations have included:
- Trilateral consultations between the UK, Norway and the EU
- Negotiations between coastal states on the big, highly migratory pelagic stocks (Iceland, UK, Faroes, Norway, Greenland and the EU)
- Talks on a bilateral agreement between the UK and Faroes.
- Talks towards a bilateral fisheries between UK and Norway
- Separately, the EU has also held separate bilateral negotiations with Norway
UK/EU Fisheries Agreement
The UK/EU negotiations are primarily focused on setting total allowable catches for 2023 on the 70 or so shared stocks. Quota shares and access arrangements between the UK and the EU are fixed by the Trade and Cooperation Agreement until 2026, after which they will be subject to annual agreement.
Mixed Fisheries: Despite dealing with 70 individual stocks, our understanding that, for many of these, agreement was reached quickly by following the headline ICES scientific advice. The question of how to apply ICES mixed fishery scenarios to those stocks where there are technical interactions between different species proved more controversial. Different species have different levels of interaction and in complex multispecies fisheries like the demersal fishery in the Celtic Sea, the range can be considerable (haddock quite a lot, monkfish, megrim and sole much less).
Cod in UK waters, for which scientists detect a northward movement in distribution and low recruitment, possibly through some kind of regime shift, is not an economically important species in the Celtic Sea or Irish Sea, and there is a judgement call required as to how to balance protection for the residual component of the stock whilst maintaining economically viable fishing opportunities on the many (up to 40) other economically important species. The degree to which this already complex set of considerations was further complicated by political manoeuvring to secure negotiating leverage in these complex negotiations by both sides is an open question but was certainly a factor.
In the final outcome, ICES headline advice appears to have been followed in the main in the Celtic, Irish Sea and West of Scotland fisheries with some consideration to mixed fisheries interactions on specific stocks like haddock and megrim. In the North Sea, where mixed fisheries interactions were dealt with on a more pragmatic basis, the decision to limit recommended increases in haddock and whiting TACs to 30% (rather than 160% and 224% respectively) is widely regarded as a sound call in the context of the trilateral negotiations.
Seabass: The positive ICES advice this year provided scope for modest increases in the catch limits for all metiers: trawl and seine, gill net, and hook and line. This is welcome as a step towards reducing dead discards of unavoidable bycatch, though quite limited. There will be many, certainly, who are frustrated by the slow pace of improvement, which is largely dependent on the size of incoming recruitments. A further source of frustration will be the time that it take to obtain parliamentary approval for the changes that will delay the availability of the increased limits for around four months. As this lack of agility was one of our principle criticisms of the CFP, the Federation will be campaigning for a much more streamlined mechanism for the future. These changes should be capable of being implemented through licencing conditions in 24 hours, not 4 months.
The changes are:
Trawl and Seine – More flexibility from 760kgs per two month period to 3.8 tonnes per year
The 5% per trip limit remains in place as does the closed season in February and March
Hook and Line – The 5.95 tonne annual limit is raised to 6.2 tonnes
Gill Nets – the 1.5 tonne limit is increased to 1.6 tonnes per vessel per year
It is impotant to check these provisional figures with the MMO guidance when it becomes available.
Spurdog: The extremely positive scientific advice on spurdog after having previously been on the prohibited species list, opens the possibility of a significant fishery in 2023 and 2024, subject to a number of conditions, such as returning mature females to the sea. There will be a rather frustrating delay whilst certain legal and constitutional hurdles are navigated to take them off the prohibited species list, but we are assured that EU vessels will only be able to catch and land spurdog caught in UK waters when this facility is also open to UK vessels.
Skates and Rays: The Skates and Rays group TAC was the subject of a difference of opinion on interpretation between the UK and the EU, but in truth, for this year at least, there seemed little difference in the outcomes. The group TAC remains an imperfect way to manage 12 different sub-species but a complete alternative solution has yet to materialise.
The NFFO will participate in meetings to make progress on this front in the New Year.
Non-Quota Species: Progress has been made in ensuring data transparency as it is not possible to manage any fishery on the basis of inadequate information. The UK’s insistence of a committment in the agreed record will mean that catch statistics from both the EU and the UK will now be published quarterly. This removes an important impediment to sustainable management. In the meantime, it has been agreed to continue to monitor uptake of catch limits without the kind of hard stop that would carry adverse consequences, including fleet displacements. The longer-term approach to managing NQS through multi-year strategies will begin with king scallop in the New Year.
UK/Norway/EU Trilateral
The UK/EU/Norway fisheries agreement has now been signed and the trilateral negotiations completed.
The outcome in summary is:
North Sea
Cod + 63%
Haddock + 30%
Whiting + 30%
Saithe +19%
Plaice + 6%
Herring (A fleet +7.3%, B Fleet +5.6%)
The very positive ICES scientific advice this year meant that the task of setting TACs for the main jointly managed stocks was relatively straightforward. Restraint was shown in setting TACs in the haddock and whiting fishery in acknowledgement of the interaction of these species with cod. The substantial increase in the TAC for cod is exceptionally welcome as it brings the industry’s view of abundance and those of ICES into closer alignment. The well- attended meeting in Edinburgh at the beginning of November between the industry and senior ICES fisheries scientists was likewise a very positive development.
Much of the time during the negotiations was spent on a long-running dispute between the EU and Norway about how to handle bycatch in the industrial fishery.
UK/Norway Fisheries Agreement
The bilateral with Norway principally concerns access arrangements and quota exchanges.
The arrangement for reciprocal access for demersal species up to 30,00 tonnes introduced in for 2022 will be rolled over into 2023. The level and type of quota exchange is determined by need, surplus and politics. The UK prioritised an inward exchange of monkfish as the TAC was facing a significant reduction. Politics are likely to have been a significant factor in deprioritising take up of the full fishing opportunities offered by Norway in the North East Arctic.
Coastal States
A management framework to cover shares and harvest control rules for the massive western mackerel and blue whiting stocks is edging slowly towards agreement. All parties know that an agreement is vital to avoid stock decline, but it remains to be seen if the necessary compromises to overcome national self-interest can be made. The signs are that the parties (Greenland, Norway, Iceland, Faroes, EU and the UK) are edging towards agreement but a final effort is required to close the gulf on quota shares and access arrangements. Talks will resume on mackerel and on blue whiting in the New Year.
Big Picture
Contrary to some of the more lurid catastrophe narratives which appear in the media, most stocks in the northeast Atlantic continue to head in the right direction, as they have done since the turn of the century. Some like North Sea haddock and plaice and Western hake now have biomasses above anything in the historic record. Equally there are a few outliers, notably cod at the southernmost extent of the species distribution, that are not thriving, probably not unconnected to changing sea water temperatures. Fluctuations in recruitment and changed scientific perceptions accounted for most of the stocks where there were big swings in the 2022 assessments. Broadly speaking, the decisions taken this December keep us safely on the road to sustainable fisheries management, whilst reaffirming the importance of food security, thriving fishing businesses and coastal communities.
Beyond the annual negotiations, it has been a busy year for the NFFO.
Spatial Squeeze
Without doubt, the publication of the report on displacement commissioned by the NFFO and Scottish Fishermen’s Federation from independent consultants ABPmer, with financial support from the Fishmongers Company, was the most dramatic policy intervention of the year.
The report estimates that the rapid expansion of offshore wind and the implementation of a network of marine protected areas, under the best-case scenarios mean that the fishing industry will lose access to one third of the fishing areas currently available to it, and under the worst-case scenario we will lose a half. The scale of displacement ahead is truly breath-taking, and the consequences will impact on individual fishing businesses, coastal communities, fisheries management and fisheries science.
The report is not just an objective analysis by respected consultants, based on reasonable and reasoned assumptions, but also a call to arms for joined-up government and effective marine spatial planning.
Whilst the report has been widely welcomed as a timely and important intervention, we have yet to hear of how the government intent to minimise, mitigate and otherwise deal with displacement on this scale.
At the heart of the issue is the fact that fishers, unlike farmers, do not hold legal title over their production areas and to date there has been an assumption that fishing can always be pushed aside. It remains to be seen if the focus on food security in the wake of shortages in 2022 will be the catalyst for policies that match the scale of the problem. The NFFO certainly expects to be at the centre of discussions with policymakers in the New Year.
Science Forum
Cefas and the NFFO have established a new fisheries science forum through which the industry can hear about the most recent developments in fisheries science and fisheries scientists can learn directly from the knowledge held by fishermen and vessel operators. Although there are now many ways in which a two-way exchange of knowledge and information between fisheries scientists and the industry can take place, we lacked a place where direct exchanges could be held and the new forum will fill that gap. The forum’s first meeting was held on 1st November and was considered to be an extremely useful base to build on.
The NFFO is also supportive of the establishment of a Centre for Sustainable Fisheries, by the University of the Highlands and Islands and more about this will be heard in the New Year.
Highly Protected Marine Areas
The government’s lurch into highly protected marine areas in which no fishing of any kind would be permitted, suggests a drive for green credentials over a coherent, evidence based, approach that balances the need for environmental protection with food production and the welfare of coastal communities. The consultation exercise on five candidate HPMAs made clear that the interlinked issues of displacement, unintended consequences, and cumulative impacts had been given next to no thought. Without a coherent purpose, and no attempt to deal with policy consequences the candidate HPMAs, (if they are adopted) have the potential for real socio-economic and ecological harm. The fact that fishing organisations were not invited onto the HPMA panel speaks volumes on where the drive for this policy comes from. It is also of significance that the chair of the HPMA panel Richard Benyon, now Lord Benyon, was the UK fisheries minister who signed up for the misconceived EU landings obligation, from which his department are now trying to find an escape route.
The consultation having now concluded, we await the publication of a summary of responses in early 2023 and the final decision to designate or not from Secretary of State for the Environment Therese Coffey before the end of June.
Shellfish
Having successfully launched the Shellfish Industry Advisory Group, to give the economically important shellfish sector an effective voice at the policy level, most of the Federation’s efforts go into making the group a successful example of co-management, involving fisheries scientists, fisheries managers as well as a good cross-section of the shellfish sector.
The mammoth task of developing fisheries management plans, foreseen in the Fisheries Act, through energetic sub-groups for crab/lobster, whelk and scallop, and overseen by Seafish, who provide the secretariat for the Group currently occupies most of the Group’s time.
Risk, Safety and Training
The NFFO pursues a twin-track approach to keeping vessels and crews safe in a sometimes-hostile environment. We have ongoing engagement with the Maritime and Coastguard Agency to press for pragmatic and effective approaches to fishing vessel surveys and better communication between the MCA and the industry. We also work to assist individual fishing vessels to meet safety standards and prepare for vessel surveys. The appointment of Charles Blyth, an-ex MCA surveyor and qualified naval architect, as NFFO Safety Officer has been a game changer. A more relevant approach to surveys for the under-15m fleet has been secured and a video explaining how to prepare a vessel for survey has been widely welcomed.
Crew Welfare
The NFFO is a member of the Fishermen’s Welfare Alliance, whose role is to work ensure sound employment conditions for crews across the whole fleet, irrespective of country of origin. Working in cooperation with a range of regulators and across the supply chain, the FWA also works in the complex and politically fraught area of immigration policy and labour supply.
Fisheries Law, Fisheries Policy, and Fisheries Management Plans
Disappointment at the limited achievements of Brexit in terms of securing additional fishing opportunities commensurate with the UK’s legal status as coastal state remains sharp. The focus during the year, however, shifted to the opportunities provided by leaving the Common Fisheries Policy to design and implement fisheries policies more tailored to the specific needs of our fleets and fisheries. The Fisheries Act 2020 provides a balanced legal framework and the recently published Joint Fisheries Statement, provides a necessary policy framework for the development and implementation of UK fisheries policy within the context of devolved responsibilities.
