NFFO Trust Fund Grants

Chairman of the Trustees, former NFFO President and Chairman, Bob Casson, said:

“We are pleased to announce these grants that will directly help fishermen in a variety of ways. We accept applications from regional bodies such as producer organisations and NFFO regional committees to ensure that the monies are going precisely for the purposes that are identified in the ports.”

“I would like to take this opportunity to acknowledge the generous financial support of NFFO Services Limited, the NFFO’s commercial arm.”

“The grants can make a huge difference to individuals by funding training and certification as well as providing lifejackets and portable radios. This is a way that the commercial success of our services company can be spread throughout the broader industry. The level of funds available for distribution is directly linked to the profitability of our company each year.”

“The Trustees have agreed in this round of applications to make grants for safety training, skippers’ certificates, lifejackets, refresher courses hand-held radios, and financial support for local training associations.”

“By decentralising the decisions on where this money is to be spent – so long as it is in line with the Trusts purposes – we can direct it to precisely where the local industry feels that it is needed. We also encourage recipients to explore whether these funds can be used to lever in match funding for items eligible under the European Fisheries Fund.

Such areas, purportedly intended for scientific experimentation and providing a “reference” for monitoring MCZs, would ban many human activities including any form of fishing. According to official Natural England/JNCC guidance they should include examples from all broad scale habitats and habitats and species identified as features of conservation importance in each of the 4 English regional project areas.

However, the 2009 Marine and Coastal Access Act, which provides the legislative requirements for MCZs has no requirement for such no take zones.

Dale Rodmell, NFFO Assistant Chief Executive, said: “There is absolutely no need for draconian areas of “no-man’s land” for the purpose of measuring ecological improvement in MPAs which would be readily evident from any general time-series programme of monitoring. Such proposals are ill thought through and show a careless disregard for people’s livelihoods in order simply to give a free reign to conservation scientist’s experiments.”

“In many respects they represent the epitome of the conservation land-grab, anti-people philosophy that has never been far below the surface amongst parts of the conservation lobby and patently within the government’s conservation agencies which are prescribing such areas. This is just one of a range of shortcomings in the government’s MCZ policy that has so far failed to give careful consideration to balancing sustainable marine use with conservation.”

Regional MCZ Projects

English regional MCZ projects are now in a last minute dash to include reference areas in their network recommendations. This comes amid widespread condemnation that the process is too rushed to refine the network sufficiently within the timeframe of the projects, which must complete their recommendations by the end of August this year.

“When the regional projects have been tasked with attempting to develop a network recommendation in the space of little over 1 year, there is precious little time to have an effective dialogue on reference zones which in practical terms constitute planning a second MPA network.”

“Understandably representatives of the fishing industry who have been engaged in the projects in order to limit harm to the industry have deep reservations about engaging over such proposals. It is still essential, however, that the harm that such areas would cause is emphasised as strongly as possible.”

Data Limitations and Bias

The process of site selection is further hampered by the inadequate information base upon which to make robust decisions and regional project groups are faced with selecting areas in many cases virtually blindly in order to meet the official guidelines.

“When in the majority of the planning areas there is very limited ecological data that identifies what is actually there to protect, you know that decisions cannot be robust and this calls into question what scientific purpose these areas could really serve.”

Harm to Vulnerable Inshore Fishing Communities

What official ecological data does exist tends to be concentrated in coastal areas. This has created a tendency to bias MCZ proposals to those areas and reduce the flexibility for choice.

“When this is applied to what will become no take zones we are talking about at a stroke destroying local fishing communities who are restricted from moving elsewhere and who may have fished those waters sustainably for hundreds of years.”

“One has to seriously question whether this is really what society wants from Marine Protected Areas; scientific playgrounds and barren fishing communities that were once vibrant? After thinking about that one might also consider whether we have planned any equivalent areas on land. The answer to that is a definite no, so why are we doing it at sea?”

The current General Manager will retire shortly and the NFFO is seeking a committed individual who combines a strong understanding of the fishing industry, with an ability to identify and secure commercial opportunities.

NFFO Services Limited recently celebrated 25 years of safe and successful provision of liaison and guard-ship services to the offshore oil, gas, cable and renewable industries. As a company we are looking for someone to build on that experience and success.

The successful candidate will have a demonstrable track record in the fishing, fishing liaison, or offshore sectors, will have first class communication skills and an ability to work collaboratively.

An attractive remuneration package will accompany the post.

Applications should be sent to:

The Chief Executive

National Federation of Fishermen’s Organisations

30 Monkgate

York

YO31 7PF

The closing date for applications will be Friday 15th April 2011.

What’s the problem?

The fishing industry presently loses significant value as a consequence of weak/absent markets for the full range of edible or otherwise usable species which are currently caught. This phenomenon is a significant cause of discarding (dead fish thrown overboard), and also contributes to fishing effort being focused on a narrower range of edible species, some of which are overexploited. While inefficiencies of the current regulatory system, imperfect markets, lack of information, poor product development, weak business skills and a failure to work co-operatively are all thought to be contributing to this market failure, a complete understanding of the causes and their relative importance is largely unclear.

Figure 1: The Fishing for the Markets project logo was designed with help from the pupils of Freethorpe Community Primary School, Norfolk. The winning picture was created by Eireann Hurley.What are the aims of the project?

This programme of work, also known as “Fishing for the Markets?, will provide the detailed and informed actionable insight needed for the subsequent development of effective future market interventions. These interventions will be designed to mitigate the core issues described above.

The programme of work includes a substantial element of field and market research to build the evidence base. The programme embeds customer engagement on many levels, contributing to the evidence base by way of capturing the collective intelligence and generating support for any solutions identified.

The work will identify the barriers and incentives needed to produce effective market-driven behaviour change and will serve to:

• Maximise the value from the existing catches (i.e. from a broader range of species).
• Decrease the reliance on the pressure stocks.
• Reduce wastage of natural resources.
• Support fishing communities.
• Increase revenue to fishers and drive greater efficiency in the supply chain.

Which policy areas will the research inform?

This research programme will help to deliver Defra?s objectives to “promote increased domestic food production”, sustainable food production from the marine environment and “pursue a zero waste agenda”.

It will also inform Defra?s policy to minimise discards, the Sustainable Access to Inshore Fisheries (SAIF) project and the reform of the Common Fisheries Policy.

Other UK customers that will benefit from this research are; consumers, the fishing industry, fish processors, retail & food service sectors, buyers & sellers of fish, providers of business and marketing support to the fishing industry, NGO’s and seafood accreditation organisations. Internationally, the work will also be of interest to the European Commission.How can we make better use of all the fish that are caught in English commercial

fisheries?

Fishing for the Markets commenced in December 2010 and has six distinct work packages (WP):

What are the results from the project and how will they be used?

WP: Evidence and Policy liaison will be provided by a specialist researcher who will directly facilitate linkages between the programme and policy development.

WP: The Customer and Market Intelligence work package will raise the profile of the core issues underpinning the programme of work whilst gathering insight and experience from a range of individuals and organizations along the supply chain, about existing market practice and any un-tapped potential for under-utilised species.

WP: Qualitative research methods will be employed in the Social Research work package to explore species interest and demand in informed fish eaters and at the high-end food service sector and ethnic cuisines.

WP: The Fish Markets work package will review the strengths and weaknesses of current fish market operations, identify best practice and areas for improvement.

WP: The Industry Skills component will explore the business development and marketing skills needed to get a greater diversity of species to market.

WP: An Evaluation Strategy will appraise the most appropriate methods and metrics for evaluating future interventions which address the core issues in market-led sustainability. Results are expected to be available by late May 2011.Where can I find further information about this and related research?

For more information about discards see: http://ww2.defra.gov.uk/environment/marine/cfp/discards/

For information on related research please contact Defra’s Marine and Fisheries Science Unit: marinescience@defra.gsi.gov.uk

Although the pot fisheries for crab and lobster have been in an enviable position over the last decade, certainly compared to the traumas faced by the whitefish sector, there is mounting pressure to take conservation steps to ensure that they do not go down the same path.

Although the scientific assessments of the various shellfish stocks in UK waters lack a high degree of precision, the principal concern is to find a way to cap fishing effort at current levels and to prevent a further expansion of the fishery that could undermine this broadly healthy position. One of the perceived dangers lies with the amount of latent fishing effort contained in dormant or underutilised licence entitlements that if unleashed on the shellfish stocks, could spell disaster. Concerns over seasonal overproduction in the crab fisheries have also been a driver for a more restrictive regime that has applied to date.

To date the NFFO has advocated an approach to shellfish conservation based on a strong regional dimension and local management where possible, to reflect the diversity of conditions found around the coast; as well as taking into account the differences between the inshore fisheries and the more nomadic fisheries. We have actively supported inte rnational voluntary measures to curb seasonal overproduction in the crab fisheries.

