23 July 2010
The NFFO and UKAFPO, the representative body for producer organisations in the UK, are to discuss ideas on the extension of the role of POs in the UK.
It has been agreed that a paper produced by the Federation provides a “useful and reasoned starting point” for talks
Producer organisations are a fixture in the management of fisheries in the UK. Over time their primary role has evolved from cooperative marketing (including managing the EU price intervention support mechanism) to the management of sectoral quotas on behalf of their members. Although wide variations in size, form and function are evident between the different POs, there is a widespread acknowledgement that they play a positive, and indeed pivotal, role within the fishing industry.
However, for a variety of reasons it would be a mistake for the fish producer organisations to rest on their laurels:
- It is widely expected have that following the election discussions will begin on a review of POs
- The (defeated) Scottish proposals on a separate quota management for Scotland contained a range of ideas on PO reform; these are likely to re-emerge
- The turbulence in the under 10 metre sector following the introduction of registration of buyers and sellers and its impact on the visibility of landings from the under 10 metre fleet, threatens to destabilise the system of FQAs and rights based management on which PO quota allocations depend
- New ministers will want to see a resolution to the under 10 metre quota issue
- CFP reform is likely to impact on POs in one way or another, although in general terms they are seen as a positive feature of the CFP
Producer Organisations can respond to this situation in a number of ways. They can:
- Wait and see what the Defra reform paper says and CFP reform says and respond accordingly
- Rely on the view that FQA holders have legitimate expectations with regard to their quota holdings and that this will be sufficient to protect against enforced redistribution or “re-balancing” of FQAs between the sector and under 10s
- Prepare for the debate ahead by discussing and adopting a progressive agenda that sets the scene for the next generation of PO management.
If the third option is taken the NFFO has already produced two papers that provide a basis for discussion:
- The NFFO response to the SAF project propositions1. The NFFO paper outlines a solution to the shortage of quota in the under 10s through:
- Capacity reduction through decommissioning or the Danish system of rights based management (with certain safeguards)
- Using quota released from a possible decommissioning scheme to facilitate the entry of super under 10s into POs
- A producer organisation for under 10s, or integration of under 10s into existing POs
- Reducing or eliminating the significance of the arbitrary under-10 metre dividing line
- The NFFO’s paper advocating the replacement of micro-management by sustainable fishing plans2, which would transfer management responsibilities to the fishing industry through a system of approval and audit. There are signs that the Commission will include some variation of this concept in its CFP proposals and the key to its delivery will be bodies such as producer organisations.
In these ideas lies the possibility of redefining the role of producer organisations as agents of a new CFP, relevant and purposeful, not just fearful and defensive.
Producer Organisations and an Expansion of Delegated Responsibilities
The strength of producer organisations lies in their proximity to the operational fishing vessels and their operators, and the opportunity that this provides to tailor management measures to reflect regional and fleet variations, such as the seasonality of different fisheries. This has provided the basis for delegated quota management responsibilities that are widely regarded as a highly successful model. This paper suggests that the experience of quota management in the UK and in other member states, should be the basis on which to build the mechanisms through which a transfer of responsibility from remote fisheries managers to the industry itself could be achieved.
Using this fundamental strength, it is possible to envisage a development and evolution of delegated responsibilities in which producer organisations could play an enhanced role. These could include:
- Producer organisations preparing and submitting sustainable fishing plans which would detail how the vessels in membership will fish over the next 3-5 years; this could be seen as the delivery mechanism through which simplification of the CFP could be achieved by moving away from prescriptive micro-management
- Through regional annual fisheries reports POs could provide fishing industry information and knowledge in a systematic form that could be used by both ICES and policy makers to inform and supplement fish stock assessments and fisheries policy
- Through these means, POs could contribute to the development of long term management plans for the fisheries of concern to their members
- Producer organisations could also be the means for dissolving the current divide at 10 metres, by incorporating under 10 metre vessels into existing POs or assisting the development of a new under 10metre PO (or POs)
- Through affiliation to national and international organisations, or where appropriate directly, a more decisive role in contributing to and influencing CFP and regional sea basin policy.
All this presupposes an evolution and expansion of the PO role from delegated quota management to a range of other delegated responsibilities, including technical measures and fisheries management.
It goes without saying that the expansion of POs’ delegated responsibilities would go hand in hand with the quota management, marketing, industry reputation and other roles currently performed.
Code of Practice
Taking on these new responsibilities will require POs to present themselves as responsible, professional, and capable. It could be in their interest to draw up a code of practice based on current PO best practice that makes clear what is expected of them.
Institutional Capacity
If producer organisations are to take on a range of new responsibilities the question of capacity will have to be addressed. Coordinating and preparing sustainable fishing plans will be a time consuming business and could require a range of skill sets that not all POs currently hold or could afford.
If sustainable fishing plans are part of the CFP reform it is likely that they will be facilitated through permissive legislation that will allow those POs, or those member states, willing and able to proceed. There will be no “big bang” after which sustainable fishing plans will supersede prescriptive micro-management. The Commission has already signalled that the successor to the European Fisheries Fund, after 2013, will include provisions to provide finance for additional capacity to increase industry’s ability to shoulder additional delegated responsibilities. POs should prepare to position themselves to take advantage of this and indeed, through representations, to shape the form through which this kind of support is provided.
Delegated Responsibility and Reduced Administrative Costs
The European Court of Auditors report on the CFP has drawn attention to the absurdity that in some member states the cost of administrating fisheries exceeds the revenue generated by those fisheries. In the medium to long term, ways must be found of managing fisheries more cost-effectively.
Delegating responsibility from central administrators makes sense in terms of effective governance; however it makes even more sense in terms of fiscal prudence. Once established, delegated responsibility, within a system of approvals and audits, offers the prospect of simplified and cheaper fisheries administration.
Fleet Restructure
One of the persistent challenges for effective fisheries administration lies in ensuring a broad balance between fleet capacity and available resources. Against the background of historic levels of overcapacity and technological creep, a system of rights based management that embraces the whole (or the overwhelming) part of the fleet, in the type of arrangements described in this paper could become a powerful tool for making necessary adjustments to fleet capacity.