The real work, however, lies ahead with the development of fisheries management plans that will over time replace EU retained fisheries law. Frontrunner plans are under development for crab and lobster; whelk; king scallop; seabass; Eastern Channel and Southern North Sea flatfish; and Channel demersal non-quota species. The NFFO will expect to be heavily involved in discussions with the appropriate bodies as the shape of the plans emerge.
Fuel Costs
2022 will certainly be remembered as the period when geopolitics impacted heavily on the viability of many fishing vessels through stratospherically high fuel costs. Unlike many EU member states, no fuel subsidy was provided to sustain UK fleets, creating an uneven playing field, and had it not been for the reasonably high quayside price for many fish and shellfish species, many vessels would have had to tie up.
Membership
This year, the Welsh Fishermen’s Association-Cymdeithas Pysgotwyr Cymru moved to formalise its membership of the NFFO, having worked very closely with the Federation for many years. While maintaining its distinctive national identity and role, the WFA-CPC will now have two seats on the Executive Committee and will participate fully in all of the NFFO’s policy decisions. Its members will also be eligible for grants made through the NFFO Training Trust.
New CEO
During 2022, the NFFO’s Chief Executive, Barrie Deas, announced his retirement at the end of April 2023, after 26 years at the helm. After a robust recruitment process, the Federation announced that his successor will be Mike Cohen, currently NFFO Deputy Chief Executive. Mike is a past NFFO Chairman, and successfully ran the Holdeness Fishing Industry Group, so he is very well equipped to meet the challenges of the role.
NFFO Services Limited
The Federation’s commercial division, NFFO Services, has for almost 40 years, provided fisheries liaison services, fisheries liaison officers, and where necessary guard-ships, to any offshore infrastructure projects likely to interact with fishing vessels. Facilitating co-existence and minimising frictions at sea has become even more important within the context of the rapid expansion of the offshore renewables sector. In profitable years, the company has channelled a substantial part of its profits into the NFFO Training Trust, which in turn has provided grants for young fishermen and safety related equipment aboard fishing vessels.
Political Pressures, Green Politics and Geopolitics
Environmental NGOs, have a valid and important role in fishing, as in any other area of society. At their best, they can be partners in the promotion of progressive policies and initiatives and unravelling knotty management problems. At their worst, they can be self-absorbed, legalistic, and irresponsible bodies, committed to a catastrophe narrative that flies in the face of the evidence. There is no doubting their power and influence. With huge funds at their disposal, they can shape media narratives and ministers are always sensitive to criticism from the green lobby. No one can look at the mess that is the EU landings obligation and fail to understand the power of the media, irresponsible environmentalism the moral panics they can cause.
Since the turn of the century when the fleets were right-sized through decommissioning, and with one or two outliers, most fisheries across the north-east Atlantic region have been on a solid pathway to sustainability. The biomass for some stocks like North Sea plaice or haddock, or western hake, are above anything seen in the historical record. This positive story is anathema to some NGOs, because it robs them of legitimate purpose and therefore potentially funding. Hence, the catastrophe narrative is rolled-out year after year, and adversarial postures are struck, with a resolute commitment to only engage with fisheries science on those occasions where it tells a negative story.
This is only one facet of the array of political pressures on the fishing industry. Others include energy policy, devolution politics, the UK’s relationship with the EU, and immigration policy. What has been missing from many of the debates is the question of how we are going to feed the country and the planet, without sustainable fisheries and the grounds on which to work. The role of the NFFO is to work with those, across the spectrum, who are open to the evidence and willing to cooperate, and to call out the charlatans, liars, and merchants of untruths and half-truths.
Discard Policy
The EU landing obligation was a badly designed piece of remote, top-down legislation, born from a legitimate desire to reduce unwanted catch. Ignoring the evidence that the fishing industry and policy makers had been steadily reducing discards for over 20 years (in the case of the North Sea groundfish fishery by 90%) the landing obligation was introduced in 2013 with much righteous indignation and fanfare. It has been a flop. Worse, with its tendency to create chokes in mixed fisheries and the exemptions required to make it work, it has been counterproductive, undermining rational fisheries management and increasing the level of discards. The UK is now working on ways in which reducing unwanted catch remains a policy objective, but in ways that avoid the over-centralised, blunt approach that characterises the landing obligation. The evidence objective in the Fisheries Act, the scope to integrate rational discard policy into fisheries management plans, and using TAC and quota policy to minimise choke/discard risks, seem to offer the key elements of a new and better approach.
Offshore Wind
The news that some meteorologists consider that we are entering a period of lower wind velocities is unlikely to halt the headlong rush to build offshore energy installations on a massive and unprecedented scale.
With governmental aspirations for 130Gw of offshore energy generating capacity to be built by 2050, the continually increasing pace of wind farm construction is hardly surprising. 2022 has seen the ongoing development of the vast Hornsea and Dogger Bank wind farm zones in the North East and proposals to extend existing smaller wind farms south of the Humber.
This was also the year when offshore power stations started to encroach on the Celtic Sea. The Crown Estate began consultation on areas to be leased for the first floating wind turbines in English and Welsh waters. This is unknown, untried technology and we await further details of how it will be constructed, installed, operated and maintained: all activities likely to have significant impacts on fishing activity across a very wide area.
While the Crown Estate will lease areas for the construction of four 1Gw arrays in this first round, a further 15Gw of generating capacity, or even more, installed in the Celtic Sea in due course has been suggested. Dedicated lobbying by the NFFO and its member associations and Producer Organisations in the affected region – with particularly notable efforts from the Cornish Producers Organisation and the WFA-CPC – has succeeded in removing the threat of imminent development from some of the most sensitive fishing grounds, but valuable areas remain under consideration. There are also concerns about how little has been done to understand the impact of these vast and novel developments on the healthy marine ecosystems that our fisheries depend on. The NFFO continues to campaign for more and better quality research to rectify this shortcoming.
Alternative Propulsion
We can already take pride in knowing that fishing provides one of the healthiest and lowest carbon sources of protein known. When it comes to meeting the aspiration of net zero carbon emissions, our industry is already well ahead of most. There is no reason to rest on our laurels, however, nor to neglect the fact that cutting carbon emissions further will also mean reducing fuel use and so cutting costs.
The NFFO commissioned a report from independent experts at Hull University, to examine the potential for electric propulsion for fishing vessels. Electrifying the Fleet generated significant interest from many quarters, including the All-Party Parliamentary Group on Fisheries. This helped to create the momentum which led, in December 2022, to the creation of the Vessels of the Future forum. Convened by Seafish and chaired by NFFO Deputy CEO Mike Cohen, this initiative has brought together representatives of the fishing industry, ship builders, engineers, officials and researchers, from across all four UK administrations. Its aim is to support projects that will lead to the development of new technologies to increase vessel efficiency, reduce fuel costs, and shrink our carbon footprint even further.
£100 Million
There was, from the outset, concern that much of the fishing industry’s second prize, the £100 million announced by PM Boris Johnston as the Trade and Cooperation Agreement failed to deliver the additional fishing opportunities promised by those at the top of government at the time, would fail to find its way to support those who had lost out – fishermen and vessel operators. Those better equipped to navigate the application forms and public procurement processes have an inbuilt advantage in the public procurement labyrinth. Some good Fishing/Science partnership projects have been funded but when the dust settles there is a suspicion that on the whole, fishermen and fishing vessel operators – who were supposed to be the main beneficiaries – will have lost out, following the pattern of many of the earlier European funding programmes.
Remote Electronic Monitoring
REM is a feature of the modern world, for better or worse. AIS, CCTV, AI and a whole array of rapidly developing information technologies have already, and will continue to impact on the fishing industry. The key question, of course, is where and how these technologies will be used and what safeguards for their use will be put in place. There are regular calls for REM (in particular, CCTV) to be placed upon fishing vessels as an enforcement tool. Leaving aside the civil liberty, ethical and legal issues involved, this would be to waste the real potential of REM to efficiently capture a whole array of data of use to fishers, fisheries scientists and fisheries managers. This can only be done where there is trust and confidence in the uses of the new technologies from all parties. We have had positive experiences using CCTV, in the North Sea and Celtic Sea. Misused, or used as a blunt enforcement tool would generate a reaction that would set back the use of REM for at least a decade. By contrast, its intelligent deployment could transform data deficiencies, leading to better, more sensitive and refined fisheries management. There will be a Defra consultation on REM in the New Year and this is the line we will take.
Finally
Finally, on behalf of our President, Chairman, Executive Committee, and whole NFFO staff, we would like to wish you a very happy Christmas and best withes for the New Year
The loss of the Jersey vessel, l’Ecume II, is a devastating blow for the island community and for the South-Western Fish Producer Organisation, through which the vessel was a member of the NFFO.
As the search continues, efforts will be made to understand the causal factors behind this tragedy. In the meantime, our thoughts are with the families and friends of the skipper and two crew members.
Mike Cohen, the current NFFO Deputy Chief Executive, will take over as Chief Executive of the National Federation of Fishermen’s Organisations, when Barrie Deas, the current CEO retires at the end of April.
Mike has a legal and science background, as well as helping to form and leading the Holderness Fishing Industry Group for 7 years. He has also held the position of Chairman of the NFFO and is widely known and respected throughout the fishing industry.
The appointment was ratified at a recent meeting of the NFFO’s Executive Committee. In the interim, Mike will continue as Deputy Chief Executive.
Barrie Deas said, “This will be a popular appointment, and although we had a strong field of candidates, it was felt that Mike had the right blend of experience and skills to amply qualify him for this important industry role. Above all, he knows what to expect as he has sat around the Executive Committee table for several years as well as acting as chairman and latterly as deputy.
NFFO Chairman, Paul Gilson said, “I have had the privilege of working alongside Mike on a series of visits to the coast and I have seen at first hand his concern for and deep commitment to the welfare of working fishers. I am looking forward to working with him in the future”.”
Mike Cohen said: “I’m proud to be associated with the fishing industry. It provides food for the nation and jobs in places that are often forgotten by those in power. I have always strongly supported the NFFO’s approach – seeking to unite all sectors of the fleet, to fight our corner intelligently, persuasively and forcefully – so I am delighted to be taking up this new position. Barrie is a very hard act to follow, but I am looking forward to getting to grips with the challenges of the role and continuing to support the Executive Committee to stand up for our industry.”
Ends
In partnership with the National Federation of Fishermen’s Organisations (NFFO) and supported by the Fishing Industry Safety Group (FISG) the film is aimed at helping all owners to prepare for their MCA inspection following changes to the regulations for fishing vessels under 15 metres.
The Seafarers’ Charity aims to make working at sea safer for all and ensuring fishers can work and return home safely from voyages without experiencing harm or an accident is a big part of that.
The Seafarers’ Charity has supported the production of the film which highlights the changes to the MCA’s inspections of under 15m vessels. It will help owners to get their vessel ready survey as well as signposting resources to help prepare for a successful inspection.
Charles Blyth, Risk, Safety & Training Lead at the NFFO identified that many fishers were not aware of the changes to the MCA’s inspection regime and were therefore finding themselves tied up and prevented from fishing for longer periods because they did not meet the new requirements. Charles approached The Seafarers’ Charity with his idea for a short film to help share information on preparing for the new inspection requirements. As a previous Marine Surveyor with the MCA, Charles is well placed to help fishing vessel owners and the wider industry maintain high safety standards for their crews and their vessels. Charles said,
“Recently, the under 15 metre fleet has seen some significant changes to the MCA inspection requirements including new stability tests and an out of water inspection, with some vessels struggling to meet all the requirements and therefore being tied up and unable to fish. We have made this information film to support all owners of under 15 metre vessels.”