TACs and Quotas for Shellfish?

From preliminary discussions, the signs are that Defra will shortly propose the introduction of TACs and quotas for the brown crab and lobster fisheries, linked to a system of rights based management. This would set overall catch limits. Individual vessel’s access to the resulting quota allocations would be linked to some form of previous track record in the shellfish fisheries. The main justification for this approach, which will amount to the most radical management intervention in the shellfisheries since the introduction of minimum landing sizes, is that without a means to cap latent effort, any future conservation measures could be undermined by an increase in the number of vessels currently prosecuting other fisheries turning to shellfish.

Pot Limits

This new approach in the shellfisheries marks a departure from the previously favoured policy – a national pot limitation scheme. Although there are examples of successful pot limitation schemes (Brittany, Northumbria) these tend to be those applied in relatively local circumstances where conditions are broadly similar for all vessels. Progress always seemed to stall on a national scheme because of foreseeable problems of how to achieve equity across widely differing fleets and fishing operations, and the balance between effective enforcement and bureaucracy.

Divisive

There is no disguising that the approach now chosen by Government will be divisive, within the industry at large and within the NFFO.

On the one hand are dedicated shellfish vessels, committed to the shell fisheries, who are willing to support sensible conservation measure to ensure the long term health of the stocks but who see no point in their sacrifice, if the success of these measures then simply attracts additional effort into their fishery. Moving forward on shellfish conservation requires an effective ring-fence to provide security for those who have invested in and are already committed to the shellfish fisheries.

On the other hand, there are those who have not been active in the shellfisheries in recent years but who hold an entitlement to fish for shellfish that can be activated in the future. Under the expected Defra proposals these licence holders would lose this entitlement and with it the option to diversify into shellfish in the future. They stress the importance of maintaining flexibility to change target species and gears, in the ever changing context of inshore fisheries. This is an argument against the progressive pigeon holing of the fleet that can have adverse economic and conservation consequences.

Practical Considerations

Over and above divergent views on how to deal with latent effort are a number of practical considerations on Defra’s preferred approach.

• The first is with the logic of imposing quantitative limits (quotas) on the UK fleet when other EU fleets will not be similarly constrained. A solution to this problem could lie in pressing for similar limits in other member states but there is a natural reluctance to follow the same path as the whitefish industry into an EU controlled system of TACs and quotas
• The second consideration concerns the fact that a large proportion of the fleet is under-10 metres in length and until relatively recently there has been no EU or UK obligation for this category to submit catch returns. This raises questions over the validity of basis for allocation of share of the quota
• A third question relates to whether scientific assessments are precise enough to make satisfactory recommendations on TAC levels in the crab and lobster fisheries

Comprehensive Reform

It is clear from discussions held so far that shellfish conservation through the vehicle of rights based management is only part of a much wider package of reforms envisaged by Defra. These would stretch across the inshore fisheries, and across both under-10 and over-10 metre whitefish quota management.

We will know more when the various consultation papers are published later this spring but it is clear that shellfish is intended to be part of a broad programme of reform and that dealing with the issue of latent capacity will be at the heart of the approach.

In an area as complicated as shellfish conservation, one of the most important ways in which policy mistakes can be avoided is by through the preparation of a thorough impact assessment. Although these can vary enormously in scope and quality, the best provide clear guidance on the potential consequences of various options, including the status quo.

NFFO Shellfish Committee

These are not simple issues and the NFFO has never patronised its members by suggesting simplistic solutions where these are not available. When the proposals are published, the NFFO Shellfish Committee will study them and then meet to agree NFFO policy on this undeniably complex and potentially divisive issue. It is of the utmost importance that all parts of the Federation’s membership with a stake in these issues attend the meetings to ensure that all sides of the argument are taken into account.

The NFFO’s broad and varied membership can be seen as a microcosm of the wider industry complexes and therefore the Federation’s views on this issue are likely to be of particular interest to Government.

The RAC’s Demersal Working Group met to discuss the issue in Edinburgh and said afterwards that the NSRAC is totally committed to reducing discards.

It has already produced a substantial piece of advice for the EC on how this should be achieved in the context of the mixed demersal fisheries in the North Sea.

NSRAC chairman, Niels Wichmann, said: “We are very concerned to avoid the kind of knee-jerk political reaction to recent media attention on discards that, from experience, invariably produces a mess. Some of the worst legislation on the CFP statute book was created in this way.

“Our experience of the EU Cod Management Plan, and from other countries, is that effort control, days at sea restrictions, is not a solution to the problem of discards.

“A simple ban may produce good headlines for a few days but would not in itself achieve the desired result.”

“It is important to stress that substantial progress in reducing discards has already been achieved by different projects in diverse fisheries.”

The NSRAC is itself preparing a comprehensive list of discard reduction projects throughout member states to demonstrate their extent and diversity

“The key is that these measures are tailored to the specific conditions in those fisheries and have the active involvement of the fishers concerned,” added Mr Wichmann.

“The priority must be to continue this progress until we have achieved fully documented, low-discard fisheries across the board.

“This is not the time to revert to a top-down approach when the whole thrust of CFP reform is in the opposite direction for the simple reason that top-down hasn’t worked.”

Even where discard bans are in place, as in Norway, it has by no means resulted in the elimination of discards.

The NSRAC believes progress will be made by building on existing approaches which have already delivered significant discard reductions.

Mr Wichmann said there are different reasons for discards in different fisheries and progress is made by tailoring solutions to take these into account.

RACs are the formal channel for stakeholders to provide suggestions and advice to the EC and the Council of Ministers and Member States on fishing in Europe.

The NSRAC is comprised of fishing industry and other stakeholders, including environmental NGOs, anglers, a woman’s network and trade unions.

The Regional Advisory Councils are a key element of the 2002 reform of the Common Fisheries Policy (CFP).

They aim for better engagement of the people the policy affects and for more regionally-focused fisheries management.

For Emma Bonino, it was important to be seen to be tough. For Franz Fischler, it was impatience with the complexities of fishing, which threatened to eat into the time for his real preoccupation – agriculture.

For Maria Damanaki, it is becoming quite apparent that her time at DG Mare will be remembered for the degree to which she ignored the views of the fishing industry.

Whatever the reason, there is a discernible lack of real dialogue between the Commissioner and the fishing sector. This carries implications.

No Commissioner who had read the advice from the regional advisory councils, or talked in any meaningful way to the fishing sector could have entered the October or December negotiations in the way she did; alienating member states and behaving in an imperious manner as the bearer of some “truth” that has escaped the rest of us. It takes a certain talent to manage to get all member states to act in unanimity in opposition to the Commission’s proposal.

The fishing sector has become used to her brief appearances, at this or that meeting or conference, to lecture the participants, before departing to some more pressing appointment. Monologue rather than dialogue.

But it is not only the fishing sector who she is not listening to. As much as anyone, senior fisheries scientists were horrified at the thought that their work and advice would be politicised when she repeated the naive and unhelpful refrain “ just follow the science” – as though raw biological advice didn’t need balancing with management and socio-economic considerations .

Of course, it is not precisely true to say that the Commissioner does not listen to anyone. Doubtless like any unaccountable ruler there will be an inner circle and favourites, who filter the outside world for her. But this is dangerous for her and the rest of us. Only a frank and open dialogue can provide the kind of governance to which the Commission purports aspire.1

All this is having a corrosive effect on the RACs, who expend much time and effort preparing coherent and evidence-based advice, drawing on the wide and deep experience of stakeholders, usually on a consensus basis, only for it to be disregarded like the scribblings of a four year old.

The Commissioner’s political instincts appear to be decidedly top-down. As such there is a manifest contradiction between what she has said that the Commission will propose for CFP reform and her suggested approach to discards, one can now only wait with trepidation for the Commission’s proposals in May/June. Discard Ban and Effort Control

Apart from a fairly obvious attempt to shift the media heat on discards from the CFP onto the member states, what else could possibly account for the high-handed proposals2 that will be tabled by the Commission at the High Level Meeting on discards on 1st March? The Commissioner’s cabinet, or whoever inhabits her inner circle, has reacted to Hugh’s Fish Fight with a classic knee-jerk reaction and cobbled together an approach that flies in the face of RAC advice, hundreds of discard reduction initiatives and the direction of travel in CFP reform. The proposals include:

• A discard ban
• Effort control in mixed fisheries
• A mandatory catch quota system

Whoever the Commissioner is listening to it’s not the fishing industry; it’s not the RACs and it’s certainly not those member states struggling to administer the cod effort regime. And she is certainly not listening to the overwhelming majority of respondents to the Commission’s own consultation who called for an end to this type of top-down management that invariably fails to deliver results. And she’s definitely not listening to the experience of other countries where effort control has been tried and failed.

