23 July 2014
NFFO Response to Greenpeace/NUTFA Report "Championing coastal waters".
The recently published Greenpeace/NUTFA report, Championing coastal waters, is perhaps a
little less toxic and a little more measured than previous Greenpeace publications
on the UK fishing industry. It is however, a mix of motherhood and apple pie, cynical
manipulation, half-truths and naivety which does not stand up to much scrutiny.
Nevertheless, we are concerned, because its recommendations, if ever
implemented, would have serious adverse consequences; most of all for the
small-scale fishermen that Greenpeace cynically purports to support. Naivety,
especially when tied to an immovable self-righteousness, is capable of doing
great damage – but only if taken seriously by decision-makers.
We therefore feel compelled to respond.
Greenpeace
Action Plan
• Regionalise fisheries management
• Restore fish stocks
• Protect the marine environment
• Redistribute quota to the under 10 metre sector
• Prioritise access for low-impact
fishermen in the UK’s 0-12nm zone
Regional Management
But
let’s start with a positive. We are particularly pleased to see Greenpeace
support a shift away from top-down management to regional management of fisheries. This change has come 15 years
after the NFFO and Scottish Fishermen’s Federation explained in detail why micro-management
from Brussels was a significant part of why the CFP was failing to deliver
effective conservation measures. “Zonal” management, as we called it at the
time, has during the intervening period, gathered widespread support, leading ultimately
to the inclusion of important provisions in the CFP for member states to take
the lead in policy formation at regional seas level. During the 2002 CFP
reform, the regional advisory councils were a first tentative step in this direction
and the process has now gone a further step. It’s good that Greenpeace has seen
the light and supports this potentially important break with remote top-down
attempts at management.
The
advisory councils have been one of the great successes of the last reform and
it is encouraging that Greenpeace now seem to value their worth. But where have
they been? The other NGOs have been happy to sit down with the fishing industry
and work positively and collaboratively, whilst Greenpeace has rejected this
kind of fraternisation. Anyway, there is always room at the advisory council
tables, they are by design broad churches – but advisory councils can only work
in the context of mutual respect and a spirit of compromise. If Greenpeace are
up for that so are we. The NFFO has been very active in the advisory councils
and intends to continue to be so. We would be very happy to repeat our offer to
meet Greenpeace to discuss any issues relating to UK fisheries.
Restore Fish Stocks
Another
area where we see progress is in Greenpeace’s position in relation to steadily
rebuilding fish stocks. It is heartening but probably not unexpected that even
Greenpeace has had to abandon its catastrophe narrative which posited that all
fish stocks are on a trajectory to collapse; although it continues to imply
that recovery cannot possibly be happening in offshore fisheries where the
bigger boats work. Even though Greenpeace’s acknowledgement is grudging, the
evidence is now simply overwhelming that a turning point in European fisheries
came around 2000. Right across the North East Atlantic, and across all the main
species groups fishing pressure has been dramatically reduced by around 50%;
and with a few exceptions, our fish stocks are rebuilding steadily as a result,
some dramatically. We are now having to address the problems of fisheries
systems in which fish-on-fish predation is a bigger factor than fishing pressure.
This is very good news.
Greenpeace argues that small-scale fisheries
are inherently more sustainable than large scale fisheries. But the truth is
that there are many examples of well-managed, sustainable, large-scale
fisheries (Barents Sea cod, Northern Hake, North Sea haddock) and also many examples
of sustainable small-scale fisheries. Equally, there are examples of both
small-scale and large scale fisheries which are mismanaged and which are therefore,
in the long term, unsustainable.
There
is no inevitable correlation between scale and sustainability, so let’s knock
that one on the head.
Where
we can agree with Greenpeace is in relation to fishing capacity. It is very
difficult if not impossible to manage quotas, or limit environmental footprint,
if there is a fundamental imbalance between fleet capacity and available
resources. Important decisions on where there is overcapacity, and how to
address it where it exists, are absolutely fundamental to fisheries and marine
environmental policy. This applies equally to the under and over-10 m fleets.
Redistribute Quota and Prioritise
access to low impact fishermen
There
are complex ethical and legal aspects associated with redistribution of quota
from one fleet sector of the fleet to another, perhaps best illustrated by
imagining the issue in relation to quota forcibly transferred from a 10.1 metre
vessel to a 9.9 metre vessel. If the
latter’s owner had sold his larger vessel, along with licence and quota, to
join the under-10m fleet, as has not infrequently been the case in the past,
the ethics become even more complex. But leaving aside these moral (and legal)
complexities, but acknowledging the large amount of latent capacity within the under-10 m sector, the evidence suggests
that if substantial amounts of relevant quota were transferred to the inshore
fleet, especially to those using passive forms of gear as Greenpeace advocates,
the result would be:
- An increase in the numbers of under-10m
vessels operating in the already pressured inshore zone, as unutilised or
under-utilised vessels become active,
attracted by the new fishing opportunities
- A reduction in fishing activity offshore,
where fishing pressure is already less intense
- An increase in the amount of static gear
on grounds that are already saturated with gear
- Increased competition on the inshore grounds
for space and fish
- Pressure on under-10m vessels to fish to
fish further from customary grounds and further from the coast, with associated
safety implications
This
would be an example of one of the classic unintended
consequences with which fisheries management abounds. The authorities think
that they are doing one thing for the very best of motives and the results are
entirely different from what was expected. A shift of fishing activity from
offshore fisheries to inshore zones would be very bad news for existing small-scale fishermen.