This film is available on The Seafarers’ Charity’s YouTube Channel here.
All of the main political parties at Westminster were represented, including fisheries minister Mark Spencer and Shadow Fisheries spokesman Daniel Zeichner. The influential gathering also included the head of marine spatial planning at the MMO, the chairman of the Environment, Food and Rural Affairs Committee, senior figures from the Crown Estate, the chair of the All Party Fisheries Group, a representative from the European Commission, as well as fishing industry representatives and members of the press.
The purpose of the event, organised on behalf of the NFFO and SFF by parliamentary specialists, Connect, was held to highlight the scale, pace and implications of the mounting displacement issue.
Suzannah Walmsley from ABPmer described the analysis underpinning the report which identifies the expansion of offshore wind and marine protected areas as the two main drivers for displacement. Under the worst-case scenario this will mean that the fishing industry will lose access to half of the areas currently available to it by 2050. The best-case scenario is that we will lose a third.
NFFO Chief Executive, Barrie Deas, made clear that the political imperatives for zero carbon emissions and the need for protection for sensitive marine species and habitats are fully understood by the fishing industry. What is currently missing, however, is a balancing appreciation that food security can only be achieved if production areas – key fishing grounds – are also protected. At present, the fishing industry is not even a statutory consultee when it comes to marine spatial planning decisions. By contrast with agriculture, fishers do not have legal title over their fishing grounds and there is an implicit belief that fishing can always be shifted elsewhere. The ABPmer report makes plain that the sheer scale and potential for displacement ahead requires fresh cross-government action.
Elspeth Macdonald (SFF CEO) emphasised that the pace of change on offshore wind and marine protected areas was like a “bulldozer on steroids” and that the consequences if not addressed would be calamitous. Both federations stressed that early and meaningful dialogue and intervention could mitigate and minimise the scale of disruption but at present those cross-government discussions were not happening – there is a lack of joined-up thinking within government. Elspeth also made the point that the two federations should not have had to commission this work – it was necessary because of a gap in government policy.
Fisheries Minister, Mark Spencer, said that his inbox was full of anti-bottom trawling propaganda coordinated by elements of the green lobby, and that the public had consequently been misled into an inadequate understanding of both what MPA designation was and the impact different forms of mobile fishing gear.
Robert Goodwill, chair of the EFRA Committee, highlighted the disparity between the establishment of national parks where, rather than being “turfed out”, farmers were invited to participate in achieving conservation objectives in partnership with regulators. This contrasts starkly with the notion that marine protected areas (which cover 38% of English waters and 50% of inshore waters) should be cleared of productive activities, beginning with Highly Protected Marine Areas.
The parliamentary launch of the NFFO/SFF report was an important building block in understanding that good intentions are not enough. Unless the scale and pace of the mounting displacement crisis is understood and addressed, we will enter a period where profoundly chaotic outcomes will emerge. Fishing businesses and coastal communities will be harmed but it will also be increasingly difficult to manage or even understand our fisheries. Experience suggests that displacement will lead to perverse outcomes for fisheries but also the marine environment.
The ABPmer report is in this sense, a call to arms. It is possible to limit displacement effects, but this requires meaningful engagement and dialogue at an early planning stage. Effective marine spatial planning has a central role to play. The cumulative effect of multiple micro-displacements can no longer be ignored.
Next Steps
An EFRA Committee enquiry resulting in a thoughtful report could be the next step in understanding of the current displacement trajectory and promoting solutions.
Fisheries Minister, Mark Spencer undertook to begin a dialogue across government to ensure that fisheries displacement is adequately addressed.
Opposition parties have a crucial scrutiny role to hold government to account in ensuring that displacement is dealt with thorough an evidence-based rather than rhetoric-based approach.
The presence of the European Commission at the event is an important reminder that displacement has a serious international dimension.
The All Party Fisheries Group can help to focus minds on the potential consequences of displacement
The two federations must continue to press for parity with land-based conservation and energy security policies. There is still a major job of work to be done but this parliamentary event successfully played its part.
Summary
- 38% of UK waters are already designated as marine protected areas of one kind or another. Similarly 50% of inshore waters are subject to designated MPAs. Management measures within this network of MPAs, along with the accelerated expansion of offshore wind, represent a major displacement threat for the fishing industry.
- Ministers have made the decision to push ahead with pilot HPMAs, despite the absence of policies to deal with large scale displacement from customary fishing grounds
- An inadequate approach to evidence is apparent throughout the process of site selection for pilot HPMAs. Because the issues of cost and displacement have not been addressed adequately at site or macro level it is likely that both socio-economic and ecological harms will result.1
- Policies driven by good but incoherent intentions, and which fail to foresee and address implementation issues can have serious adverse consequences2.
- Fisheries and marine environmental protection are complex policy areas and there is clear evidence that rushing into a poorly thought-through policy can cause more harm than good. This is true for ecological damage as well as socio-economic harm.
- HPMA candidate sites show all the symptoms of a rushed shockingly superficial process that has prioritised the act of designating HPMAs as an end in itself, without seriously considering the consequences of this political theatre. With this consultation ministers have made a rash decision to push ahead with the designation of pilot HPMAs in advance of a comprehensive or coherent strategy on how to handle the forthcoming crisis of marine space. This is a mistake that will carry serious consequences.
- Steps to replace balancing competing activities and objectives with a hierarchy of prioritiesas the guiding principle of marine spatial planning are currently under way. In place of a comprehensive and coherent suite of policies to address the consequences of prioritisation, HPMAs are being introduced there in a policy vacuum.
- These five pilot HPMAs mark an initial step within policy which applies a strict dichotomy between areas reserved for nature conservation and areas necessary for food production. This contrasts starkly with the approach applied on land, where food production and environmental production are seen as complementary and intertwined objectives.
- Marine protected areas have an important role to play in protecting vulnerable habitats and species when they have clear conservation objectives, are well sited and sensitively managed on the basis of evidence. A careful, evidence and dialogue-based approach to establishing and managing a network of marine protected areas has, however, been abandoned and replaced by a rushed and inadequate process that sidesteps the elephant in the room: displacement.
- Understanding and dealing with the consequences of policy decisions is the hallmark of mature and responsible government.
- Pushing ahead prematurely with the establishment of HPMAs, in the absence of coherent policies to understand and address the wider ecological and socio-economic displacement issues raised by the trajectory of current energy and environmental policies would be reckless and irresponsible.
Displacement
At the highest level, our objection to these HPMA proposals lies in the ongoing exclusion of fishing from an increasing proportion of British waters. Both HPMA candidate sites, and wider government policies, do not take account of these wider macro level displacement issues. This is a glaring policy vacuum with the most profound potential consequences.
Source: Spatial Squeeze in Fisheries
The NFFO/SFF-commissioned report by ABPmer on the spatial pressures mounting on fishing activity provided an idea of the scale of the challenge ahead and the potential for displacement of fishing activity from customary grounds. Offshore wind and management measures within marine protected areas present the two most significand drivers of this change, yet there is no coherent government policy on how offshore energy, food security and the UK’s ambitions for marine environmental protection are to be balanced. To date there has been an assumption that fishing activity (fishers having no legal title to their production areas) can always be shifted. There is a growing awareness, however, that in addition to requiring fishing in sub-optimal locations with potentially higher fuel costs and consumption, the knock-on effects on other fisheries can be profound, albeit difficult to model.
The consultation documents state that “Analysis is on-going to understand the displacement impacts of HPMAs”. That this proposal has been put forward without analysis of its likely impact having been conducted is a shocking admission. The five HPMA candidate pilot sites are being inserted into an already complex mix before any coherent government policy to address the displacement issue has emerged. This is short-sighted and irresponsible and if pursued will deliver bitter outcomes.
Food Security
Seen in the round, the spatial squeeze will seriously limit the contribution made by fishing to the nation’s and global food security. Unlike farmers, fishers do not hold legal title to their production areas and this makes fishing uniquely vulnerable to displacement. HPMAs are but one facet of a much larger looming problem that, so far, is going unaddressed by government. Whole supply chains depend on the landing of fish and shellfish – but the consultation document has nothing meaningful to say about how marine spatial planning will deal with this radically altered production and policy landscape.
In the light of imperfect information, the HPMA programme has made a series of assumptions in selecting its preferred option, option 4, and, as a result, it adopts a process which is effectively biased against the ecosystem benefit of the provision of food.
Blue Carbon vs Increased Fuel Consumption Caused by Displacement
Sequestration of carbon is liberally sprinkled throughout the document as one of the underpinning rationales for HPMAs. Yet there is no assessment of the increased fuel consumption and carbon emissions entailed in requiring fishing vessels to steam further and for longer to make up for fishing under sub-optimal conditions.
Consultation
Stakeholder Community
It is clear that Defra ministers have, in conceiving HPMA policy, only listened to one part of the stakeholder community – the advocates of closed areas as a panacea for a range of fisheries and environmental management challenges. The answer why this is so – and why the Benyon Report panel included environmental organisations but not representatives of the fishing industry – remains an enigma.
Breach of Trust
The process of identifying marine conservation zones under the Marine and Coastal Access Act 2009, was ostensibly a stakeholder-led exercise which gave the fishing industry a degree of confidence that protection for sensitive marine habitats would be secured whilst minimising the impact on existing fishing activities. It was understood that robust evidence and dialogue-based process would determine which fishing activities would be compatible with which conservation objectives on a site- by-site basis.
That considered, stepwise, approach has been abandoned and this amounts to a breach of trust with the many fishers who gave their time and experience to identify MCZ sites, only to see that approach abandoned and their contributions discarded.
Conservation objectives
The conservation objective for all sites is stated to be:
“To achieve full natural recovery of the structure and functions, features, qualities and composition of characteristic biological communities present within HPMAs and prevent further degradation and damage to the marine ecosystem subject to natural change.”
There are many problems with this. Having one objective for five very different sites highlights how little this process has to do with achieving specific real-world conservation outcomes. Merely claiming areas of the sea in the name of a particular political ideology is the key. Identifiable, meaningful environmental change is not even contemplated.
It is impossible to be sure what is meant by “full natural recovery”. Recovery implies reattaining some prior state, but what state and exactly how much earlier than the present are not specified. Fishing intensity is now less at some sites than it was in the past. Are we to assume then that sites are to be recovered to their state before they were commercially fished at all? In some locations that is hundreds of years ago and we have no way of knowing what those ecosystems looked like then.
Indeed, the evidence presented seems to show only the most approximate picture of what these ecosystems look like today and how they are deemed to have changed. It is hard to discern any precise baseline against which progress is to be judged. How then, are we supposed to know when this ‘objective’ has been met? When will recovery be said to have been achieved? How will we know if there has been ‘further’ degradation, particularly when the HPMAs encompass everything from the sea bed to the wave crests. Similarly, how will we judge whether ‘degradation and damage’ has been caused by ‘natural change’ (and if it is natural, we may ask why it is viewed as ‘damage’: these are living ecosystems, not sculptures) without a clear statement of the current status of all of the things that are supposed to be conserved and an understanding of the natural forces to which they are subject. The impact assessment for the sites gives estimated timeframes for habitat recovery that are mostly said to be “2-25 years”. An order of magnitude between the upper and lower estimate does not indicate either secure understanding of what the objective is or a plan for how to achieve it.
The Marine and Coastal Access Act (2009) requires any Marnie Conservation Zone order to state conservation objectives. The Act elsewhere refers to opinions being given as to the extent to which the objectives have been achieved and the steps required to be taken to achieve them. The Act clearly, therefore, anticipates that objectives should be specific and actionable. Simply to say that ‘nature must recover’ is insufficient. It is unclear where the authority to declare sweeping, indefinite closures of areas of the sea without specific reasons or objectives is claimed to come from, but the Marine and Coastal Access Act does not provide it.