Just in case this article is misread as suggesting complacency on discards, it is worth noting that total discards by the English fleet have been reduced by 50% over the past decade. Maintaining this progress won’t be helped by this kind of superficial “We must be seen to be doing something approach”.Notes

1 Governance in the EU. Commission White Paper 2001

http://eur-lex.europa.eu/LexUriServ/site/en/com/2001/com2001_0428en01.pdf

2 Strictly speaking a suggested policy rather than a formal proposal, a “non-paper” in the jargon.

In many ways this approach is the opposite of the Big Society. Despite an expensive and elaborate process of “stakeholder participation” through four regional projects, the approach, designed by the previous government but implemented under the Coalition:

• Is an example of statism – the belief that society’s goals can best be achieved through centralised government controls
• Is superficially democratic and participative but for those involved, feels like a juggernaut speeding to a fixed destination
• Is impatient – it is on a fixed timetable at least in part to meet broader EU controls in the form of the Marine Strategy Framework Directive although the most immediate time constraints are self-imposed
• Is formulaic – despite different regional approaches, conformity is achieved through “Ecological Network Guidance” to ensure ecological (but not social or economic coherence) and there is a big-government back-stop if the regional projects fail to deliver
• Suffers from an incoherence at the heart of the project – we don’t know with any degree of precision what it is we are protecting, or how much of it to protect
• Is careless of the consequences for “small people” – the process has hardly begun to consider the consequences of displacement for fishermen, their communities or the knock-on effects in adjacent or distant fisheries

Even in the fishing industry, where the displacement effects of this approach are likely to be felt more acutely than any other offshore sector, it is acknowledged that there is a need to protect biodiversity and vulnerable species and habitats and that marine conservation zones have a role to play in achieving this. It is the way that the previous government and now the present government have gone about it that has given rise to concerns which have found their expression in the MPA Fishing Coalition.

What could a Big Society approach look like?

There appears to be no fixed ideas about what the Big Society looks like but it seems to centre on a move away from a top-down legislative approach to multiple initiatives at a local level with a high degree of involvement and control resting with citizens.

We are already well down the top-down road with MCZs but it is worth considering what an alternative approach might look like. It would be:

• Incremental. In other words, the process would start with a handful of experimental MCZs which would be trialled and tested before moving on to develop additional sites. At the very least this would avoid a car crash that such mega-projects are prone to.
• Adaptive. Lessons would be learned through these early MCZs and the problems encountered avoided subsequently as the number of sites is expanded
• Evidence based. The rushed process that we are witnessing relies on the formula that decisions are based on the best available information and science. But the quality of “best available” can be very low indeed. An adaptive approach offers the opportunity to build the evidence base to a level where there is a reasonable confidence in it and therefore that management measures within MCZs will have the desired effect.
• Participative. The current process has more in common with the ideology of nature reserves from the 1890s. One of the important lessons learned from these early experiments in nature conservation is that they will fail to provide the protection that they aim for if they ignore the needs of the local populations. Similar considerations apply to marine conservation zones, despite advances in monitoring and control technology.
• Win-win. MCZs established through a genuine process of engagement with the fishing communities could identify ways in which the design of the MCZ could be adapted to deliver advantages for both fishers and the environment. Trust is at the core of this approach: but there are few in the fishing industry who believes that the current process offers them anything other than harm. Those that are involved in the four regional projects (including the NFFO and many NFFO members) do so for reasons of self-defence).
• Transitional Support The hard part in the introduction of any new management regime is often the short-term impact – which of course can carry long term consequences. A more thoughtful approach would have woven into its fabric ways of easing the transition

Unease amongst Environmentalists

There are signs of mounting unease, even amongst the more thoughtful and less gung-ho environmentalists, about the monster that their enthusiasm has helped to create. The rushed process, the failure to give anything but superficial consideration to the issue of displacement and above all the nagging question whether marine protected areas are the best way to deliver Good Environmental Status as required under the EU Marine Strategy Framework Directive are all causing unease. A handful of pristine jewels surrounded by a degraded seascape – caused by the displacement of economic activities – does not seem like a huge step forward.

Even the civil servants charged with implementing the policy of the previous administration seem to appreciate that a wrong turning has been taken. Fear of loss of face seems the only motivating force driving the project forward, now that the money is about to run out and Natural England’s role has been redefined.

Contradictions

There is no sign however that policies will change any time soon; so we are left with a series of contradictions: a government committed to the Big Society implementing a Big Government approach; an environmental lobby anxious about the speed and perhaps even the direction of travel; and a fishing industry involved in the process but braced for the impact.

Hugh Fearnley-Whittingstall

KEO films

101 St John Street

London

EC1M 4AS

Dear Hugh

Fight for Fish Campaign

As you know the NFFO was pleased to support the Fight for Fish campaign and we are equally pleased to see that it has already had some positive effect. Demand for some of the low value species, like pouting, has increased as a direct result of the Channel 4 focus on fish, fishing and discards.

As we have said on our website, the programmes brilliantly illuminated the discards problem. Even if the campaign was a little thin on describing what is already being done to reduce discards, and what in practical terms can be done to move further, it provided the level of public attention that can translate itself into political and commercial action.

The main test of the Campaign’s strength, and whether discard reduction really has become a priority for the Common Fisheries Policy, will come later this year with the review of the EU Cod Management Plan. When the current plan was adopted in 2008, the Commission took the deliberate decision to set the North Sea cod quota at a level in which massive discards were inevitable. If we are to avoid a repeat of this economic, environmental and ethical catastrophe, the Commission will have to be persuaded that the avoidance of discards should be at the heart of their approach.

It is important for you to understand that there has already been real progress in reducing discards. Moving beyond posturing will require all parties to build on what has been done already. There is no single solution to discards because different kinds of discards have different causes; but there are solutions – tailored, customised initiatives that have already made a difference. None of these represent a panacea: there are none. Supported (rather than undermined) by the management system, we believe that discards could be progressively pushed to the margins rather than residing as at present centre stage. We draw your attention to some of these initiatives:

Catch Quotas: participating vessels provide fully documented catches and commit to no discards of cod

Trevose Seasonal Closure: provides protection for aggregations of spawning cod where and when they would be vulnerable and discards more likely

Square Mesh Panels: have dramatically reduced unwanted catch of either juveniles or by-catch of haddock and whiting

Catching for the Market: aims to align landing with what can be sold profitably

Cod Avoidance Plans (formal and informal): where skippers use their own knowledge and experience to avoid cod whilst fishing for other species and while stocks rebuild

Benthic Release Panels: provide beam trawlers with a means to reduce discards and maintain the quality of their catch

Irish Sea Double Panel Project: trials to reduce discards of demersal species in the nephrops fishery using a double square mesh configuration

Shrimp veils: permit the escape of small plaice and other species in this necessarily small mesh fishery

Real Time Closures: have successfully diverted fishing on vulnerable aggregations of cod and encouraged cod avoidance

50% Project: through involvement of skippers and social marketing reduced discards in the beam trawl fishery by more than 50%

Eliminator trawl and (variations on the same approach) allows cod to escape from a demersal net

Against and so far limiting all of these initiatives are three main drivers of discards – regulations that generate discards; unselective fishing gear; and low value species. The Fight for Fish campaign, if sustained, we believe could provide the dynamism and commitment to secure a major breakthrough in reducing discards of all three types. So far, this has been missing at the highest levels (although public hand-wringing has not).

Regulatory Discards

The most dramatic intervention that the Fight for Fish could make would be to ensure that the replacement to the current cod management plan (from Jan 2012 onwards) will avoid the obscene levels of discards witnessed during the current plan.

Secondly, the Technical Conservation Regulation (EC 780/98) is based around the notion of catch composition and is well overdue for replacement. Vessels are required to have on board the “correct” catch composition for the mesh size that they are using. This inevitably generates discards as “fish don’t necessarily swim in the correct percentages”. This is another sphere where the focused attention of the campaign could be useful.

And finally, each December the Council of Ministers on a proposal by the Commission make quota decisions for the coming year that increase discards. This is where the cosmetic approach to fisheries management is at its worst. At present this is the approach that is resulting in the discards of many tonnes of dogfish, skates and porbeagle shark.

Gear Selectivity

We are certain that huge steps can be taken in reducing discards by refining gear configurations. Indeed huge steps have already been taken. What prevents a further rapid movement in this direction is a complex mix of economics, mindset and inertia. It is not possible to disregard economics especially in fisheries like sole where small adjustments carry major consequences. However, the 50% Project gives a taste of what can be achieved when skippers are involved and enthused. More of this type of approach will deliver real reductions. The secret seems to be the right level of involvement, incentive and support, leaving the skippers to find their own technical solutions.

Low Value Species

The public and supply chain seems to have reacted quickly to the Channel 4 programmes promoting the use of less well known species. The challenge is how to keep this momentum. Having seen what can be done it would be very disappointing if this was now lost.