All
this is not to say that there are no quota shortages in the under-10m fleet
that require addressing. There are
shortages but they are not of generalised
character Greenpeace and NUTFA assert. For propaganda purposes Greenpeace
frequently refers to the fact that the under-10m fleet in the UK has access to
only 4% of the total national quota. But as this figure can only be reached by
including the vast tonnages of mackerel, herring, horse mackerel blue whiting
and North East Arctic cod, which the under-10 meter fleet could never access,
quota redistribution or not, it is all a
bit meaningless.
Quota
shortages in the under-10m fisheries tend to be regionally specific, stock
specific, and vary from year to year. They are most acute where vessels have
few alternatives (non-quota stocks) such as is the case as in the Thames
estuary.
We
have spelt out elsewhere
our remedy for quota pinch points in the under -10m fleet and the success of
the Ramsgate quota pilot underlines the validity of this approach. The essence of
our approach is:
- Differentiating between the 14% of under-10m
vessels which catch 70% of the under-10m quota allocations and the rest of the
under-10m fleet which need flexibility to access to a variety of different
quota species on a sporadic basis
- Encouraging the larger under-10s to form
cooperative groups, with or without links to producer organisation to manage
their quotas; producer organisations can however, provide professional quota management through
which in-year quota allocations can be significantly enhanced through swaps,
transfers, lease etc.
- There
are therefore ways to address pinch-points in the quotas available to the
under-10m fleet as they arise. But if Greenpeace/NUTFA are going to advocate
the use of Article 17 of the new CFP to transfer quota to the inshore fleet, it
is important that all involved do it with their eyes open and at least try understand
the consequences.
Fleet
Diversity
It is probably timely for the NFFO to restate its
position on fleet diversity.
In the UK, and especially in England, we have an
extremely diverse fleet in terms of vessel size, target species and areas of
operation. We have a few very large vessel which fish the distant water
grounds, or target the massive shoals of Atlantic mackerel, herring, horse
mackerel and blue whiting; but we also have many small and medium sized vessels
which prosecute a range of different grounds and species.
That diversity is important in terms of:
- Vessel safety (larger vessels working
the offshore grounds) - Distributing fishing effort across
stocks and grounds on a sustainable basis - Providing the supply chain with
continuity of supply, and a wide range of supply (larger vessels can fish in
worse weather) - Supporting port infrastructures (buyers, ice
supply etc. depend on continuity of landings to provide critical mass)in - Supplying very high quality niche markets
(small-scale fleets are well adapted to serve this part of the market)
In fact there is often an interdependence between fleet segments. This was seen most clearly
when the large beam trawlers left the port of Lowestoft in the 1990s; there
followed a drastic reduction in the local small boat fleet. Without the larger
vessels providing continuity of supply, fish-buyers and port infrastructures
could not be sustained.
A healthy diversity is therefore one of the best
ways of ensuring that a port, region or whole fishing industry has resilience. Removing that diversity
would be to undermine an important balance.
Greenpeace’s attempt to exploit artificial divisions
within the fishing industry such as the entirely artificial administrative
dividing line at 10 metres is as unhelpful as it is contemptible. But if taken
seriously and larger vessels were removed from the fleet, the result would be:
- Uncaught UK quota
- The failure of important UK fishing
ports - The failure of those small-scale fleets
which are currently dependent on supply chains and port infrastructures
sustained by the continuity of supply provided by larger vessels.
A big vessel
To
make its case for redistribution of quota the Greenpeace report spotlights a
large Dutch owned UK registered freezer trawler. The case study is a wonderful
case of misinformation and comparing apples with oranges. It is difficult to see how the vessel’s
entitlements for mackerel, northern blue whiting, and horse mackerel have any
bearing whatsoever on under 10m fisheries. This is a red herring, presumably included in the report because the vessel
is large (pelagic vessels generally are) and because the ultimate owners are
Dutch. It is important that non-UK vessels on the UK fishing register
contribute appropriately to ensure that the economic benefits associated with
quota accrue to the UK. What Greenpeace chose not to highlight was that despite
Dutch ownership the vessel has a crew of 63 fishermen, all of them domiciled in
the UK and the vessel is managed by an English company, with offices in England
and paying UK taxes. It also chooses not to draw attention to the EU rules
which prevent discrimination on the grounds of nationality in the allocation of
quota or fishing licences.
Property
Rights
The system of Fixed Quota Allocations in the UK
evolved in a pragmatic, largely unplanned way, in response to various pressures
and opportunities. On the whole, it is one of the most advanced quota
management arrangements in Europe, with a high degree of decentralisation and
flexibility. The transition to the current arrangements certainly played an
important role in ending the blight of over-quota landings prevalent in the
1990s. It is not perfect, few things are. But it is very far from being the
perfidious, property heist that Greenpeace would want us to believe.