The word “experiment” has been used with distressing frequency by officials discussing HPMA programme, as though seeking to make a virtue of the failure to base this process in proper evidence. The Marine and Coastal Access Act does not grant authority for experiments.
Impact Assessment
An impact assessment document has been published for this policy, but it is incomplete in several crucial respects.
The “Cost of Preferred Option” section of the summary has been left blank, with only a comment later in the document that “We estimate that costs to businesses will be between £0.006m- £9m” – a degree of uncertainty so huge as to render this estimate useless for decision making.
Section 8, of the IA document betrays a misunderstanding of how the landings system works and consequently a gross under-representation of the costs to industry, particularly the <10metre vessels.
The Registration of Buyers and Sellers[1] means that to be registered as a “landing” in the official statistics the first sale note must be offset against the purchase note of a registered buyer. This effectively excludes the whole informal sector where small quantities of fish, less than30 kg, may be sold on to individuals (or restaurants). These will be landed from inshore vessels, typically fresh and commanding the highest prices. The average prices for recorded landings will include large quantities of frozen fish which command a lesser price. In addition, it should be noted that often the inshore fleet will target Non-Quota Stocks, NQS, which do not necessarily figure in the Landing Declarations[2].
The result is a serious underestimation of the value of the fisheries and therefore of the cost of closing areas, 8.10.
Information about fishing effort is largely confined to the use of VMS data from the over 12m fleet, with only some unquantified references to spotter data for smaller vessels. This leads to a skewed view of the importance of the sites to fishing communities. Data on under 12m vessels is available: from landings declarations, for example, or simply by going to ports and asking for it. Offshore developers have been doing this for years, when assessing the impact of their projects and compensating those adversely affected by them, so why not do it in this case?
The impact assessment’s description of the policy context does not include any reference to the Fisheries Act or the Joint Fisheries Statement. It is hard to see how a significant fisheries management initiative such as this can be evaluated without any reference to those clear and unambiguous statements of law and policy governing this area.
There are repeated references to conducting a fuller impact assessment after the conclusion of the present consultation. Surely, though, consultees cannot give meaningfully informed responses if the likely impact of the proposals hasn’t been assessed. The same could be said of the repeated promises to evaluate the effects of displacement. It is shocking that a process which claims to be based in evidence can state that “Analysis is on-going to understand the displacement impacts of HPMAs”. If the impacts of the proposed measure have not yet been studied, how can these radical measures be imposed? Livelihoods are at stake and yet are treated as an afterthought.
To state that a decision will first be taken and its implications examined later is entirely inconsistent with principles of integrity, objectivity and accountability that lie at the heart of good governance. Far from a proper impact assessment, much of this document reads like an attempt to gather the information that, according to the Benyon Review, should have been collected before the selection of sites was first made.
Site Level Assessments
The consultation exercise so far has made clear that ministers are preparing to make decisions on the flimsiest information, extracted from broad-scale existing data sources, rather than comprehensive site-level surveys. This is true of both ecological and socio-economic data used to prepare the short-list of candidate sites. This has been referred to during the various consultation meetings as a google earth approach to evidence. When peoples’ livelihoods are on the line this is not good enough. Neither is it adequate to rely on a 12week consultation to fill the gaps.
The fishing industry and the wider public should have confidence that the effort has been taken to understand what is at stake, and what it is that HPMAs are for.
Given the scale at which ecological and socio-economic evidence has been gathers so far (the “google earth approach”) it will be of the utmost importance to collate evidence at site level, prior to making any definitive decisions.
It is absolutely essential that the views of the fishing industry at site level are fully taken account because it is here that some idea of the impact of the current policy approach can be understood. A cosmetic box-ticking consultative exercise will not suffice.
Allonby Bay
The impact assessment wrongly identifies this site as being in the Northumberland IFCA region. It is impossible to know whether the failure to correct this glaring error before publication is the result of a lack of understanding, or a lack of care – and difficult to decide which is worse.
It is profoundly worryingly that “recovery timeframes were not assessed for this site”. This statement is suggestive of a very incomplete understanding of both the status of the site and the aim of establishing an HPMA there. Why has the site even been included in this proposal if the assessment has not been completed?
Bafflingly, we are told that “With limited disturbance in this area, Allonby Bay represents a relatively natural ecosystem”. The report seems to have concluded that fishing there is doing no harm, in which case why is it being proposed to ban it? There is simply no proposed link between the conservation objective – such as it is – and the contemplated conservation action. Furthermore “Impact [of a fishing ban] on local communities could be significant” because the vessels operating there have a high degree of reliance on the site. If fishing is not adversely affecting the ecosystem and to ban it would cause significant economic harm to local families, how can such a step possibly be contemplated?
Lindisfarne
The inadequacy of the site information and the impact assessment process are starkly demonstrated by the proposed Lindisfarne site. Given the displacement effect and knock-on consequences and solid opposition from the local community, it is inconceivable to us that Lindisfarne could be designated as a HPMA.
All of the general concerns regarding displacement apply here.
North East of Farne Deeps
Although not the most heavily fished areas off the North East coast, two reasons present themselves as reasons why designation of NE of Farne Deeps would be misconceived:
- It is recognised that the impact of fishing on the ecology of the area has been negligible
- Displacement of the fishing activities that do occur in the area will concentrate impacts in other areas leading to potential ecological degradation and socio-economic impacts there, including some near-shore zones
Dolphin Head
It is the absence of a coherent government policy to account for and deal with the displacement effects of vessels which currently work in this area that is the principal reason why designation as an HPMA would be a stepping stone to socio-economic and ecological harms.
The failure to consider shipping when proposing to create a HPMA at Dolphin Head is a bewildering omission. The sea’s surface is listed as a conservation feature and yet the high volume of shipping passing through the site is ignored. It seems clear that some sectors are being privileged in this process, while fishing is targeted.
Not only is this region already heavily used and host to a variety of infrastructure developments, it is also the location of our most significant maritime interactions with EU member states, with all of the post-Brexit complexities that entails. Should an HPMA be imposed on this already convoluted situation, the neglected issue of displacement will prove especially disruptive.
We strongly endorse the comprehensive consultation response submitted by the South East Fishermen’s Protection Association which raises a multitude of valid and unanswered questions regarding this site and the Government’s HPMA policy generally.
Silver Pit
The Silver Pit has been fished since the mid-nineteenth century. It cannot seriously be suggested that we can know what this ecosystem looked like before its use by humans became firmly established. What purpose is served by stopping food production in an area where it has been conducted for 170 years?
Moreover, the environmentally deleterious consequences of displacement will be particularly severe in this location. Historically, it has primarily been fished with mobile gear, by French, Scottish and southern English boats. The surrounding shallow waters are extensively fished by the local potting fleet. A longstanding agreement between mobile and static gear fishermen has ensured that these two sectors have coexisted successfully for decades.
Imposing an HPMA here would displace the mobile gear boats onto the surrounding shallow ground, in an attempt to recoup some of their economic losses. Bottom trawling effort would, therefore, be displaced from a location where it has occurred continuously for generations and onto a region where it has never taken place. If fishing activity is causing ‘degradation’ as claimed, this measure will not reverse it: it will substantially increase it.
Fisheries management
For all these sites then, we are not certain what the current ecosystems contain; we are not clear about what they ought to look like; we cannot state what steps must be followed to bring about the desired change; and we will not know when the endpoint has been reached. Seemingly the only thing that can be specified about these HPMAs is that fishing must be stopped.
It is clear that the sites have been selected so as not to interfere with the operations of some marine users (offshore wind, shipping, aggregates dredging). The desire to conserve the marine environment has been conditioned by a reluctance to engage with industries perceived as having greater national strategic significance. We submit, however, that food production – both for the UK population and for export – and the provision of jobs in coastal communities, are worthy of equal consideration. Instead, this whole process is predicated on an assumption that some industries are more important than others – indeed, are more important than marine conservation – and must be prioritised.
This does not look like a conservation measure: it looks like a fisheries management measure. As such, it is entirely inconsistent with the promise in the Fisheries Act 2020 that “the management of fish and aquaculture activities is based on the best available scientific advice”. It also fails to respect the commitment in that Act that fisheries management should be conducted through the development of a Joint Fisheries Statement.
The process being followed looks like an attempt to circumvent the careful, considered and collaborative decision making process envisaged in the draft JFS (“The use of best available evidence and scientific advice, transparent decision making, and partnership working, will be core principles that will underpin delivery”) and instead to privilege the views and demands of an unrepresentative constituency far removed from the locations that will be subjected to these new under-the-radar fisheries management regimes and the views of the people who live and work there.
Conclusion
We can only speculate on why the Government has decided to push ahead with pilot HPMAs armed with little more than good intentions. The thrust of our response is that good intentions on their own are not enough, and there is sufficient reason to understand that the fishing industry will be harmed by the displacement generated by this premature and ill-considered initiative.
The present government’s emphasis on securing food security and economic viability, sits very incongruously with a marine policy approach that will undermine both.
Notes
- When the scientific community evaluated the effects of a seasonal closure of a large area of the Northern North Sea in 2004, it concluded that:
- The measure had made little difference to the spawning stock biomass because much of the uncaught cod was caught outside the closed area or after the seasonal restriction had been lifted
- The Dutch beam trawl fleet had been displaced onto pristine ground previously unfished
- The Scottish demersal fleet was forced to work on grounds full of immature haddock, where there was an exceptionally high level of discards as a result
- There is a direct parallel between the Government’s current policy on HPMAs and the EU landing obligation adopted in 2013, which was similarly driven by good intentions but skated over the practical implementation issues, in a rush of legislative exuberance and political opportunism. The evidence suggests that overall discard rates per trip for all quota species was higher in 2019 than in previous years in the North Sea, Irish Sea and Celtic Sea. This indicates that the same or greater % of the catch is being discarded under full implementation of the landing obligation than beforehand.
http://randd.defra.gov.uk/Document.aspx?Document=15357_MF1262_English_catch_and_discard_patterns_during_phased_implementation_of_the_Landing_Obligation.pdf In other words things have been made considerably worse.
[1] https://www.legislation.gov.uk/uksi/2005/1605/contents
[2] Note that NQS accounted for c.50% of the value of English fisheries in 2019 – MMO, UK Sea Fisheries Statistics.
Jim Evans, Chief Executive of the WFA-CPC, said, “We have worked very closely with the NFFO over many years, and it seems a logical step to now apply for formal membership to better fight the many issues confronting our members.”
“The spatial squeeze, the future management of shellfish and quota species, and supporting our fleets through turbulent times, all require the hard work of a vigorous professional representative organisation, and we recognise that operating within the NFFO fold will strengthen our arm in these vital areas.”
Barrie Deas, NFFO Chief Executive said, “We have many individual Welsh members and Jim Evans has been a valued co-opted member of our Executive Committee for many years, but the time has come to strengthen our bond at organisational level, recognising that the Welsh Association will always have a distinctive national identity and role.”
The WFA-CPC will henceforward have two seats on the NFFO Executive but will retain its individual identity and direct lines of communication with the Welsh Government.
It will participate in all of the NFFO’s policy decisions. Its members will be eligible for grants made through the NFFO Training Trust.
“The contribution made by the Welsh Fisherman’s Association is already immense, not least in the area of fishing vessel safety, training and crew welfare. It makes sense to harness all that energy and goodwill for the broader good, he added.
