NFFO Chairman’s Report 2022

Persistently high and volatile fuel costs and the scale of potential displacement from customary fishing grounds are the new threats to the viability of our industry.

The Fisheries Act, the Joint Fisheries Statement and the development of fisheries management plans offer a pathway to a more agile and adaptive fisheries management system in the UK. This will however involve a huge amount of work and will take place within the constraints described above.

A united, vigorous, national organisation to provide the fishing industry with a strong voice where it counts is a prerequisite if we are to have any hope of shaping our future.

For 45 years the NFFO has made sure that government of the day knows, with absolute clarity, the considered unified view of the fishing industry in England and Wales. The need for a unified industry speaking with a single voice has never been stronger.

Fuel Costs

The most immediate challenge facing our fleets is undoubtedly the high cost of fuel. The price has, for several weeks, been hovering around the point where it becomes no longer viable to go to sea because earnings no longer cover costs – of which fuel is the most significant component. Approaches to government for a short-term support package have been rejected on the ground that fishing still has the duty rebate on red diesel and fishing is only one amongst many sectors facing difficulties. Fishing, however, as price takers, rather than price makers cannot, unlike other sectors, simply pass on higher fuel costs to the consumers. When vessels are forced to tie-up the whole supply chain is affected. The NFFO has asked what contingency plans have been made by the government to deal with the situation, should supplies dry up – so far without response.

Ukraine

In addition to adding to the spike in energy costs, the war in Ukraine has had profound knock-on effects, some of which impact on fishing. A revaluation of energy policy has triggered an accelerated expansion of offshore wind and the relaxation of the consents process. Both of these have potentially profound implications for the displacement of fishing activity.

A rethink on food security is also under way. The UK’s negotiating priorities in this year’s autumn fisheries negotiations may prioritise access to cod and other whitefish species previously sourced from Russia. Russian scientists and data have been suspended within the ICES system so certain stock assessments may be below the usual standard.

The war in Ukraine has and will continue to have major impacts on fishing and fishing policy.

Following the impact of covid related lockdown, the fuel price crisis highlights the absence of well-thought-out contingency plans to deal with a variety of shocks impacting primary producers and supply chains. Caught-out by surprise each time and reacting in an uncoordinated, unplanned, ad-hoc way is simply not adequate. More robust planning is required but short-term support is the urgent immediate necessity.

Offshore Wind and NFFO/SFF Spatial Squeeze Report

The expansion of offshore wind at pace is a major contributor to net carbon zero. How that expansion is handled will have profound consequences for the fishing industry, as spelt out in the jointly commissioned NFFO/SFF Spatial Squeeze report, undertaken by authoritative consultants, ABPmer, and published earlier this month (See Annex). Offshore wind will have an immense impact on where we can fish but the difference between the worst-case and the best-case scenarios is very significant. Much can be done to mitigate displacement through careful site planning and design decisions but here is no sign yet that the Government has a coherent policy to deal with fisheries displacement.

Given the intensity of the proposed expansion of floating wind platforms in the Celtic Sea, the Federation has formed a regional group through which to share information and coordinate response to the multiple licence applications in the pipeline. This is a model that may be appropriate for other areas too.

Marine Protected Areas and Displacement

This is also true of management measures within marine protected areas. With accelerated timetables for management measures and the introduction of highly protected marine areas, government policy has largely substituted a bulldozer approach for the evidence and dialogue-based approach which preceded it. We know that fisheries displacement can generate unintended effects and the scale of displacement implied by the government’s energy and nature conservation policy is likely to be a major factor in the future of our fisheries and fisheries management. A summary of the Spatial Squeeze and the worst-case scenario is reproduced at the end of this report. The report will now form the platform on which we will fight for recognition of the displacement issue and for an adequate joined-up Government response to protect food production areas and systems.

Bottom Trawling/Landing Obligation

A persistent anti-trawling drumbeat against trawling has been a feature of fisheries politics for two or three years. As around 58% of the UK’s catch is made by this method and the calls for a ban have been at the level of slogans rather than serious, considered, evidence-based, policy proposals, it is all to easy to dismiss these efforts as incidental noise. What makes these campaigns dangerous, however, is that politicians and decision-makers can be trapped by populist politics and their own electoral self-interest into knee-jerk reactive measures. The classic example of this has been the EU landings obligation, for which the UK government is actively seeking the exit door without conceding the principle of minimising unwanted catch.

The strongest safeguard that we have in this regard is that one of the eight objectives in the Fisheries Act is that management measures must be evidence-based. Providing food for people to eat is the strongest argument in favour of bottom trawling and its detractors have yet to address the practical consequences of the policies that they advocate. Every fishing method (indeed every human activity) has an environmental impact which must be managed and minimised and there is much work going on in this field. The work of Ray Hilborn and his team in Washington University have made plain that despite the misinformation peddled by its detractors, fishing has one of the lowest ecological footprints of any food production systems. This is not to deny that in both terrestrial and marine spheres that there are biodiversity challenges. We, as an industry have a responsibility to make further progress but this must be done in a way that is evidence-based, proportionate and recognises that food security is a key element in the matrix.

Risk, Safety, and Training

Over the past 12 months, our Federation has greatly strengthened its work in the area of fishing vessel risk assessment, safety and training. A revamped Safety Committee, under a new chairman, Nigel Blazeby, and the appointment of an experienced and energetic full-time officer, Charles Blyth, have begun to encourage the MCA to move towards greater two-way communication with the industry and to assist vessel operators’ compliance with the complex raft of safety rules. Although it is early days the signs are very encouraging. The NFFO is committed to high standards of safety aboard fishing vessels and is more than ever convinced that active engagement in the risk assessment process is the means to achieve high levels of compliance. A particular focus has been to bring a degree of common sense and realism to the new under-15m safety code and to have an approach to vessel stability that has a degree of flexibility to meet varying circumstances. A meeting with Transport Minister, Robert Court emphasised that the problem lies not so much with the Code but the MCA’s approach to surveys. Representations to the Maritime and Coastguard Agency show early signs of having an impact. The Federation will continue this twin track approach of helping members and the wider industry achieve compliance, whilst making the case for a more flexible means of achieving high standards aboard all classes of fishing vessel.

