Defra have consulted on how any additional quota, obtained as the UK renegotiates its fisheries relationship with the EU as it leaves the Common Fisheries Policy, should be distributed. The NFFO have submitted the following response.
We agree that Defra should consult widely on how additional quota that is secured as the UK leaves the EU, should be allocated. We do not, however, consider that the questionnaire format is an appropriate vehicle for the views of a national organisation which has a duty to reflect the views and interests of a wide spectrum of members and whose policy positions often reflect carefully balanced compromises, developed after extensive discussion.
We therefore submit this paper in response to Defra’s call for evidence.
We have elsewhere argued that FQAs should remain the basis for allocating existing quota and for recognition of FQA’s role in delivering sustainable fisheries. We continue to hold those views.
It is worth noting that the availability of additional quota is unlikely to be evenly spread and will reflect:
⦁ The outcomes of UK/EU negotiations for a post-exit fisheries agreement
⦁ UK negotiating priorities and the timing of any adjustments
⦁ The scale of the divergence, stock by stock, between current relative stability shares and an objective assessment of the resources located in the UK EEZ
We understand “additional quota” available to the English fleet, to refer to increased UK share of TAC species, over -and-above that obtained under the current relative stability allocation keys, subsequently adjusted to reflect deductions proportionate to FQA holdings that are managed by the devolved administrations. The residual will be “additional English quota”.
Allocating Additional Quota
It is axiomatic that “everyone wants more quota.” Government therefore faces the unenviable task of rationing fishing opportunities. That is inherent in the task of limiting access to a fishery. Failure to limit access only has one destination: excess effort leading to reduced catches for all. This is the most basic reality of fisheries management.
Limiting access is necessary, therefore, but requires hard choices. There is a responsibility on Government to be as equitable as possible and transparent as possible in the allocation process, and there should also be clarity about the aims and objectives of the policies in which allocation decisions are embedded.
Quota, though vitally important in many fisheries, is not the only way in which, post-Brexit, benefits can be brought to the fishing industry and thought ought to be given to how to achieve equity through a broad package of measures to support fishing and our coastal communities. This might include:
⦁ Additional quota but also:
⦁ Reduced competition from non-UK vessels within the 12mile limit
⦁ Using additional quota to secure quota exchanges favourable to the UK as part of a balanced reciprocal agreement
⦁ Reduced regulatory burden through UK autonomy on fisheries regulation
⦁ New forms of co-management in which fisheries stakeholders hold a key position
⦁ Post-EMFF financial support
One way of navigating through the maze of competing demands for more quota would be to establish explicit principles against which the claims could be assessed. Such an approach would at least make explicit the value judgements behind the allocation decisions.
Possible Allocation Principles
⦁ Equity: In a broad sense, the benefits of leaving the EU and the Common Fisheries Policy should be made available to the whole of the UK fishing industry, irrespective of sector, vessel size or type, or target species; at the very least, post-Brexit, no industry group should be left worse off
⦁ Chokes: Additional quota could be used to facilitate the progressive implementation of the landing obligation, in particular, to mitigate chokes in mixed fisheries
⦁ Acute Quota Shortage: Additional quota could/should be used to address acute quota shortages where these are demonstrable, even in non-choke situations
⦁ New Entrants: Additional quota could be used to encourage new entrants but only where this does not imply an unsustainable increase in fishing capacity
⦁ Community Benefits: The allocation of additional quota could be made contingent on bringing long-term benefits to a specific region/coastal community or to bring wider economic benefits to the UK economy
⦁ Sustainability Incentives: Additional quota could be used to incentivise voluntary adoption of desirable fishing patterns and practices
⦁ Consistency with Management Objectives: The allocation of additional quota should be consistent with the long-term fisheries objectives and used to facilitate transitional arrangements as the fleets adjust to the post-Brexit management regime
⦁ Evidence: All allocation decisions should be based on evidence and transparent information
One approach might be to invite the Defra/MMO managed part of the fishing industry to submit fishing plans for additional quota, which could be assessed against the criteria above.
We do not support a monetary quota auction system as it would over time lead to an unhealthy concentration of ownership and control of quota.