The allocation of quota will always be
controversial, whether between member states, devolved administrations, fleet
segments and vessels within groups because to a large degree it determines share
of income. Fisheries managers have a responsibility to allocate quota in a way
that is perceived to be broadly equitable but also in a way which is consistent
with broader management objectives, such as sustainability. Historical track
record has been widely used because it provides a claim based on use. In the UK,
the allocations system evolved into one in which this underlying approach has
been supplemented by decentralised management, quota trading, as well as
allocations based on environmental criteria (for example the Catch Quota
system).
The new CFP reaffirms member states’ authority to
allocate on any basis that they deem fit but requires that the criteria
employed, economic, social, environmental etc. are explicit. Member states
continue to face decisions on the degree of support for artisanal fishing one hand and providing security of tenure as a basis for investment and sustainability.
Generally speaking, the extremes of this debate (unconstrained market forces vs
social engineering) are not very helpful in finding a fair and proportionate
balance. Neither is the quality of the debate helped by wild and unsustainable
assertions. Greenpeace, for example, states that UK “quota is often held and
controlled by non-fishermen.” In fact the UK quota register suggests that the percentage
of UK quota held by non-fishermen is very small, about 4.5%.
The future of quota management in the UK, will we
hope, be based on a sober analysis of options, weighing the benefits of what we
have in relation to the advantages and disadvantages of change in a particular
direction. We will probably not be able to avoid the more voluble contributions
of Greenpeace but we can at least see them for what they are. Poorly thought
through, somewhat naïve, somewhat disingenuous, somewhat manipulative and
certainly divisive interventions which don’t really help, least of all
small-scale inshore fishermen.
An
exclusive 12 Mile Limit?
Greenpeace argues that
the historical rights of some other member states’ fleets to fish between the 6
and 12 mile limits should be extinguished. There is no doubt that removing
competition from other member state fleets would be a very popular move amongst
inshore fishermen, including many NFFO members, not least in the Thames estuary
and Bristol Channel.
However, any honest assessment of the pros and cons would
reveal the major obstacles to achieving this objective, which Greenpeace choose
not to discuss, despite their centrality to the issue. Greenpeace must
recognise this, which makes this part of their report little more than
opportunistic posturing; either that or they anticipate the UK leaving the EU.
The CFP reform having been settled last year, politically,
there is no realistic prospect of changing the historic access rights before
the next CFP reform within the next 10 years. Even then, there is the question
of whether this item can climb to the top of the UK’s CFP priorities.
Furthermore, the Government would face a price
for other member states to agree. It is obvious that other member states will
not voluntarily surrender an established right enshrined in the basic CFP
regulation, which they benefit from, unless they can be persuaded that they
want something else more. During the last two CFP reforms the status quo on
historical rights has not been challenged, in fact it has not been raised. Any
discussion that has taken place has been in relation to whether the existing
derogations from equal access which gives member states exclusive control out
to 6 miles should be retained. Sometimes it is better to let sleeping dogs lie.
It is easy to see the populist appeal of demanding
the expulsion of all foreign vessels from UK territorial waters but it’s not
going to happen any time soon.
In this sense, this part of the Greenpeace report is
just dishonest. By raising expectations that non-UK vessels can easily be
stripped of their historical rights, is a cruel hoax; cheap words with nothing
to back them up.
Conclusion
Greenpeace in this report concedes, perhaps somewhat
reluctantly, that progress is being made to put our fisheries on a sustainable
footing. The weight of evidence is now simply too heavy for them to come to any
other conclusion.
Greenpeace remains committed however, to a divisive
narrative which splits fishing vessels into two categories: small (good) and
big (bad). This is not supported by the evidence which suggests that our fleets
are in fact a continuum of vessel sizes, methods and target species, exploiting
both inshore, offshore and indeed, distant waters; in any event, it is not the
scale of the vessels in a fishery which matters in terms of sustainability but
how the fishery is managed.
To support
its divisive narrative, Greenpeace uses misleading and spurious statistics to
suggest a massive imbalance in quota allocation; and to suggest an injustice of
historic proportions that leaves the small-scale fishers of this country
starved of quota. In fact, with the exception of Channel cod where the problem
is the UK’s low national quota share,
quota shortage in the under-10m sector is regionally specific, and varies by
species, and from year to year. The NFFO has advanced positive suggestions on
how these quota pinch-points could be addressed in real time.
The Greenpeace report concludes that a transfer of
quota from the offshore fleet to the inshore fleet would not only rectify an
historic injustice but it would lay the foundations for a different kind of
fishing industry in the UK – a cottage industry.
The reality is that such a policy approach, if
pursued, would be disastrous for the very people that Greenpeace purports to
support. Pursuing the Greenpeace solution would draw in additional vessels into
the inshore fisheries for quota species. Many of the inshore fishing grounds
are already saturated with gear and the existing small-scale fishermen could
only be worse off under these circumstances.
Maintaining the diversity of our fleets is the best
guarantee of a resilient UK fleet and sustainable fisheries for the future.