Blind Alleys

Again quoting from our website, if we are to make genuine progress in reducing discards it is important to knock a few blind alleys on the head.

• Some commentators have reverted to saloon bar logic: “just ban” discards. It is important however to understand that where a theoretical discard ban is in place, such as in Norway, it is the cherry on top of an entirely different approach to fisheries management – one that is adapted to the specifics of their fisheries. In Norway’s case the primary emphasis is on protection of juveniles, principally through a massive programme real time closures. This certainly works well to reduce discards, although even here there should be no illusion that discards have been entirely eliminated. But is difficult to see how a ban and the underpinning programme of large-scale RTCs could be workable in the much more complex and diverse mixed fisheries of the EU. Giving in to demands for a theoretical ban on discards would amount to posturing and would achieve roughly zero. We have already tasted this kind of knee-jerk non-solution with the 2008 ban on high-grading, as meaningless a piece of poorly thought-through reactive legislation as you are likely to find.
• Quotas are here to stay. The reason for this is that in fisheries where stocks are shared it is necessary to distribute the fisheries resource to the different member states, to Third Countries that have access arrangements with the EU, and to different groups of fishermen and vessel operators. Despite the rigidities of the present system and of operating a quota system in mixed fisheries, no one has yet been able to suggest a more effective allocation mechanism that would deal with the realities of shared stocks. The plain fact is that we have little option but to work to make the quota system function better than it does at present as opposed to ditching it. And there is much that can be done on this front. Catch quotas are one example. More efficient quota swaps and transfer arrangements are another.
• Replacing quotas with effort (days-at-sea) allocations, despite its superficial attractions to some, is a non-starter. Experience as well as academic economic theory confirms that effort limitation creates a perverse incentive which intensifies fishing activity during the period that the vessel is permitted to go to sea. One form of this is seen in technological innovation – what the Americans call capital stuffing. It is therefore an approach entirely counter-productive in conservation terms. Besides it lacks the precision of the quota system as an allocation mechanism.

All of this suggests both that there are practical, doable, ways of reducing discards but there are also pitfalls to avoid and that there is much to be done. We look forward working with you collaboratively to achieve a progressive reduction of discards in the ways outlined above.

Kind Regards

NFFO

Most fishermen in Northumbria would agree that it has survived the onslaught of the anglers’ pressures primarily because of the determined and resourceful efforts of the the NFFO Salmon Committee, led by Chairman Derek Heselton.

Over three decades, the Committee has marshalled evidence, worked with scientists and Government officials, harried politicians, exposed distortions and faced down threats, to make the case that the North East drift net fishery is one of the best and closely managed fisheries in Europe.

This, over the years has been a titanic struggle over shares of a scarce resource. Some of the richest and most powerful interests in the country have coveted the fish caught in one of the oldest coastal fisheries, to boost their recreational rod fisheries in the rivers. The angling lobby succeeded in closing the salmon drift net fishery in Scottish waters in the 1960s.

The Salmon Committee has fought back by repeatedly exposing the sham conservation arguments used by the anglers to try to force a closure of the drift net fishery. In fighting this uneven fight it has gathered impressive and sometimes unexpected allies to fight at his side.

Undoubtedly the most damaging setback came, in 1992, when Tory Fisheries Minister John Selwyn Gummer, using the shield of a review of the fishery, announced that the drift net fishery would be phased out on the grounds that it was “interceptory”. In fact, the review itself was a sound piece of work that was used import the political aspirations of the angling lobby into the salmon conservation debate. A moment’s thought confirms that all fisheries commercial or recreational, net or rod and line are “interceptory”. What matters from a conservation perspective, is the total out-take of fish, not whether they are caught in the rivers or at sea.

As the terms of the phase-out meant that drift net licences had to be surrendered when the licence holder retired, there has been a slow attrition of licences, subsequently accelerated by a licence buy-out when the anglers considered the phase-out to be proceeding too slowly for their tastes and put the majority of the money forward to buy out the rights of those prepared to sell.

There are now only 14 drift net licences issued but last years’ season was a good one with prices for wild salmon receiving a premium. Along with the T and J net fisheries, the NFFO will continues to support these small fisheries that have showed, over many years, a tenacity and fighting spirit that has ensured their survival against the odds.

NGOs like Ocean 12 and the International Federation of Fishworkers, and also some within the UK fishing industry, are also keen to draw a firm line between, on the one hand, small-scale artisanal fisheries and on the other large scale “industrial” fleets. The argument is made that the former are good from a number of perspectives and should be ring-fenced and afforded special advantages within the reformed CFP. The (often but not always, implicit) inference is that the larger vessels are bad, not to be trusted, too powerful, generally harmful and up to no good.

At this stage we should register an interest. The NFFO’s membership contains hundreds of small vessels. From the salmon drift net fishery in the north east to the hand-line mackerel fishery in the south west; from the beach launched vessels of the south east, to the shellfish fleets in Wales and dozens of creeks and harbours on the east coast, south coast, in the south west and Irish sea – some of the NFFO’s oldest and staunchest members operate small vessels. For those who need reminding, the NFFO played a pivotal role in overturning the proposed increase in the minimum landing size for bass that would have put many small operators out of business; and the Federation has also put forward the most progressive and coherent ideas for resolving the quota problems faced by parts of the under-10metre fleet. We have also made special efforts to include small vessels in the MPA Fishing Coalition to ensure that they have a voice in the setting up of marine conservation zones. Our annual membership subscription rate is scaled to be proportionate to vessel size and therefore earning capacity. The smallest vessel on our membership list pays £7. 26 per annum.

These examples demonstrate the NFFO’s commitment to the small-scale fleet; nevertheless, it is important not to be seduced (as the Commissioner appears to be) by an idealised, picture post-card version of the reality of our inshore fleets and by pantomime caricatures of small = good, big = bad.

It is our considered view that it is not in the long-term interests of the operators of small-scale vessels to be treated as a special, separate, category – even if the short-term these fleets receive a few sweeties in the form of preferential access to EFF grants.

These are the reasons why:

• Small-scale fleets play a unique role in terms of providing employment, sustaining fishing communities and as an entry point into the fishing industry. However, there is a fundamental interdependence between the small-scale and large-scale fleets. Port, marketing and management infrastructures all require the continuity of supply that the larger vessels with their ability to fish in poor weather bring. Without a range of vessel sizes, all operating in their different ways, on different grounds, in many cases it is doubtful if continuity of supply could be maintained. And without continuity of supply there would be catastrophic consequences for buyers, processors – and for many in the small-scale fleet itself.
• The fishing industry does not lend itself to a crude division and simplistic definitions that splits the fleet into two categories: inshore/ artisanal/ small-scale/ low environmental impact on the one hand; large-scale/ industrial/ offshore on the other. It is possible to find vessels that fit these categories at the extremes, but in-between it is also possible to find large vessels that fish inshore for some of the time; multiple small-scale vessels in a single ownership; and small vessels that fish 40 miles offshore at certain times of year – all examples contradicting the attempt to shoe-horn a complex reality into simplistic management categories
• Many fishermen began their fishing careers in small boats before moving on to larger vessels. Many also wish to spend the end of their careers in small vessels. This continual interchange between the small and larger-scale sector is valuable and should not be undermined by impenetrable but essentially artificial barriers
• The alternative approach, suggested by some, is to describe a category of small-scale, inshore vessels with very low environmental impact. It would then be for vessels to demonstrate that they meet those criteria in order to access certain kinds of preferential treatment. But this approach is not without its problems either. The critical questions here are: how is this category to be defined and what parts of the existing small-scale fleet (say under 12m or under 10m) would be eligible to join this select group; certainly some, but many of the existing fleets who doubtless consider themselves small-scale operators would not. This is a recipe for division, and arbitrary and unfair pigeon holing – in short a bureaucratic nightmare. In supporting this approach many of the existing inshore fleet would be turkeys voting for Christmas, even if it is not clear at the moment which turkey is destined for the table.
• It is clear from statements made by the Commission that in envisaging separate arrangements for the small-scale fleets, what is not under consideration is some kind of exemption from the conservation regime. If that is the case, then it is difficult to perceive what “separate treatment” might entail beyond preferential access to grants. But even here, there are problems beyond how small scale is defined. (The current EFF definition of small scale includes vessels under 12 meters but excludes trawlers). The drive for this approach largely comes from southern member states like Italy and Greece who historically have subsidised their large inshore fleets. To what degree any current or future UK government would want to go down this road has to be a moot point.

We are clear therefore that a separatist, protectionist, welfare, approach to the inshore fleets would be both unworkable and undesirable from the point of view of small-scale operators themselves. It would pigeon hole the industry to a greater extent than it already is; and it would entail an unhealthy degree of bureaucracy and leave the small-scale sector exposed to the whim of arbitrary political decisions in the future.