“Given the way we have fought together to ensure a fair deal for fishing in the past and the turbulence that we can see ahead of us for the future, not least to defend access to our fishing grounds, unity and working together is absolutely essential”, said Jim Evans.
“That is why this move at this juncture just makes sense.”
Persistently high and volatile fuel costs and the scale of potential displacement from customary fishing grounds are the new threats to the viability of our industry.
The Fisheries Act, the Joint Fisheries Statement and the development of fisheries management plans offer a pathway to a more agile and adaptive fisheries management system in the UK. This will however involve a huge amount of work and will take place within the constraints described above.
A united, vigorous, national organisation to provide the fishing industry with a strong voice where it counts is a prerequisite if we are to have any hope of shaping our future.
For 45 years the NFFO has made sure that government of the day knows, with absolute clarity, the considered unified view of the fishing industry in England and Wales. The need for a unified industry speaking with a single voice has never been stronger.
Fuel Costs
The most immediate challenge facing our fleets is undoubtedly the high cost of fuel. The price has, for several weeks, been hovering around the point where it becomes no longer viable to go to sea because earnings no longer cover costs – of which fuel is the most significant component. Approaches to government for a short-term support package have been rejected on the ground that fishing still has the duty rebate on red diesel and fishing is only one amongst many sectors facing difficulties. Fishing, however, as price takers, rather than price makers cannot, unlike other sectors, simply pass on higher fuel costs to the consumers. When vessels are forced to tie-up the whole supply chain is affected. The NFFO has asked what contingency plans have been made by the government to deal with the situation, should supplies dry up – so far without response.
Ukraine
In addition to adding to the spike in energy costs, the war in Ukraine has had profound knock-on effects, some of which impact on fishing. A revaluation of energy policy has triggered an accelerated expansion of offshore wind and the relaxation of the consents process. Both of these have potentially profound implications for the displacement of fishing activity.
A rethink on food security is also under way. The UK’s negotiating priorities in this year’s autumn fisheries negotiations may prioritise access to cod and other whitefish species previously sourced from Russia. Russian scientists and data have been suspended within the ICES system so certain stock assessments may be below the usual standard.
The war in Ukraine has and will continue to have major impacts on fishing and fishing policy.
Following the impact of covid related lockdown, the fuel price crisis highlights the absence of well-thought-out contingency plans to deal with a variety of shocks impacting primary producers and supply chains. Caught-out by surprise each time and reacting in an uncoordinated, unplanned, ad-hoc way is simply not adequate. More robust planning is required but short-term support is the urgent immediate necessity.
Offshore Wind and NFFO/SFF Spatial Squeeze Report
The expansion of offshore wind at pace is a major contributor to net carbon zero. How that expansion is handled will have profound consequences for the fishing industry, as spelt out in the jointly commissioned NFFO/SFF Spatial Squeeze report, undertaken by authoritative consultants, ABPmer, and published earlier this month (See Annex). Offshore wind will have an immense impact on where we can fish but the difference between the worst-case and the best-case scenarios is very significant. Much can be done to mitigate displacement through careful site planning and design decisions but here is no sign yet that the Government has a coherent policy to deal with fisheries displacement.
Given the intensity of the proposed expansion of floating wind platforms in the Celtic Sea, the Federation has formed a regional group through which to share information and coordinate response to the multiple licence applications in the pipeline. This is a model that may be appropriate for other areas too.
Marine Protected Areas and Displacement
This is also true of management measures within marine protected areas. With accelerated timetables for management measures and the introduction of highly protected marine areas, government policy has largely substituted a bulldozer approach for the evidence and dialogue-based approach which preceded it. We know that fisheries displacement can generate unintended effects and the scale of displacement implied by the government’s energy and nature conservation policy is likely to be a major factor in the future of our fisheries and fisheries management. A summary of the Spatial Squeeze and the worst-case scenario is reproduced at the end of this report. The report will now form the platform on which we will fight for recognition of the displacement issue and for an adequate joined-up Government response to protect food production areas and systems.
Bottom Trawling/Landing Obligation
A persistent anti-trawling drumbeat against trawling has been a feature of fisheries politics for two or three years. As around 58% of the UK’s catch is made by this method and the calls for a ban have been at the level of slogans rather than serious, considered, evidence-based, policy proposals, it is all to easy to dismiss these efforts as incidental noise. What makes these campaigns dangerous, however, is that politicians and decision-makers can be trapped by populist politics and their own electoral self-interest into knee-jerk reactive measures. The classic example of this has been the EU landings obligation, for which the UK government is actively seeking the exit door without conceding the principle of minimising unwanted catch.
The strongest safeguard that we have in this regard is that one of the eight objectives in the Fisheries Act is that management measures must be evidence-based. Providing food for people to eat is the strongest argument in favour of bottom trawling and its detractors have yet to address the practical consequences of the policies that they advocate. Every fishing method (indeed every human activity) has an environmental impact which must be managed and minimised and there is much work going on in this field. The work of Ray Hilborn and his team in Washington University have made plain that despite the misinformation peddled by its detractors, fishing has one of the lowest ecological footprints of any food production systems. This is not to deny that in both terrestrial and marine spheres that there are biodiversity challenges. We, as an industry have a responsibility to make further progress but this must be done in a way that is evidence-based, proportionate and recognises that food security is a key element in the matrix.
Risk, Safety, and Training
Over the past 12 months, our Federation has greatly strengthened its work in the area of fishing vessel risk assessment, safety and training. A revamped Safety Committee, under a new chairman, Nigel Blazeby, and the appointment of an experienced and energetic full-time officer, Charles Blyth, have begun to encourage the MCA to move towards greater two-way communication with the industry and to assist vessel operators’ compliance with the complex raft of safety rules. Although it is early days the signs are very encouraging. The NFFO is committed to high standards of safety aboard fishing vessels and is more than ever convinced that active engagement in the risk assessment process is the means to achieve high levels of compliance. A particular focus has been to bring a degree of common sense and realism to the new under-15m safety code and to have an approach to vessel stability that has a degree of flexibility to meet varying circumstances. A meeting with Transport Minister, Robert Court emphasised that the problem lies not so much with the Code but the MCA’s approach to surveys. Representations to the Maritime and Coastguard Agency show early signs of having an impact. The Federation will continue this twin track approach of helping members and the wider industry achieve compliance, whilst making the case for a more flexible means of achieving high standards aboard all classes of fishing vessel.
Crew Welfare
Like many parts of the UK economy, parts of our fleets have become dependent on labour sourced from overseas. There is a particular responsibility on us to ensure that crew, whether recruited domestically or from overseas, are recruited fairly and treated well. It is well recognised that the Government’s own immigration policies have created an obstacle to using the skilled worker route (as opposed to relying on inappropriate transit visas) which increase labour vulnerabilities. There are strong legal safeguards for crews, not least in ILO 188, but enforcement – and prosecution when abuse is identified – is the key to stamping on those who misuse the system. The whole fishing industry should not be the subject of character assassination on the basis of actions of a few. Neither, however, should those who abuse their crews be protected from prosecution.
Bass
Seabass is an important fishery for many different vessels in many locations operating a wide range of gears. This heterogeneity makes managing this fishery a challenge, added to by a considerable recreational fishery and backdoor sales from unlicensed vessels to restaurants and retail outlets.
In fisheries negotiations, the NFFO in recent years has focussed on reducing the number of bass discarded dead as a result of rigidities in the catch limits applied. Discarded dead bass caught as unavoidable bycatch achieves nothing in rebuilding the stock and is the source of massive frustration within the industry.
Against this background it will be interesting to see the progress made by Defra/MMO in developing one of the first fisheries management plans for bass, using novel ways to ensure that everyone involved in the fishery’s voice is heard. The tricky part will be in defining a way through the many voices to a sustainable and profitable fishery based on a well-designed plan. One of the issues to be addressed is the degree to which, as a shared stock, it will also be a jointly managed stock with the EU, or whether the UK flows a separate path.
Shellfish
The NFFO was instrumental in setting up the Shellfish Industry Advisory Group, which now provides an effective voice for the economically important but previously underrepresented shellfish sector. With Seafish providing a dynamic secretariat, the umbrella group and its crab/lobster, whelk and scallop sub-groups) have taken the lead in the development of fisheries management plans for these sectors. This may provide a model for the often referred to but rarely defined concept of co-management. The shellfish sector, in representative terms has leapfrogged from poor cousin to possible exemplar and the NFFO should be proud of its role in achieving this progress. Many challenges lie ahead, including the management of non-quota species (see below) and displacement, but the sector is now much better equipped to deal with these.
Non-Quota Species
The Trade and Cooperation Agreement sets tonnage limits for EU vessels fishing non-quota species in UK waters (40KT) and UK vessels fishing in EU waters (12KT). In addition to this lack of symmetry, which echoes the distortions of the CFP, there are deep concerns about the transparency and accuracy of catch reports through which these complex multi-species, multi-gear and multi-jurisdiction fisheries will be managed in the future. In England and Wales, the value of landings of non-quota species (which range from the highly valuable to the economically negligible) exceeds the value of landings of quota species. This gives an idea of how important it is to get management of this complex and varied sector right. The flawed approach in the TCA and the emerging understanding of the task ahead has led the (UK-EU) Specialised Committee on Fisheries to suspend the enforcement of the agreed tonnage limitsin 2021 and 2022. Agreement on a multi-year strategy with the EU is a priority for the Specialised Committee but there is a mountain to climb in an area which, as we have seen, has the potential to become highly politicised.
Inshore Fisheries
In recent months dissatisfaction has been vocally expressed on some parts of the coast about heavy-handed management, glaring errors, and a wilful disinclination to deal fairly and openly with the industry. Some IFCAs have been singled out for particular criticism and a Defra review of the IFCA system is under way. Not all parts of the coast have the same experience and the Federation has opened a dialogue with the Association of IFCAs to identify problem areas and discuss possible solutions.
The hugely successful conference The Future of Inshore Fisheries held in London in 2018 has had a mixed legacy. It was inspirational for many, providing a glimpse of how we could manage our multi-faceted inshore fisheries with high levels of participation from those in each fishery, and working in cooperation with fishers, fisheries scientists, and fisheries administrators (co-management). The conference spawned several initiatives, including regional fisheries groups around the coast, as Defra and the MMO seek to find better ways to communicate with the industry. The establishment of the Shellfish Industry Advisory Group is another strand which took its lead from the conference. In the North-West England a project involving the MMO, Seafish, the NFFO and local fishermen, seeks to address a range of issues associated with remoteness from markets and the seasonality of catches.
Although the myth-busting conference inspired a commitment to work on the basis of evidence and cooperation, covid undoubtedly set back the timetable and a priority now must be to reinvigorate the conference energy and rebuild momentum.
2026/Regulatory Autonomy/ Joint Fisheries Statement
Although there are few in the UK fishing industry that would see the Trade and Cooperation Agreement with the EU as anything other than a defeat, a disappointment and a setback, the TCA does not represent the CFP status quo. Although many CFP rules have been incorporated into UK domestic legislation (as EU retained law) the UK now has the scope to diverge from those rules when it its deemed necessary or desirable. In addition to regulatory autonomy over the fisheries within the UK EEZ, the UK now negotiates as an independent party in international fisheries agreements. This is significant.
The Fisheries Act 2020 and the Joint Fisheries Statement provide, respectively, a new legislative and a policy framework which over time will allow the development of a tailored fisheries policy for the UK, mainly through the implementation of fisheries management plans. This is a positive development but will require enormous effort and commitment to bring into reality. Work has begun on a tranche of frontrunner fisheries plans, including for shellfish, bass, flatfish in the Channel and Southern North Sea and mixed demersal species in the Channel.