Fishing Plans could provide the means through which a group, bidding for extra quota, could:
⦁ Demonstrate how additional quota could be used to underpin sustainable and profitable fishing activities
⦁ Be a vehicle for co-management
⦁ Contain policies on the encouragement of new entrants
⦁ Detail how fleet capacity of the group is aligned to fishing opportunities
⦁ Explain how additional quota will be used to mitigate choke risks
⦁ Detail how additional quota would support the relevant coastal community
⦁ Contain details of partnership working with fisheries scientists to improve the information base for management decisions
A balance between fishing capacity and available fishing opportunities is the most basic and essential element in any successful form of fisheries management. It will be important that additional quota does not fuel an unsustainable fleet expansion in any part of the fleet. What may be right for an individual operator might not be right at aggregate level and so it will be important to have a robust understanding sector by sector of where that fleet component stands on the fishing effort/yield curve.
This is particularly true of the inshore fisheries which did not have access to large scale decommissioning grants in the past, where physical space for fishing is under pressure, and where there remains a significant latent capacity issue.
We do not favour effort control, as TACs and quota allocations will remain as fixtures because most of our regulated stocks will still be shared with other countries and there is no plausible alternatives to quantitative national limits on catches. In these circumstances, effort control would therefore only add a further layer of control and bureaucracy. Furthermore, the evidence worldwide suggests that input controls generate behaviours incompatible with management objectives and can carry adverse safety implications.
We do favour, however, an exploration of whether genuinely low impact vessels could be taken out of the quota system by counting their catches against a notional allocation managed at national level.
Low Impact Fishing Vessels
There is a strong argument for taking genuine low impact fishing vessels out of the quota management system altogether by accounting for the mortality attributable to their catches by a single allocation at the start of each year. Additional quota on a few key species could be used to facilitate this transition.
From one perspective this approach is to revert to the arrangements which applied to the under-10 metre fleet before it became distorted and engorged by displacement of effort from the over-10m fleet in the late 1990s, as operators fled the impact of cod recovery measures.
There is broad agreement that the artificial division of the fleet at 10 metres is increasingly irrelevant, as some parts of this fleet have developed into highly efficient vessels with catches that can exceed many over-10 metre vessels. The challenge for this fleet is to ensure that it is integrated into the mainstream management regime.
Taking genuine low impact vessels out of the day-to-day quota management regime will depend heavily on how “low impact” is to be defined. Relatively low catches of target species would be one way, so long as there is confidence that at aggregate level, catches are fully accounted for. Accurate recording of catches using mobile phone technology could be a precondition for inclusion in this relatively privileged group.
A simple length division at 7 metres has been suggested and may be the most tractable approach, although it risks replicating some or all the unintended consequences associated with the boundary at 10 metres.
A wider definition of “low impact” could be envisaged embracing an assessment of impact on:
⦁ Target species
⦁ Non-target commercial species
⦁ Cetaceans and other non-commercial species
⦁ Seabed ecosystems
⦁ Carbon footprint
Although more comprehensive as a definition, this approach would be considerably more complex to manage. Whatever definition is chosen, it will be important to recognise that inshore fishing is a highly varied but also highly dynamic sector in terms of evolving technologies, modes of operation, business organisation. Some parts of the fleet comply with the ideal of an artisanal small-scale fishery, whilst others are highly entrepreneurial in organisational terms with a considerably greater impact on stocks.
Additional Brexit-related quota should be seen as an opportunity to address some of the longstanding issues associated with quota shortage in specific coastal fisheries. But as the brief discussion above suggests, it will be important to understand the issues in the round – not just as a quick-fix quota bung to keep the noisiest voices quiet. The Inshore Management Conference planned for October 2019 will, hopefully, shed light on the options available.
We are strongly of the view that there should be no question of allocating quota to recreational sector in advance of:
⦁ A comprehensive national licensing scheme within a fully implemented conservation and enforcement policy
⦁ Catch constraints at least equivalent to the commercial fishing sector
⦁ Full catch recording
The UK’s departure from the EU provides an opportunity to rebalance the UK’s quota shares to more closely reflect the resources located within the UK’s EEZ.
Allocating additional quota provides an opportunity but also a challenge. Limiting access to fisheries – including access to quota – is a fundamental part of managing fisheries sustainably.
In order to ensure that equitable and transparent criteria are used to allocate additional quota, we suggest that explicit principles linked to management objectives are established, against which bids, expressed as fishing plans, may be assessed. Those fishing plans which most closely matched the qualifying criteria would receive additional quota.
We oppose effort control but are open to using some additional quota to take genuine low-impact vessels out of the quota system – if this can be done safely. No quota allocations should be made to the recreational sector without a comprehensive conservation and enforcement regime in place first.