So, against this background what is the NFFO’s vision for the small-scale fleets?

• Strengthening the economic self-reliance of the small-scale fleet is the way forward. Removing the fate of the fleets as far as possible from decisions made by Government by developing self-management or co-management through their own organisations. Building the capacity within the small-scale sector to do this.
• Acknowledging the interdependence of the whole industry and working with other sectors for the general good; finding ways to ensure that the seats that are already available within the NFFO, on the RACs and other bodies are taken up by authentic representatives of the small-scale fleets
• Developing solutions to the quota problems that face the under 10m fleet that work for all parties along the lines proposed by the Federation, including putting in place safeguards against over- concentration of quota ownership.
• Building a united front and making common cause on the major issues confronting the industry, not least the displacement from fishing grounds by marine conservation zones.
• Developing a balanced policy on shellfish policy and latent capacity that take into account the views and interests of the small boat sector

In short, we think that the siren call of the separatists who want a kind of apartheid – separate development – for the small boat sector should be rejected as a half-thought-through approach, leading part of the small-scale fleet into a cul-de-sac of perpetual dependence – and the cutting the remainder loose to survive as they can.

The NFFO was founded on the principle of mutuality – fishermen providing support for those other groups of fishermen when they need it – irrespective of vessel size or where on the coast the vessel is based. It is a principle that has served us well and we will not be abandoning it just yet.

As talks continue, it has become increasingly clear that the elaborate superstructure that has been created to manage national fishing effort limits, required under the EU Cod Recovery Plan, often undermines the central purpose of achieving the reduction in fishing mortality – regarded as essential for the rebuilding the cod stocks.

As effort allocations to each member state have been reduced year-on-year, to meet the terms of the Cod Management Plan; and as vessel operators struggle to remain viable in any way that they can; the results are often the opposite of that required to rebuild the cod stocks. In other words, the bureaucracy surrounding the cod management plan is frequently an obstacle to achieving the plan’s objective.

Whilst some vessel operators have sought shelter within the Catch Quota projects, which provide additional cod quota and more relaxed effort constraints, others for which this is not an option, are trying to get by as best as they can. Some vessels opt to work outside the cod recovery zone for part of the year to ration their use of days; or move into fisheries where the effort limits are less severe; or spend the significant sums to obtain the days-at-sea that would allow them to remain viable in the main whitefish fisheries. The discard sampling statistics confirm however, that a large part of the fleet when these alternatives run out, fish on as best they can during the period that they are allowed to go to sea – and widespread discarding of cod non-cod demersal species is the result. In other words, the constraints imposed by the cod recovery plan – in terms of an ultra-low TAC backed by effort limits ratcheted down each year – generate divergent responses from the fishery. Some vessels are pushed towards the catch quota projects but others survive by following fishing behaviours thatundermine the purpose of the cod recovery plan.

Whilst vessels within the catch quota schemes are subject to fully documented catches and cannot discard cod, the vessels outside the schemes are subject to extreme financial pressures that often intensify fishing pressures on cod, including widespread discarding. This makes the prospects of quantifying the reduction (if any) of fishing mortality which results from effort constraints a forlorn task. One example illustrates the issue: although the minimum mesh size for targeting the larger whitefish species, such as cod, was increased ten years ago, the average mesh size in use in the North Sea has fallen over the same period. This is explained by vessels which have sought to escape the economic consequences of effort control moving away from the whitefish fisheries into adjacent fisheries like the nephrops (prawn) fisheries that require a smaller mesh size but which will still to some degree or other catch cod as a by-catch.

Sight of a range of perverse consequences like these, is generally lost as the industry and officials are preoccupied with designing an effort scheme that is equitable and consistent with the terms of the cod recovery plan but also gives the fleets some hope of economic viability. This Federation is the strongest advocate of a move away from prescriptive micro-management and towards a fisheries management system based on delegated responsibilities; however, good ideas can be spoiled by poor implementation and here is an example of delegated responsibility at its worst. The Commission, having overseen a failed effort scheme base on flat rate limits (2003 -2008) persuaded ministers that allocating effort to member states in the form of KilowattDays represented increased management “flexibility”. The reality, as effort limits come down year on year, is often the opposite of flexibility and also leads to the kind of perverse outcomes described above.

Impact assessment? What impact assessment?

All this might have been thought through before the adoption of the present effort regime but incredible as it may seen, this, the most intrusive of management measures applied under the CFP since its inception, has never been subject to a formal impact assessment. The use of effort control remains highly reliant on the belief of a small number of officials within the Commission that it is an appropriate instrument in the demersal mixed fisheries. The evidence and the opinion of the industry subject to it, along with the officials who are tasked with managing it, suggest that it is not.

Cod Review

Whether this deeply unsatisfactory situation can be put to rights depends in part on the outcome of the forthcoming review of the cod recovery plan. ICES scientists will shortly begin reviewing their assessment methods in relation to the cod stocks, and shortly after that a joint ICES/STECF working group will examine the broader issues associated with the effectiveness of the cod recovery initiatives to date.

The Federation will participate in these meetings and will ensure that the issues outlined above are raised.

In practice this has meant reliance on what NFFO members have been willing, or able, to pay in subscriptions, or what the Federation has been able to earn for itself.

This principle has served the Federation well. Owing no favours, the Federation has been able to be bold in policy, uncompromised by financial entanglements that threaten and compromise its integrity.

This principle was informed by the fishing industry’s experience with the Fisheries Organisation Society (FOS). This was a government sponsored body set up with good intentions before the Second World War but which was hobbled by its annual grant and was considered a tame poodle in policy terms. Until it finally faded from view in the 1990s, the FOS was crippled because it was never clear how far its reliance on government funding influenced its policy decisions. There have been more recent examples where fishermen’s representative bodies have been funded overwhelmingly by government, all equally unsuccessful, all short lived and all tainted and taunted by the refrain that, He who pays the piper………..

Financial independence is more important than ever before for any organisation that wants to maintain its integrity and critical edge

ICES and the RACs are planning to establish regional task forces to tackle the problem of weak stock assessments impaired by deficiencies in the data used to estimate abundance and advise on management measures. The regional task forces will also provide a platform for increased cooperation and dialogue. Fisheries managers from the member states will be invited to participate to strengthen the initiative.

The North Sea and North West Waters regional advisory councils proposed the new initiative which has now been enthusiastically supported by ICES. At a recent meeting in Copenhagen it was agreed to go ahead and to establish terms of reference for the new task forces. Once established, the individual task forces will decide which fisheries and stock assessments should take priority. Whilst some stock assessments are robust, others have suffered from years of a downward spiral of deteriorating data, leading to weak assessments, leading in turn to low TACs. Both fishermen and scientists have a keen interest in ensuring that the assessments are as strong as possible. In many ways this initiative can be seen as resetting or rebooting those assessments weakened by years of poor data.

Building on work already done by ICES with the Baltic and Pelagic RACs, the first task of each RTF will be to decide on which stocks require attention using a quality matrix. This helps to identify weak assessments and the nature of the problems faced. From there, the RTFs will make recommendations on:

• the type of assessment model appropriate for the fishery
• the specific data problems faced in the fishery (e.g. landings statistics, discards estimates, natural mortality estimates, changes in fleet behaviour)
• Steps to rectify the problems found

The RTFs will be a good place to discuss how industry data and knowledge can be incorporated into the assessments, including data from the various fisheries science partnerships now common throughout various member states.

The next step will be a meeting in early April to set the ground rules for this important new initiative.

The determination of the Commission to decentralise CFP decision-making was spelt out in its 2009 Green Paper on CFP reform. It is by no means clear however, that when the dust settles towards the end of this year, the CFP will have moved forward. And, without decentralisation, and specifically without some form of regionalisation of the CFP, the Lisbon Treaty requires all CFP decisions (except the setting of TACs and fishing effort limits) to be subject to co-decision-making with the European Parliament. Those who already complain about the glacial movement of the legislative process in Brussels will now face an average two year wait for change to even the smallest technical detail. Without a substantial degree of delegated decision-making, the CFP will be paralysed for a decade until the Commission, Council of Ministers and Parliament learn the hard way that even more micro-management in an already cumbersome and unwieldy system, is not the way forward.

What’s Gone Wrong?

In many ways the Commission’s Green paper was an insightful and progressive document. Once it got past its apocalyptic vision of the direction of European fish stocks (that it has since disavowed), the Commission’s analysis of the CFP’s rigid and inflexible decision-making process as the root cause of its many failures, was accurate and honest. Its suggested solutions – a radical decentralisation of decision making and transfer of delegated responsibilities to member states in sea basin regional bodies and (subject to certain safeguards and guarantees) to the fishing industry itself – were coherent and well founded.

But as we move towards the Commission’s CFP reform proposals, expected in May or June, things don’t look good.