The NFFO’s work within Parliament to secure a Fisheries Act that was fit for purpose has been widely acknowledged. This has been followed by an extensive and balanced response to the draft Joint Fisheries Statement. Work is underway on frontrunner fisheries management plans. Together these three strands represent the architecture of our future fisheries policy and so deserve maximum attention.
2026 marks the end of the transitional period which allows EU fleets to operate freely within the UK EEZ. After that point access will be a feature of annual fisheries negotiations. We can expect both the EU and the UK to manoeuvre for best position ahead of and during those negotiations, complicating the already complex task of managing shared stocks through the Specialised Committee for Fisheries.
Mixed Fisheries
A disproportionate amount of time is spent on managing the mixed demersal fisheries. Single species stock assessments provide only limited guidance when setting TACs in fisheries where stocks may be exhibiting different trends and conservation status. Zero TAC advice is not particularly helpful for fisheries managers in these circumstances. There are signs of a more flexible and subtle approach may be viable using real time catch information to help skippers avoid hotspots of vulnerable species. Cod in UK waters and spurdog are two front-runners for this particular approach.
Meanwhile, ICES continues to develop advice that shifts away from single species advice which allow sustainable harvesting across the range of species in a mixed fishery
Fisheries Science Partnerships
The NFFO has championed cooperation and mutual understanding between fishermen and fisheries scientists for over twenty years. The original Fisheries Science Partnership was a ground-breaking initiative through which data gaps were addressed through projects involving fisheries scientists and fishermen working collaboratively.
The concept has been picked up by the UK Seafood Fund. Although there are concerns that research organisations are better placed to access the necessary funds, there are signs that the fund will help to underpin fisheries management with good data. The bottom line is that is not possible to manage a fishery effectively on the basis of inadequate of inaccurate information. FSPs address the gaps.
NFFO Services Limited/ NFFO Training Trust
Our commercial division continues to make a major contribution in support of the Federation’s representative work and to minimising frictions between fishing operations and major offshore infrastructure development in the oil/gas or renewables sectors. The company regularly makes donations of £100,000 to the NFFO Training Trust to help young fishermen through certification and for fishing vessels to purchase certain types of safety equipment and for the education of the public about the fishing industry.
We owe a debt of gratitude is to Mr Bob Casson, chairman of the NFFO Training Trust and the other trustees whose efforts make the Trust work.
Markets
Leaving the EU single market and customs union carried the inevitable consequence of increased export documentation and higher costs. Although the initial period of disruption and delay at the border lasted only a few months, there has been some consolidation as smaller firms making smaller consignments have struggled with the new regime. Steps to streamline the export process have been taken and must go further. There has been, however, a very strong rebound from these changes and the covid lockdown and demand from the continent and elsewhere overseas is generally high. The exception to this broad picture is with those firms dealing in bi-valve molluscs who have had to face an obdurate and immovable Commission and have suffered badly.
The degree to which trade sanctions will be used as a political tool in the future in relation to the Northern Ireland Protocol, Ukraine, or post-TCA adjustment period changes is an open question. There is however, one fundamental feature in this relationship. The UK has immense fish and shellfish resources in its waters and there is huge demand in Europe for those resources. Numerous businesses on both sides of the Channel depend for their survival on that trading relationship to work smoothly.
Conclusion
There is only one conclusion. With all that is going on across multiple fronts, and what we can see is coming towards us in future years, it is absolutely essential that the fishing industry in England and Wales has a vigorous, inclusive, responsive, organisation at national level to ensure that its voice is heard.
Consultation 2, which has taken the comments and views of stakeholders from Consultation 1 and those made at the Authority meeting in June 2022 is attached. This consultation considers the different methods, systems or criteria that the IFCA might use to manage, limit or control access to a specific management area.
As with Consultation 1, they will also be listening to the views of all interested stakeholders by inviting them to go and talk to them on 8 and 9 September 2022 at the Inn on the Lake, Gravesend, Kent. For information on how to book a slot to talk to Members of the IFCA on either of these days go to http://cocklereview.kentandessex-ifca.gov.uk/ and click on consultation 2 on the timeline.
One-to-one officer support will be available to support stakeholders navigate the complex legal area of licence allocation, which the Listening Phase highlighted was poorly understood. Stakeholders will be able to book a specific time to talk to officers, either in person at the Ramsgate or Brightlingsea office, or over a Zoom/Teams/Facetime call during the period 27 to 29 July 2022. Should you wish to speak to an officer then email info@kentandessex-ifca.gov.uk to arrange an appointment. Please note that this session will just be used to explain the consultation document and answer any questions about the document; the one-to-one session will not collect evidence from stakeholders.
For more information on the proposed process and timeline go to http://cocklereview.kentandessex-ifca.gov.uk/
Completed questionnaires must be returned to info@kentandessex-ifca.gov.uk by 16 September 2022
If you require a paper copy of the questionnaire then this can be posted out to you or collected from one of their offices. Please ring the office on 01843 585310 and they will arrange that with you.
In recent months there has been considerable turbulence between Inshore Fisheries Conservation Authorities and fishermen in their districts. In some areas the relationship has become toxic. Enforcement appears arbitrary, or even vindictive. Errors have been made. Nobody wants a law-breaking, free-rider in their area, but the IFCAs are increasingly seen as policemen rather than modern fisheries managers working for the benefit of the fishery and the fishing community. The unhappiness is not universal – IFCAs, fleets and issues vary around the coast – but the NFFO’s continuing tour of the ports is hearing, over-and-over again, about disproportionate enforcement, and a breakdown in what was previously a reasonably harmonious and positive relationship between the regulator and local inshore fishermen.
There have always been tensions in certain IFCAs, and of course personality clashes can play a part, but the dissatisfaction is so widespread and the breakdown in relations is appearing in so many areas that a systemic cause is suggested. What has changed?
Causes
Covid hasn’t helped and lockdown created barriers to communication between face-to-face IFCA officers and fishers. Behind that, however, lies a fundamental change in IFCAs’ role. This change is driven by national policy on Marine Protected Areas. 50% of English inshore waters are now covered by MPAs of one kind or another and fisheries management within the district now takes second place to management measure within MPAs. The role of IFCAs is now largely dealing with the forest of paperwork associated with MPA assessments. Critically, because the burden of proof lies with the regulator and the industry, and the default is closure of the fishery, the burden falls on each IFCA to demonstrate that each fishing method is compatible with the conservation objectives of each site. The funds to deal with this new burden were inadequate from the start and the result is a fundamentally changed relationship between the IFCA and the fishermen in their district. Fisheries officers have been leached away to service the MPA assessment machine and have left fisheries management to lower qualified staff.
IFCAs are in the frontline in the delivery of the government’s policies and are bearing the brunt of the resulting frictions.
What inshore fishers are experiencing now will also be the future for offshore fisheries as the government maintains its gung-ho rush to extend the MPA network, presumably in order to burnish its green credentials. The result inshore is the breakdown of relationships, mistakes and blunt, disproportionate policing rather than modern fisheries management based on the consent of those whose activities are being managed.
When fishermen feel persecuted it is hard for them to see their IFCA as their saviour but unless IFCAs produce positive MPA assessments the law says that the fisheries must close.
It is this that is driving the way in which IFCAs’ role has changed and the way that IFCAs are now being perceived by many fishermen.
I have spoken at length to the Association of IFCAs and they are insistent that the role of IFCAs is to manage the fisheries within their districts sustainably, for the benefit of the community. This aspiration is, however, being systematically undermined by their role in managing the MPA process. A collegiate relationship is being replaced by something much more toxic.
This is the classic law of unintended consequences but unless it is addressed it will poison fisheries management from top to bottom in the coming years.
Solutions
It’s important not to give up on co-management and the dialogue between Defra/MMO and inshore fishers is improving. There is so much to prepare for, including fisheries management plans that impact on inshore fisheries.
Certainly, at the level of the Association of IFCAs, there is a commitment to the regulators working closely with the industry on evidence-based management to support sustainable fisheries and the fishing communities that depend on them.
But:
- Individual IFCAs must reaffirm their commitment to proportionate and risk-focused enforcement
- Communication must be improved
- Greater effort must be made to get fishers’ voices heard
- Central government must re-evaluate their nature conservation ambitions in light of the spatial squeeze, unintended side-effects, displacement and the impact on the way IFCAs are being forced to operate: a degree of joined-up government is required
- Fisheries management should be put back at the centre of what IFCAs do
- Joint initiatives to address unlicenced fishing – especially for bass – should be undertaken, to improve and cement relationships
- The relationship between IFCAs and the fishing industry should be reset to put cooperation back at the centre
- IFCAs should not be tasked by central government to undertake tasks that they are not resourced for, or equipped to deliver
Paul Gilson
Chairman
NFFO
July 2022
Contracted by the National Federation of Fishermen’s Organisations (NFFO), with the Scottish Fishermen’s Federation (SFF), marine consultancy ABPmer has developed a series of scenarios to better understand and communicate issues surrounding future spatial pressures on fisheries.
The report was produced among mounting concerns within the fishing industry across the UK, about the loss of fishing grounds to an array of competing spatial pressures, of which offshore wind and marine protected areas top the list.
Suzannah Walmsley, ABPmer Project Manager, said, “Fishing provides enormous value in producing low carbon, healthy and sustainable food, contributing to our food security and supporting our coastal communities. But the lack of effective safeguards for fishing from marine spatial planning means that these benefits are under threat.
The fishing industry recognises the need for marine protected areas, and the importance of net zero targets, but the extent of likely future spatial pressures is of a scale not previously seen, and will have significant implications for fisheries and their future viability.”
The report emphasises the need for a strategic approach to understanding and dealing with the potential for displacement. To that end, the report provides insight into the impact of spatial squeeze on fishing, and highlights the importance of enabling co-existence and co-location where possible, so that marine developments and nature conservation occur in a way that is compatible with the continuation of fishing activity and the viability of fishing businesses.
Intended as a starting point, the report emphasises the need for an improved evidence base for fisheries in marine spatial planning, a strong and effective voice for fisheries in the planning process, and that displacement is avoided, minimised and mitigated as far as possible through technology choice, design and siting, innovation and management.
The event provided a useful update and opportunity to discuss on a number of important developments within the ICES system that have significance for commercial fisheries, including:
- Quality control (there had been 10 adjustments to ICES 2021 advice)
- Implementation of an ecosystem approach
- Governance of data quality
- Stakeholder engagement and communications
- The science/management required to keep fishing mortality on track once target levels have been achieved
- The need for better and more timely mixed fisheries advice
- Ensuring that fisheries science is continually sense-checked against reality
- Constraints imposed by covid and the temporary suspension of Russia from the advice process
Divergence in Stock Perception
In one of the most significant developments for the fishing industry, effort will now go into establishing a mechanism within the ICES system to deal with those circumstances where there is a radical divergence between the industry and scientists on the fortunes of a particular stock. Experience has shown that whilst science generally provides a reliable understanding of biomass and fishing trends, occasionally things can go wrong. Important input data can be missed, developments in the fishery misunderstood, assessment models and their assumptions can be flawed. Likewise, different perceptions can arise from an incomplete understanding of what is going on – from either side. Counting the number of fish in the sea was never a straightforward task.
Fishing vessel operators have a direct everyday experience of stock trends and developments and if that experience is seriously at odds with the outcomes of stock assessments, the issue requires investigation. A proposal will now be developed as a matter of priority to deal with such cases. In the recent past retrospective adjustments have had to be made to correct the science. The assessment process is the best chance that we have for generating an objective and impartial understanding on which to base management and harvesting decisions – but it is not infallible.