The Commissioner appears distrustful, not just of the fishing sector, but of her own officials. Her naive insistence that fisheries management decisions should simply “follow the science” has dismayed member states, the fishing industry and ICES scientists equally. The former know that in the present setup, the Council is the place where broad management and socio-economic considerations are brought to bear on the raw scientific recommendations. The latter are worried about the politicisation of the scientific working groups that produce the scientific recommendations. This and the Commissioner’s other equally distracting enthusiasms threaten to alienate the member states and the fishing sector at exactly the time when the reform process needs all the support it can get.

Although still notionally committed to the regionalisation agenda, there is little sign that the Commissioner is clarifying concepts and marshalling the political support necessary to drive such a radical change through. And that is before the proposals are presented to the College of Commissioners, where experience tells us, not least with the EU Cod Recovery Plan, that extraneous factors can derail the most coherent of proposals.

A further depressing consideration is that many southern member states, whilst enjoying the financial benefits of FIFG and EFF, have yet to feel the full regulatory force of the CFP – few TACs, no intrusive effort control and minimal technical measures. These member states represent a huge body of inertia which simply does not see the need for decentralisation or regionalisation.

All is Not Lost

There is one over-riding reason to believe that despite these negative factors the reform will usher in a new era for the CFP. This is that there no status quo option. The Lisbon Treaty and co-decision means that we have to move on. The CFP will simply not be able to function if every decision has to be the subject of wrangling between the Commission, the Council and the Parliament.

Even here there are pitfalls. At least parts of the Commission favour a form of decentralisation that would transfer more authority to unelected and minimally accountable officials rather than closer to the fisheries concerned. This comitology route may be a technocrats dream but would take us no closer to the decentralised management system that we in the NFFO want and which already works well in other countries.

So, there is much to play for in the coming months. The NFFO’s Executive Committee will be meeting shortly with senior Defra officials to discuss the UK’s reform objectives and what is being done to secure them.

The Commission had proposed a 19% reduction in the TAC for prawns – the economic mainstay of the Irish Sea; it had also proposed that the Area VII nephrops TAC should be divided into functional unit mini-TACs, constraining a vital flexibility for the fleets; also the EU cod management plan agreed in November 2008, prescribed a 25% cut in days at sea to be implemented in 2011.

Although the Irish Sea still faces huge challenges, things look a bit better now. After strenuous lobbying, backed by credible scientific and economic evidence, the cut in the prawn TAC was limited to a more absorbable 3% reduction; functional unit TACs were seen off as an unjustifiably bureaucratic approach; and a review of the EU Cod Management Plan was secured, against mounting doubts over its relevance to conditions in the Irish Sea.

Looking forward, the Northern Irish fishing industry is taking stock of its position and preparing for the future:

• Industry leaders are in discussions with DARD, the Northern Irish fisheries department, over a decommissioning scheme that would allow around 17 vessels to voluntarily leave the fleet, improving the prospects for the vessels which will continue fishing. Decommissioning has proven in the North Sea cod and plaice fisheries to be an effective tool in regenerating depleted stocks
• Despite the crippling prospect of a 25% reduction in permitted days at sea, a combination of astute rationing of available days and the extra days made available by the departing vessels, suggests that it will be possible to for the fleet to live within the effort constraints, for 2011 anyway
• Scientific sampling work has confirmed that the Northern Irish fleet has very low levels of discards of cod but relatively high discards of haddock and whiting. It is clearly in the industry’s long term interest to reduce these substantially and successful trials have been undertaken on a double square mesh net configuration adapted to conditions in the Irish Sea. The task is now to press for amendments to EU regulations that would permit the general use of this gear substantially reduce discards of haddock and whiting whilst retaining marketable catch
• The impact of the EU Cod Recovery Plan and its successor, the EU Cod Management Plan, has wreaked destruction on the Northern Irish whitefish fleet – reduced from 40 vessels to 2 boats. And the net benefit of the battery of measures (from gear configurations in 1999 to effort limits in 2010 and everything in between) has been – in terms of rebuilding the cod stocks and according to the science – close to zero. The Review of the EU Cod Plan at least offers the opportunity to scrutinise the biological processes and the fisheries, to begin to determine what is going on. Does the problem lie in a decline in the productivity of the stock? ; is there a problem at the larval stage? or does the problem lie in the fishery?. Rather than continuing with the existing tried and failed approach, the Cod Review, done properly, offers the possibility of getting onto the right track, after a decade of wandering in the wilderness.

The Irish Sea is a relatively small marine space and measures like real time closures are not easily applied. Equally, it is clear that the stock and fisheries dynamics in the Irish Sea are very different from the North Sea; yet the Irish Sea has in the main, been treated as an adjunct to the North Sea. It has been evident for some time that the Irish Sea requires its own solutions based on the specifics of its ecosystem, its stocks and its fisheries.

The FIMPAS project has been running since 2009 led by the Dutch Government and ICES, and covers 3 offshore Habitats and Birds Directive Natura 2000 sites in Dutch offshore waters including the Dogger Bank, Cleaver Bank and Frisian Front.

The work forms a test bed of how measures may be developed subsequently within UK waters and this is particularly significant for the Dogger Bank where the UK is expected to formally submit the UK section of the Dogger to the European Commission as a Special Area of Conservation (SAC) this summer. The workshop concluded that it would be necessary to progress measures for the Dogger by considering also the UK and German sections in tandem. This will be progressed with the intention of holding a further workshop in the summer and with the expected close involvement of the North Sea RAC.

Dale Rodmell, NFFO Assistant Chief Executive, said: “Naturally, we had deep concerns over initial alarmist proposals brought to the meeting for blanket bans for beam and otter trawling in both the Dogger and Cleaver Bank areas. This highlights the failure yet to bed down the setting of management measures for MPAs in a sufficiently scientifically informed process. This is something which the industry, in the face of sometimes over-zealous green lobby interests, has to keep a close eye upon. We now have alternative industry proposals on the table with view to moving forward on a more sensible footing.”

“From a regional seas conservation perspective you would not select the Dogger Bank as an MPA in the first place, it being a shallow sand habitat naturally impacted by the action of waves and storms and with key flat fisheries known for low discards and the Danish sand eel fishery which is dependent upon the area. The risks are not just severe economic impacts to the fleets affected, but the risk of fisheries displacement onto less prime fishing grounds and habitats that are more sensitive to fishing. In this sense, the Habitats Directive has turned into a conservation policy with perverse consequences. Despite its flaws, the European Commission and Member States are obliged to continue to implement it all the same.”

“Coupled with that, the conservation status for the Dogger is considered to be unfavourable based upon seabed ecology sampling from the 1990s that take no account of the subsequent reduction in fishing activity.”

The meeting also provided an ideal opportunity to demonstrate new advances in gear technology with presentations on the Dutch Pulse, SumWing and PulesWing trawls. The gears are currently being developed under derogation from the Commission due to the general ban on electric fishing that currently exists, but have already demonstrated significantly lower fuel costs, discards and seabed impacts.

Photograph: Workshop participants test the 15 volt electric pulse technology for themselves, which replaces the need for tickler chains on beam trawls.

Officially termed the Eastern inshore and offshore areas, workshops held by the MMO recently in Peterborough, Norwich and Hull signalled the start of engaging with stakeholders, firstly to inform how the public engagement process will take place.

In contrast to the ongoing marine conservation planning process, where hard lines are drawn on charts to delineate MCZ boundaries within which conservation based management measures will be applied, it is less clear how the final marine plan will affect the fishing industry. As on land, however, plans are expected to be directional rather than definitive in determining what happens where, and marine licensing will continue to form the final process for permitting most marine projects and developments.

As an industry with one of the deepest maritime traditions, it is the need to accommodate increasing numbers of other marine uses that is the concern to our industry and the marine planning itself does not change that fact. However, undertaken correctly marine planning should systematically balance these multiple use needs, minimise conflict and find synergies between different uses which would signal a departure from the more ad-hoc and sectoral based approach of the past.

Whilst fishing does not occupy the majority of marine space as the conservation lobby assumes – best estimates are between 5 and 21% for bottom towed gears in English and Welsh waters1 – its diversity and heterogeneous distribution relative to other activities poses greater challenges when balancing against other marine use priorities. As well as working directly at the policy level to see that fisheries are reflected effectively in policy and planning decisions, the Federation is addressing this through two major initiatives:

• With the support of the Crown Estate, the Federation is pooling together multiple and disparate data sets on fishing activity and industry and industry held data to produced a verified set of fisheries mapping to inform marine planning processes.

• Working to see that fisheries data is most effectively analysed in order to inform the consequences of fisheries displacement should fishing be restricted in a particular area. This includes both the economic and social consequences as well as the ecological consequences of displacement.

As with the ongoing marine conservation projects, developing marine plans will have a significant stakeholder engagement element. There is no getting away from the fact that relative to other areas of policy making, such processes are resource intensive and in particular for the fishing industry require much local level engagement to facilitate the mosaic of interests in any region.

Dale Rodmell, NFFO Assistant Chief Executive said: “In contrast to the rushed “on-mass” approach to planning Marine Conservation Zones, government has set about developing marine plans in a more considered way by focusing upon one region at a time. It is essential in developing the plan that the MMO recognises the need to protect access to fishing grounds, maintain viable fishing ports and livelihoods and minimise environmental impacts to fisheries. It also needs to design an engagement process that caters for the input from the fishing industry, recognising its diversity and that input will come from people giving up their time running their everyday businesses”.

1. Eastwood, P. D., Mills, C. M., Aldridge, J. N., Houghton, C. A., and Rogers, S. I. 2007. Human activities in UK offshore waters: an assessment of direct, physical pressure on the seabed. – ICES Journal of Marine Science, 64: 453–463.

Or will the celebrity chef now move on to turn the spotlight on some other aspect of food production, leaving us pretty much where we are? In particular, what will the campaign, backed by last week’s major Channel 4 focus on fish and fishing, achieve in terms of reducing discards?

There is no doubting the man’s energy, commitment and astute approach to publicity. But the answers to those questions are not at all clear. Having marched us up to the altar of eliminating discards, where do we go from here?

Of all people, the Guardian’s TV critic hit the nail on the head. The Fight for Fish brilliantly illuminated the problem but offered precious few – in fact no – concrete solutions.

Perhaps that is fair enough. Perhaps Hugh recognises the limits to his many competences and having highlighted the irrationality and obscenity of discarding mature cod and other valuable species in a hungry world, leaves it to others to develop the solutions.

What the week of TV programmes didn’t do was give any attention to the initiatives already in place that are already successfully reducing discards. None of these represents a panacea – there are none – but they do indicate practical, tailored, solutions to particular types of discards in specific fisheries. Perhaps they weren’t mentioned because they are rather technical and not easily explained on camera. Nothing was said of:

• Real Time Closures and other types of cod avoidance
• The Catch Quota initiative which eliminates cod discards completely for participating vessels
• The 50% project in the South West
• The success of gear selectivity measures in reducing discards of juveniles, not least the use of square mesh panels in the haddock and whiting fisheries
• The many voluntary changes to fishing patterns applied by individual skippers to avoid cod and discards as far as possible.

The programme’s main attention and indignation focused on the dumping of mature fish discarded because of the rigidities of the Common Fisheries Policy. This is probably where the Fight for Fish Campaign will have its greatest impact, not least because it is well timed to coincide with the 2011 review of the EU Cod Management Plan, the main culprit in the cod discard story.

Cod Discards

At the outset of the current Cod Management Plan, in the autumn of 2008, the College of EU Commissioners made a fateful decision which led directly to the economic, ethical and ecological disaster filmed by Hugh and his team. Faced with ICES science that pointed to a rapidly rebuilding cod stock in the North Sea, the College of Commissioners looked at the various catch options suggested by the scientists and deliberately chose one that would lead to the scale of discarding, now witnessed in graphic detail by the viewing public. The reason for this choice was that the Commissioners didn’t believe that, having recently pronounced the cod stocks near to collapse, they could sanction the large increases in the quota suggested by ICES because the general public would not understand such an apparent turnaround. The Commission may now rue that decision, as it faces criticism for the massive level of discards of mature cod seen over the last few years – and as public revulsion over the resulting discards has built.

The Commission’s cynical decision was taken to follow the most restrictive catch options in the belief that the resulting discards, out at sea and out of sight of the general public, would be easier to explain than a dramatic increase in the quota for cod.

The Fight for Fish campaign, if nothing else, has blown the lid off that particular blunder but that decision and its consequences will be revisited during the course of this year as the Cod Management Plan is reviewed: This why the Fight for Fish campaign despite its roots in our transient celebrity culture may turn out to be pivotal.

Solutions and Non-solutions

There is no single solution to discards and that is because there are different reasons why discarding takes place in different fisheries. It is fair to say however that the various rigidities of the Common Fisheries Policy, low value underutilised species and unselective gear are the main drivers. There are however many potential solutions. There are multiple initiatives, some under way, some of them mentioned above, which can significantly reduce the scale of discards.

• Reforming the EU Cod Management Plan would reduce discards of mature cod at a stroke; the development of various types of avoidance strategy is well under way and can go much further;
• Marketing initiatives to change public tastes towards delicious but underutilised species all have their role to play.
• The means to more selective fishing in many cases already exist or can be found quite rapidly by skippers where the right kind of encouragement and incentives put in place. The NFFO has made suggestions on how this might be achieved through the means of sustainable fishing plans.

Blind Alleys

It is important to knock a few blind alleys on the head.

• Some commentators have reverted to saloon bar logic: “just ban” discards. It is important however to understand that where a theoretical discard ban is in place, such as in Norway, it is the cherry on top of an entirely different approach to fisheries management – one that is adapted to the specifics of their fisheries. In Norway’s case the primary emphasis is on protection of juveniles, principally through a massive programme real time closures. This certainly works well to reduce discards, although even here there should be no illusion that discards have been entirely eliminated. But is difficult to see how a ban and the underpinning programme of large-scale RTCs could be workable in the much more complex and diverse mixed fisheries of the EU. Giving in to demands for a theoretical ban on discards would amount to posturing and would achieve roughly zero. We have already tasted this kind of knee-jerk non-solution with the 2008 ban on high-grading, as meaningless a piece of poorly thought-through reactive legislation as you are likely to find.
• Quotas are here to stay. The reason for this is that in fisheries where stocks are shared it is necessary to distribute the fisheries resource to the different member states, to Third Countries that have access arrangements with the EU, and to different groups of fishermen and vessel operators. Despite the rigidities of the present system and of operating a quota system in mixed fisheries, no one has yet been able to suggest a more effective allocation mechanism that would deal with the realities of shared stocks. The plain fact is that we have little option but to work to make the quota system function better than it does at present as opposed to ditching it. And there is much that can be done on this front. Catch quotas are one example. More efficient quota swaps and transfer arrangements are another.
• Replacing quotas with effort (days-at-sea) allocations, despite its superficial attractions to some, is a non-starter. Experience as well as academic economic theory confirms that effort limitation creates a perverse incentive which intensifies fishing activity during the period that the vessel is permitted to go to sea. One form of this is seen in technological innovation – what the Americans call capital stuffing. It is therefore an approach entirely counter-productive in conservation terms. Besides it lacks the precision of the quota system as an allocation mechanism.

Spotlight

So how has the fishing industry fared under this week’s media spotlight? Apart from the focus on discards, Arthur Potts Dawson’s trip as a deckie-learner aboard the Cornishman, a Newlyn beamer, usefully highlighted the tough working environment faced by fishermen in bringing fish to the consumers’ table. The celebrity chef boarded the vessel with the usual urban sensitivities and left the vessel with a deep respect for the skipper and crew, who would be turning around to return to sea whilst Arthur returned to his London restaurant. The highpoint was Arthur’s extreme anxieties aboard during a force 9 gale – that turned out to be force 4 – with the force 9 still to come. The crew came across as calm professionals doing a very hard job.

Time will tell. The programmes, for the most part, avoided the worst type of lazy media stereotypes; and the encouragement to try different types of fish must be considered wholly positive, even if the choices and underlying rationales were a bit wonky. Fish farming got a bashing, largely for its scale and its reliance on industrial fishing for feed species.

As we have suggested above, the main legacy of the Fight for Fish could be in its impact on the review of the EU Cod Management Plan and we should know the result of that within 12 months.

This week sees the start of a major Channel 4 campaign focused on fish and fishing. In a series of TV programmes over the coming week celebrity chef big guns, Jamie Oliver, Hugh Fearnley-Whittingstall, Gordon Ramsay, Heston Blumenthal and Arthur Potts Dawson, each focus on some aspect of the fishing industry and of fish consumption, mixing campaigning zeal with practical recipes using underutilised species.

The fishing industry is still weighing up whether this attention is something to be welcomed and embraced, or something to be feared. The answer is likely to be, like celebrity itself, a mixed blessing.

Certainly, Hugh Fearnley-Whittingstall’s campaign on discards has so far turned a useful spotlight on the scale of discarding generated by the requirements of the Common Fisheries Policy. It has highlighted the gulf between the Commission’s hand-wringing over discards and its practical policies which make large-scale discarding a legal obligation for vessels in mixed fisheries. It also has drawn attention to the hugely encouraging progress that can be made in reducing other types of discards when the right approach is taken – in for example the 50% project.

On the other hand, the fishing industry has good reason to fear the arrival of instant experts, with their preconceptions, over-generalisations, need for drama and instant solutions.