The proposal to establish a new mechanism for dealing with circumstances where fishers’ experience suggests one thing and the science something else will be done at speed and will complement the periodic benchmark process. This initiative is a sign that ICES has confidence that it mainly gets things right. In those cases where there are radically different perceptions the issues will now be addressed directly. Western mackerel recently provided an example where there was such a divergence. In that case a retrospective adjustment to the science was required. North Sea cod is currently another stock that merits deeper analysis – with suggestions that the assessment model may not be fit for purpose. In the case of North Sea cod, ICES has already agreed to a meeting of fisheries scientists, fisheries managers and fishers later this year initially proposed by the industry. That meeting will take a root and branch look at the science of North Sea cod, including data inputs, models and management.
The MIACO meeting, and this particular initiative, underline how far the ICES system has evolved from the days when it was a black box into which only a few elite scientists were allowed to peer and from which smoke emerged at the end of each year. There are now multiple opportunities for fisheries stakeholders to observe and participate in the assessment process. This latest development is a further step in delivering a system of robust, authoritative, impartial system of stock assessments and advice that is open to internal and external criticism and comment.
Displacement
The MIACO meeting also provided insight into ICES work on the increased spatial pressures on fisheries, particularly those arising from the accelerated expansion of offshore wind and displacement effects from marine protected areas. ICES made clear that it had made extensive preparations to provide advice in this sphere – and has already provided some advice on spatial pressures. ICES largely works in response to specific requests for advice. The potential for fisheries displacement and how that this could be mitigated, rather inexplicably, have not been the subject of requests to ICES. The member countries of ICES are those who generally make those requests. Given the apparent inertia within both the UK and EU to even begin to address the consequences of displacement, this gap is hard to comprehend.
The absence of a coherent joined-up approach to understanding the consequences of fisheries displacement arising from policy decisions on environmental protection and offshore wind is a glaring omission of political will and direction. If the ICES system is set up to address the issues but no requests are forthcoming, something is far wrong.
Ecosystem Based Management
In a world where everything is connected, the need for management approaches to take into account the wider ecosystem has become more apparent by the year, especially against the background of climate change. The challenge of how to implement an ecosystem-based approach formed part of the MIACO discussions. A non-exhaustive list of what is required included:
- Mediating the necessary trade-offs between say, offshore wind, MPAs, and fishing (businesses, communities, employment, food security)
- Understanding the consequences of management actions
- Breaking down silos in science and government
- Assessing the impact of climate change on species distribution and species mixes as part of mixed fishery advice
- Incorporating the social and economic dimensions
- Protecting existing balances or assisting the shift to new equilibriums (for example protection for forage as well as target species)
- Making uncertainties more visible
- Adapting ICES advice to take account of ecosystem-based management
- Incorporation of climate change into ICES advice
MIACO
MIACO is an important annual event that provides for the two-way communication that is essential if scientists and stakeholders are to understand each other.
At the same time, the government has failed to provide any coherent policy to deal with the inevitable displacement effects of its marine protection policies and the accelerated expansion of offshore wind. As 38% of English waters are now designated as marine protected areas, a spatial squeeze, displacing fishing vessels from their customary grounds is now an imminent reality. Forcing inshore fishing vessels to steam further offshore, or offshore vessels inshore is a recipe for chaos. Since the issue was raise with ministers in May 2021, there has been no sign that the issue has moved beyond lip-service. Post-Brexit, in which the Government failed to deliver on its windy rhetoric, the calculation must be that there are more votes in its green credentials than fishing.
Understanding the cumulative impact of potential displacement of fishing activity should be a government priority. but clearly isn’t. The fishing federations will have more to say about this towards the end of this month, when a report on the spatial squeeze is published.
NFFO members are providing landings information that illustrate although reasonably health grossings are being made, after deductions for fuel earnings for crews are risible.
In one example a vessel in the south-west made a landing worth £11,0489 but fuel costs swallowed £10,416.
In another case, a landing of £44,176 and a fuel bill of £29,068 left £1516 to be shared amongst 8 crew.
A third example was an inshore vessel after eight days fishing made £8706 but faced a fuel bill of £5234, leaving £927 for the crew.
These examples illustrate that the current situation is unsustainable are at the point beyond which vessels will have to tie up.
The NFFO has made the case to ministers for a support package. Fuel costs are already supported in France and Spain through emergency measures.
The Government’s response so far has been that every economic sector is hurting because of high energy costs and there is no case singling out fishing for special treatment, despite the uneven playing-field with Europe. Whether the Government will sustain this hardnosed approach in the face of widespread tie-ups, with knock on effects for the whole supply chain, is for discussion.
Contingency Plan
Fishing is an area of primary production that is of enormous regional, economic and cultural significance but is beset by a wide range of challenges. The NFFO had to fight hard for a standalone support scheme when fishing was left out of terrestrial schemes during the covid lockdown. Markets have now largely recovered but high fuel costs are undermining the viability of the fleet. No doubt there will be a market correction at some point but by then the damage will be done. There is an urgent need for Treasury intervention now and in the longer term for a contingency plan to deal with these kinds of shocks. Simply put, unlike many other industries, fishing vessels are price-takers and cannot simply pass on higher costs to the consumer.
Repurpose Existing Funds
Many in the industry are of the view that at least some of the funds allocated to the fishing industry should be repurposed to deal with this crisis. The EU has unlocked funding support for member states under a crisis mechanism of the European Maritime and Aquaculture Fund (EMAMF) and are in the process of utilising unspent European Maritime and Fisheries Fund (active between 2014-2020) to deliver a second round of support. The UK contributed to the EMFF scheme when it was a member of the EU, so a second round of support would potentially make the UK eligible to claim funds. https://thefishsite.com/articles/eu-to-support-aquaculture-businesses-hit-by-russia-ukraine-war
The EFRA Parliamentary Committee is currently examining the effectiveness of the UK Fisheries and Seafood Fund and, depending on the Committee’s report there might be scope for repurposing some of the £100 million allocated to fishing for that purpose.
Spasm
We have witnessed these kinds economic of spasms before. But they can create lasting damage – first and foremost in recruiting crew – if the government adopts and maintains a laissez faire approach.
The NFFO will continue to make the case for financial support. We have learnt from experience that the Government always says no – until it says yes.
The Future Catching Policy (FCP) is a new phrase in English and Scottish fisheries policy circles that signals a move away from the discredited EU landings obligation, which remains as part of EU fisheries law retained by the UK, for the time being. Both England and Scotland are working on new policies to replace it. A proposal applying to England is expected in the autumn, while Scotland has recently concluded a public consultation on its proposals.
The Landing Obligation was born out of the later stages of the CFP reform of 2013, catapulted to centre stage off the back of the campaigning TV series Hugh’s Fish Fight. The result was classic media induced moral panic, political opportunism and top-down policy making sutured onto the rest of the CFP, without adequate thought or care. The assumption that a ban on the landing of all quota species could live happily alongside the other fisheries policy objectives was flawed. Problems soon emerged, with conflicting regulations and the new word “choke” entering the fisheries lexicon as countless days were spent by policy makers trying to fix the varied policy conflicts that it generated, in the end to no avail. As the UK approached Brexit, an outline for a future discard policy was laid out in the 2018 Fisheries White Paper. The present initiatives pick up where the White Paper left off.
There are now important questions to address, the most important of which is how to design a discard policy that works to reduce unwanted catch without undermining other aspects of fisheries policy, or the economic wellbeing of fishing businesses and communities.
Pragmatists Versus Enforcers
Policy makers are at the centre of a debate between two camps that have very different views about what should be done. On the one hand, there are those who have experienced implementing the Landing Obligation, including those in industry that see the inherent conflicts and a need to introduce sufficient flexibilities in order for a discards policy to work within the wider management framework. On the other, is the view held principally within the green lobby that the Landing Obligation hasn’t worked because it has not been adequately enforced. They see the answer as the widescale introduction of remote electronic monitoring (REM) such as CCTV as the solution, and are assiduously campaigning for it.
Although some basic contours exist in the Fisheries White Paper on extending flexibilities and use of REM, it is too early to say where policy is heading in England. In Scotland, the direction of the consultations on the future catching policy and REM, suggests an exercise in papering over of the tensions between the two camps. The Scottish proposals pick off some of the less challenging fisheries such as the pelagics and scallopers where it sees that REM can be applied without too many difficulties. But on the demersal trawl fleet, where the problems of chokes in mixed fisheries has been the most acute, although there are a few technical proposals including mesh sizes and escape panels on targeted fisheries and juvenile de minimis adjustments, the proposals on REM are less sure-footed.
Regrettably, instead of an upfront front dissection of the issue of chokes and their significance when under a system of REM, the Scottish consultation assumes that a few technical changes and adjustments through the annual TAC setting negotiation processes will be sufficient. In this context it considers the use of REM boils down to less relevant considerations over whether it is implemented on a reference fleet (i.e. sample of a fleet) or across whole fleet segments. This misses the central issue.
Principles for Reform
If a reformed discards policy with a role for REM is to become a workable policy, then the spectre of fishing vessels tied to the quayside due to chokes, under-utilisation of mixed fishery stocks, and businesses left in an intermittent state of financial freefall, must be avoided. A new approach should recognise that:
- Tackling unwanted waste is an important objective, but the importance of discards and priority given to their minimisation should be proportionate to the risk they pose to the management system and the conservation of stocks. Discard policy should be balanced and work in harmony with other management objectives. Introduced in a top-down, heavy handed way, the Landing Obligation has made few distinctions on this front.
- Managing discards, in particular, needs to be in harmony with the system of setting TACs, but the CFP prioritised MSY based on single species stock assessment over managing discards. Although mixed fishery advice is produced that can help to examine discard risks, these are produced very late in the annual decision-making cycle. The assessment system therefore needs to be reformed to provide decision-makers with more up-front information on setting TACs in the context of discards risk so that decision-makers can make informed and transparent decisions over the trade-offs can be made between conflicting fisheries objectives. This could have the advantage of also promoting greater public confidence in the scientific basis underpinning the TAC setting process that is presently lacking, as parts of the green lobby (either naively or cynically) exploit decisions that veer from single stock MSY targets as evidence of management failure.
- Given the above, more attention should be given, especially in lower risk settings, to legitimately setting TACs that are more inline in the short-term with avoiding TAC induced chokes, rather than a one dimensional focus on MSY targets.
- Where discards cannot be avoided through technical and operational arrangements, have no value, or have high survivability, then practical de minimis exemptions should be more liberally applied as a system release valve than at present.
- Importantly, the development of individual fisheries specific fisheries management plans ought to provide the opportunity for the integration of customised discard policy into future management decisions
The Lesson of Cod Avoidance
Prior to the Landing Obligation, the UK was a pioneer in the applying REM in discard reduction with successful schemes in both England and Scotland as part of cod recovery measures in the North Sea. Under this Fully Documented Fishery scheme, vessels were awarded additional quota subject to REM verification of their catches. In England, EEFPO vessels were active participants of the scheme that ran for 11 years until 2020, after which insufficient quota was made available for it to work practically. TAC setting for the cod stock had reached the point of being unable to reconcile a marked divergence in its abundance in the northern North Sea compared to the south, as climate change has affected the stock that in southern waters is at the limit of its range.
This scheme, and others like it, have demonstrated the conditions under which REM can add value to incentivise the minimisation of discards through catch verification, and conversely when it cannot. The cod avoidance scheme worked for EEFPO vessels when there was sufficient quota available to facilitate leases and swaps to avoid a choke given the abundance on the grounds, but the need to minimise catches and the incentive as part of the scheme to do so. This was achieved by making seasonal and real-time adjustments to fishing patterns depending on the target stock (haddock, saithe, whiting), where skippers “learned by doing” and adjusted their tactics over time to minimise the cod catch.