The Federation recently helped the star Times and Sunday Times food writer A.A. Gill find a berth aboard a North Sea trawler, in the hope that he would then be able to write in a fair and objective way about the realities of fishing today. Like most people he was horrified by the sheer waste involved in the discards required by the vessel to stay on the right side of the law. But when it came to solutions A.A. had the answer – follow the Norwegians, they have replaced quotas by a days-at -sea regime. In fact the Norwegians do not have a days-at-sea regime and would pour scorn on anyone who suggested that they should. Getting it this wrong, when it comes to instant prescriptive solutions for the fishing industry, takes style and panache and a deep lack of respect. A phone call could have checked that particular fact. But that call was never made.

This is the fear that the industry has as we go into Channel 4’s Fight for Fish week. In the public mind the UK fishing industry is likely to be tainted by association with unsupportable practices elsewhere in the world; and instant A. A. type non-solutions will be promoted because they are easy to explain in a 3 minute clip to camera.

The new recipes using underutilised species, created and demonstrated by some of the biggest celebrities of our time are a brilliant idea and could do a lot of good in expanding the British palate (as well as saving consumers money). But even there the pre-broadcast blurb suggests that the reason that consumers might want to use coley as an alternative, is because cod and haddock are not being fished sustainably. Haddock for goodness sake! Why? ICES advice is that North Sea haddock is at or around maximum sustainable yield. And whilst it is true that some cod stocks in EU waters face severe problems, those fisheries have only ever provided a tiny fraction of the cod consumed in the UK. What is the point of scaring consumers? The big cod fisheries are at Iceland and at North Norway and have been for centuries, and there is no suggestion that those fisheries are in any kind of trouble – quite the contrary

So, tighten your seat belts. We are in for a rocky ride. This degree of media attention can open doors, increase understanding and promote good causes. It can also generate misconceptions and corner politicians into knee-jerk reactions. A mixed blessing indeed.

The study is a follow-up to its 2008 report into the CFP, which was one of the most stingingly critical of any EU policy since the Court was established. The Court of Auditors, as its name suggests, has a particular responsibility to ensure that EU funds spent on policy initiatives achieve good value for money; its comments and recommendations however, carry policy implications that run well beyond accountancy. Both the radical character of the Commission’s Green Paper on CFP reform and its rushed and ill-considered proposals for a new Control Regulation were directly driven by the Court of Auditors’ scathing report.

The Court of Auditors has requested views on whether there is fleet overcapacity within the CFP, where that overcapacity lies and what can be done about it.

Two points can be made immediately:

1. There is overcapacity within the CFP
2. The Commission’s generalised formula of “too many vessels chasing too few fish” is too simplistic and too undifferentiated to be of much use in designing effective policies to address those areas where overcapacity can be identified.

Overcapacity cannot usefully be understood according to any simplistic CFP formula with tonnage and engine power on one side and fish on the other. A fishery by fishery approach is required, taking full account of the wide diversity of fisheries within the CFP but also that some fisheries (and some member states) have already undertaken dramatic fleet reduction programmes over the last 15 years. In short there are wide variations in the degree of overcapacity and its spatial distribution.

The existence of technical capacity to catch allowable quotas many times over is not an adequate definition of overcapacity. The modern pelagic fleet has that technical ability; it is deployed on a highly seasonal basis to catch fish in an extremely efficient and profitable way. Moreover, it is now regarded as a highly compliant sector; catches are within quotas. A simplistic definition of overcapacity would categorise the pelagic fisheries as “overcapacity” but in this context it is hardly a helpful approach.

A more sophisticated and therefore realistic definition of overcapacity is required. This would recognise that physical capacity is only one dimension of a four cornered problem. Effective fisheries management1 requires that:

1. The fleet is profitable, meaning that the profits are sufficient to renew the fleet without state subsidies
2. There is a high degree of compliance; without a high degree of compliance the system is broken
3. There is a broad balance between the capital in the fishery and the available resources
4. Management decisions are based on sound information, including stock assessments

It is these interlinked and mutually supporting pillars that must be put in place on a fishery by fishery basis if overcapacity, where it exists, is addressed as part of an overall approach to fisheries policy.

If the Court of Auditors’ report is to avoid the twin fates of being ignored to gather dust, or in precipitating hasty, ill-considered, policy changes, it is important that its report on overcapacity is set in this broader context.

Decommissioning and Value for Money

Contrary to the prevailing orthodoxy that questions the value for money equation of publically-funded decommissioning schemes, we are of the view that vessel decommissioning schemes in the UK, Denmark, the Netherlands, Belgium and France have made a substantial, perhaps even pivotal, contribution, to reducing fishing mortality and rebuilding many stocks within the CFP. In the case of North Sea cod and plaice their effectiveness seems inarguable. But there are other ways to achieve fleet reductions where this is deemed necessary. Governments naturally favour schemes like the Danish rights based management system that appears to have achieved a balance between the fleet and available fishing opportunities with a minimum of public expenditure.

Whatever method is chosen to address overcapacity, where it exists, it is important that it is applied within the context of the approach described above.

1. Net Benefits (2004) A report prepared by the UK Cabinet Office

. The time is approaching when the Commission will formulate its proposals and it has already made clear that regionalisation, in some form or another, is on the agenda. The RAC’s intervention is very timely and is therefore reproduced below in full.

North West Waters RAC

What do we want from Regional management? Note for discussions with Director General Lori Evans on Thursday 2nd December 2010

Director General,

You are aware that we have argued, in our response to the CFP consultation, for a radical decentralisation of the CFP.

We see this as the way out of blunt and ineffective measures and away from over-complexity and micromanagement. It would involve a move towards regional management and a transfer of responsibilities to stakeholders and in particular the fishing industry.

Regional Management

We recently held a meeting in Dublin to progress our thinking on what management with a strong regional dimension might look like. We were assisted by experts such as Prof. Long of Galway University who kept us right on the legal issues.

We are quite clear that the broad strategic decisions should remain with the European institutions. However, areas such as technical measures, discard reduction, long term management plans, even setting TAC levels would best be done at regional level.

We are aware that this is sensitive legal territory but from our point of view, the key participants in any form of regional grouping would be:

• The member states which hold fishing entitlements in a particular sea basin, along with
• Fisheries scientists
• Key stakeholders.

Rather than get bogged down in complex arguments over whether the regional management body will have formal or informal status, or what provision should be made to fast-track regional recommendations through the legislative system (without of course undermining the Commission’s exclusive right of initiative), we decided instead to concentrate instead on what we would want regional management to do.

And in this we have made some progress. We would want the Regional bodies, however constituted, to:

• Develop customised solutions that would deliver more effective fisheries management, and help to achieve Maximum Sustainable Yield (accepting the limitations of that concept in mixed fisheries)
• Oversee a move away from prescriptive micro-management
• As part of that process, to achieve simplification of the CFP
• To move to responsive and adaptive management that would allow us to move rapidly away from failed measures and trial new approaches
• To make decisions made at the lowest practicable level
• Progressively develop delegated authority as a means of transferring responsibilities to the fishing industry, within a framework of guarantees and safeguards
• Oversee the preparation, coordination development and approval of long term management plans, working closely with the RACs
• Maintain a close, continuous, dialogue and engagement with the RACs
• Select and refine management measures from the fisheries management “toolbox” to fit the circumstances
• Manage trans-boundary issues
• Work to ensure an alignment of economic incentives with management objectives so as to avoid perverse outcomes
• Develop a results focused management rather that a “legislate and hope it will work” approach
• Provide a forum bringing fisheries managers from the relevant member states, fisheries scientists and fisheries stakeholders into close and continuous contact to provide recommendations on the content of legislative proposals
• Improve the information base on which management decisions and recommendations are made

Sustainable Fishing Plans

We have also included in our CFP response the concept of sustainable fishing plans. We envisage this will be the delivery mechanism for a simplification of the CFP, a transfer of responsibility to those in the fishery and the basis for grass roots collaboration between scientists and fishermen.

Regional Advisory Councils

RACs have proven their worth. They vary in size, composition and approach but it is clear that the work they do is important. This is not to say that RACs couldn’t be improved. The quality of RAC advice is heavily circumscribed by:

• The size and complexity of the fisheries in the RAC area
• The resources available to do the necessary research and preparatory work
• The extent to which the RAC engages with fisheries scientists.

At the very least we would like to see progress on these fronts in CFP reform. Within a regionalised CFP RACs would become more rather than less important, even if it is decided that RACs are not to be transformed into regional management bodies. The level of dialogue and engagement between regional management bodies and the RACs could be expected to be much richer and productive than the current relationship between the RACs and the Commission, which simply does not have the capacity to cope with the quantum of advice from all the RACs. There would be a better prospect of a genuine dialogue rather than the parallel monologues that we currently experience.

Sam Lambourn Chairman

North West Waters RAC