This experience should be central to understanding the conditions under which REM can make a positive contribution to fisheries management in mixed fisheries.
It makes no sense to use REM as a means to reinforce a system of enforcement in circumstances when the system of management is fundamentally in a state of dysfunction. Something has to give.
The topic has been raised in recent fora such as the Fisheries Management and Innovation Group. As a result, the NFFO and the MMO met recently to discuss it further. Among the issues raised with the MMO were that responding to the challenge of spatial squeeze and addressing potential impacts, with measures that might be considered including appropriate safeguarding of the most important fishing areas, facilitating viable co-existence, and broader management of displacement, requires a joined-up approach set in the context of spatial planning for all interests.
That will need collaboration across government and regulators, a well-informed and cohesive industry response to the spatial squeeze, and a closer dialogue between the two. The resulting outcomes are likely to be more effective if the fishing industry and regulators of marine space work together. It is therefore incumbent on government and the fishing industry to work to address potential ‘spatial squeeze’ and the impact of displacement as far as possible. It will take effort, goodwill and intelligence to deliver well-thought through approaches.
Barrie Deas, NFFO Chief Executive, said:
“This was an important meeting in which there was an honest appreciation of the spatial challenges faced by our industry. There was a solid commitment to consider all the existing tools available to address adverse impacts on the most important fishing areas – accepting that there are both economic and socio-economic factors to take into account. Displacement can have profound knock-on consequences and so the best strategy is to assess this in the context of wider marine management and planning. Finding ways to pool data, share information and knowledge is an important first step. It is our ambition to continue the dialogue started in this meeting over the coming months. We will have to wait and see, given the undoubted complexities involved, whether the dialogue will lead to appropriate outcomes, but we cannot afford not to make the attempt. The consequences of doing nothing are too high and the pace of change too rapid.”
Amongst the issues discussed were:
- Drawing on existing marine plans, there may be measures that could be applied now
- The difference between fixed turbine windfarms and floating wind
- Different forms of co-existence
- How to ensure that fishing is treated in an equitable way with other sea-bed users, given that a licence to fish grants the right to fish, but no specific legal guarantee over access to fishing grounds – unlike farmers, fishers do not hold property rights over the grounds that they fish
- Accurate and relevant data is essential, but the methodologies employed and the assumptions on which policy decisions are made can be as important as the data used in determining outcomes
- Achieving a balance between risk and precaution in marine spatial planning
- The importance of effective monitoring in arriving at the right policy decisions
The meeting was reassuring to the extent that the MMO and NFFO share a similar understanding of the scale of the challenges ahead, and the need for relevant evidence and engagement. There was also agreement that working closely together, whilst challenging at times, would be more effective for all concerned.
The federations emphasised that fuel costs are currently at a level that jeopardises the viability of parts of the fleet. This has been offset – for the time being – to some degree by high fish prices, but the industry is caught in an inherently unstable and fragile balance.
Against this background, the federations asked the minister for the Government’s contingency plans for the not unlikely situation where parts of the fleet are forced to tie-up. This could materialise quite quickly over the summer. The minister was reminded that vessels unable to go to sea because they cannot not operate profitably would impact on the whole supply chain.
The point was also made that cost and earnings date produced by Seafish evidenced the parlous state of large parts of the industry. In addition to direct fuel costs, the increasing price of ancillary but oil-based products, such as rope and sheet netting, are spiralling upwards too.
The Minister pointed to high fish prices which mitigated the situation to some degree, and to the challenges in persuading the Treasury to provide support against the background of difficulties being experiences across the whole economy.
Although the fuel price crisis remained at the heart of the discussions throughout, the energy crisis, the Russian invasion of Ukraine and home-grown government policies which intensified the challenges facing the industry were discussed. This included displacement, shortage of whitefish in the market, labour shortage and immigration policy.
The federations emphasised the role that fishing played in providing food security, both for domestic consumers and as part of global food security through trade.
The industry representatives made the case for a collaboratively building a case to Treasury as a contingency should the position become materially worse in the next few weeks and months.
The Fishermen’s Welfare Alliance (FWA) welcomes the ITF’s conclusions that the transit worker visa isn’t fit for purpose and doesn’t meet the requirements of the UK’s modern fishing industry. Those parts of the industry that employ non-UK fishermen through the transit visa system have been lobbying government for many years for improvements, and were successful in having fishermen recognised as skilled workers in the new immigration system, but other barriers mean this route cannot be used in the way that industry had hoped. We would welcome the opportunity to look at this in more detail with government, including the Home Office and Defra.
Whilst we are still studying the detail of the report published today by the University of Nottingham, at first reading it contains much that fishing industry representatives don’t recognise, and is not representative of the situation across the UK as the report itself states. As industry representatives, we deplore and condemn bad practice and crew members being badly or unfairly treated, regardless of their nationality or immigration status. Many of the non-UK crew employed in the UK industry have been returning to work on the same vessels for many years and have contracts that take ILO188 and UK employment law into account. There is much that industry is doing to continually improve working conditions, including agreeing recently to work with a major UK retailer to help prepare non-UK crew for working in the UK fishing industry. We will continue to drive forward to ensure that all our workers are respected and well cared for.
The government’s Maritime and Coastguard Agency (MCA) has recently carried out a concentrated inspection campaign – making unannounced visits to hundreds of fishing vessels across the UK, and has not reported problems with working or living conditions aboard. We have a world-class regulatory system in the UK which is not raising systemic concerns or major problems on this issue. But there is more that government could do to support both the industry and the crew – for example, through keeping better records of transit visa workers, and having agreements with other countries about the standards and practises expected of crewing agencies in third countries that provide crew into the UK.
The meeting was convened by the Shadow Fisheries Spokesman, Daniel Zeichner MP, who has heard of cases at first hand during his port visits to the East Coast and the South West.
At the outset of the meeting with the Minister, the Federation emphasised its absolute commitment to improving safety across the whole fleet. It pointed, however, to the unavoidable conclusion the code is being applied in a way that is giving rise to multiple examples of extreme stress from the small-scale fleet as vessels face inspections under the new rules. Daniel Zeichner read out an email from one fisherman whose livelihood had been put at jeopardy despite a 45-year career without incident and who was, along with his family, under extreme stress as a result.
The Minister listened courteously and asked a number of forensic questions, as would be expected from someone who trained as a barrister. The NFFO’s central message was that the code is young but already it is clear that the way it is being implemented requires a different approach.
The Minister committed to examining the issues raised during the meeting and the Federation expressed its willingness to work closely with the MCA and the Department on improvements.
Charles Blyth, recently appointed as the new NFFO Safety lead, and who has a background as a naval architect and MCA surveyor, highlighted the Federation’s central concerns and suggestions for improvements.
- The roll test stability assessment in the New Code of Practise (which is only indicative and not an objective means to test a vessel’s stability) is resulting in perfectly capable vessels with faultless safety records being tied up or forced to spend significant amounts (£6-8000) on stability book and MCA approval. – MCA should revise this policy and allow for compliance with alternative stability assessments such as Heel test and/or Offset load test to help reduce economic impact on industry
- Previously certificated vessels are being required to alter their original design (often against manufacturer recommendations) to adhere to the CoP. Fisherman are concerned that this blanket approach may make certain vessels less safe and create over reliance on machinery (such as bilge pumps) which can fail. – Specific water freeing arrangements should be considered on a risk based, individual approach by MCA, taking into account their original designs purpose, fishing method and area of intended operation.
- Fisherman are annoyed at the significant time and expense (£147 per hour) they are currently facing when waiting for specific outcomes such as stability approval and decisions relating to individual vessels. There are many instances of stability approval taking years to complete. – MCA should agree to set a service standard on their work for stability; one week to make decisions, especially when vessels have been tied up by the MCA is reasonable.
- Fisherman are confused when faced with new stability chapter and how to present vessel for stability assessment. If they fail, they are expected to pay for a second visit- this can mean a big economic impact for small scale fisherman and coastal communities. – MCA should waive charges for return visits for stability purposes for under 15m FVs.
- There are concerns about the unfair use of detention for lack of compliance with new CoP– MCA should only detain/ remove certification in the most extreme cases and ensure that all other possible avenues of compliance are sought before such drastic action; i.e. restricting loading, limiting area of operation etc.
- Fishermen are being overwhelmed with complex information sources and the new CoP language (e.g. there are 4 different definitions of a ‘new vessel’) -MCA should pursue a simplified CoP with assistance given to FV owners as to what the new CoP means for their vessel. The amount of information sources should be consolidated (information regarding the roll test and what it means for a vessel is currently spread out over 4 different documents) and be written in a way that can be easily understood by fishermen
- There are concerns with the attitude and lack of engagement of surveyors used to inspect fishing vessels. Many fishermen are very anxious about their vessels being tied up for reasons they don’t understand, leading to lack of income, job losses, economic impact in coastal communities – MCA should offer human element training for surveyors to help them engage and work alongside fisherman to improve safety. The employment of surveyors with backgrounds other than large vessel merchant shipping (e.g ex FV skippers) to assist in MCA inspection should be explored
The Federation will be engaging with the MCA on this agenda in the coming weeks and months and following the meeting is hopeful of enlightened political guidance from the top.
The British fishing industry can rightly be proud of supplying healthy food, with a significantly smaller environmental footprint than most other sources of protein.
At the same time, however, we cannot deny the reality of climate change and the threat to our way of life that it represents. All industries – all individuals – should want to minimise their impact on our environment and reducing carbon emissions has become the focus of these efforts for many.
Burning fuel is a major driver of climate change, but producing food for a growing population takes a lot of energy. The terrible war in Ukraine and the soaring fuel prices that have followed it have given extra urgency to the need to resolve this dilemma. New solutions are needed.
Fortunately, fishermen have always been innovators and the NFFO has taken the next step in its response to the fuel and climate crises by commissioning a report (‘Electrifying the Fleet’) into alternative ways of powering fishing boats. The work was completed by a team from the University of Hull, led by Dr Magnus Johnson. A grant from the Fisheries and Seafood Scheme made the study possible, supported by additional funds from the Future Fisheries Alliance and the North Sea Wildlife Trusts.
The report’s authors conclude that, while no off-the-shelf solutions are currently available, existing technologies could be used to build hybrid diesel-electric systems that would achieve significant energy and emissions savings for static gear fishing boats.
Spreading the benefits of electric propulsion to other sectors of the fishing fleet will require technologies to be further developed and refined and there is an obvious need for investment in harbour infrastructure to support battery charging in the future.
It is clear, though, that the first steps towards practical electric propulsion for fishing boats are being taken. It is equally clear that inaction on this issue is not an option.
The new appointment of Charles Blyth, who has until recently served as a Marine Surveyor with the Maritime and Coastguard Agency (MCA) aims to assist Federation members maintain the highest safety standards.
Chairman of the NFFO’s Risk Safety and Training Committee, Nigel Blazeby, said: “Charles is an experienced and respected Fishing Vessel Surveyor; in this role he will be pivotal in working in collaboration with government agencies and member’s vessels and crews such that NFFO becomes a beacon in managing risk at sea, and that the fleet is operated in the safest way possible and that crews are properly trained and receive the best welfare provision.”
NFFO Chief Executive, Barrie Deas, added:
“We are very lucky to secure the services of someone of Charles’s calibre. Helping our members and the wider industry to adjust to the new safety requirements, whilst engaging continuously with the MCA to ensure that inspections are fair, consistent, and proportionate will be at the heart of this role. Keeping fishing vessels and their crews safe is of paramount importance, which we see as a joint government/industry challenge. Clear lines of communication are of the utmost significance, and this is where this role can help.”