Crew Welfare

Like many parts of the UK economy, parts of our fleets have become dependent on labour sourced from overseas. There is a particular responsibility on us to ensure that crew, whether recruited domestically or from overseas, are recruited fairly and treated well. It is well recognised that the Government’s own immigration policies have created an obstacle to using the skilled worker route (as opposed to relying on inappropriate transit visas) which increase labour vulnerabilities. There are strong legal safeguards for crews, not least in ILO 188, but enforcement – and prosecution when abuse is identified – is the key to stamping on those who misuse the system. The whole fishing industry should not be the subject of character assassination on the basis of actions of a few. Neither, however, should those who abuse their crews be protected from prosecution.

Bass

Seabass is an important fishery for many different vessels in many locations operating a wide range of gears. This heterogeneity makes managing this fishery a challenge, added to by a considerable recreational fishery and backdoor sales from unlicensed vessels to restaurants and retail outlets.

In fisheries negotiations, the NFFO in recent years has focussed on reducing the number of bass discarded dead as a result of rigidities in the catch limits applied. Discarded dead bass caught as unavoidable bycatch achieves nothing in rebuilding the stock and is the source of massive frustration within the industry.

Against this background it will be interesting to see the progress made by Defra/MMO in developing one of the first fisheries management plans for bass, using novel ways to ensure that everyone involved in the fishery’s voice is heard. The tricky part will be in defining a way through the many voices to a sustainable and profitable fishery based on a well-designed plan. One of the issues to be addressed is the degree to which, as a shared stock, it will also be a jointly managed stock with the EU, or whether the UK flows a separate path.

Shellfish

The NFFO was instrumental in setting up the Shellfish Industry Advisory Group, which now provides an effective voice for the economically important but previously underrepresented shellfish sector. With Seafish providing a dynamic secretariat, the umbrella group and its crab/lobster, whelk and scallop sub-groups) have taken the lead in the development of fisheries management plans for these sectors. This may provide a model for the often referred to but rarely defined concept of co-management. The shellfish sector, in representative terms has leapfrogged from poor cousin to possible exemplar and the NFFO should be proud of its role in achieving this progress. Many challenges lie ahead, including the management of non-quota species (see below) and displacement, but the sector is now much better equipped to deal with these.

Non-Quota Species

The Trade and Cooperation Agreement sets tonnage limits for EU vessels fishing non-quota species in UK waters (40KT) and UK vessels fishing in EU waters (12KT). In addition to this lack of symmetry, which echoes the distortions of the CFP, there are deep concerns about the transparency and accuracy of catch reports through which these complex multi-species, multi-gear and multi-jurisdiction fisheries will be managed in the future. In England and Wales, the value of landings of non-quota species (which range from the highly valuable to the economically negligible) exceeds the value of landings of quota species. This gives an idea of how important it is to get management of this complex and varied sector right. The flawed approach in the TCA and the emerging understanding of the task ahead has led the (UK-EU) Specialised Committee on Fisheries to suspend the enforcement of the agreed tonnage limitsin 2021 and 2022. Agreement on a multi-year strategy with the EU is a priority for the Specialised Committee but there is a mountain to climb in an area which, as we have seen, has the potential to become highly politicised.

Inshore Fisheries

In recent months dissatisfaction has been vocally expressed on some parts of the coast about heavy-handed management, glaring errors, and a wilful disinclination to deal fairly and openly with the industry. Some IFCAs have been singled out for particular criticism and a Defra review of the IFCA system is under way.  Not all parts of the coast have the same experience and the Federation has opened a dialogue with the Association of IFCAs to identify problem areas and discuss possible solutions.

The hugely successful conference The Future of Inshore Fisheries held in London in 2018 has had a mixed legacy. It was inspirational for many, providing a glimpse of how we could manage our multi-faceted inshore fisheries with high levels of participation from those in each fishery, and working in cooperation with fishers, fisheries scientists, and fisheries administrators (co-management). The conference spawned several initiatives, including regional fisheries groups around the coast, as Defra and the MMO seek to find better ways to communicate with the industry. The establishment of the Shellfish Industry Advisory Group is another strand which took its lead from the conference. In the North-West England a project involving the MMO, Seafish, the NFFO and local fishermen, seeks to address a range of issues associated with remoteness from markets and the seasonality of catches.

Although the myth-busting conference inspired a commitment to work on the basis of evidence and cooperation, covid undoubtedly set back the timetable and a priority now must be to reinvigorate the conference energy and rebuild momentum.

2026/Regulatory Autonomy/ Joint Fisheries Statement

Although there are few in the UK fishing industry that would see the Trade and Cooperation Agreement with the EU as anything other than a defeat, a disappointment and a setback, the TCA does not represent the CFP status quo. Although many CFP rules have been incorporated into UK domestic legislation (as EU retained law) the UK now has the scope to diverge from those rules when it its deemed necessary or desirable. In addition to regulatory autonomy over the fisheries within the UK EEZ, the UK now negotiates as an independent party in international fisheries agreements. This is significant.

The Fisheries Act 2020 and the Joint Fisheries Statement provide, respectively, a new legislative and a policy framework which over time will allow the development of a tailored fisheries policy for the UK, mainly through the implementation of fisheries management plans. This is a positive development but will require enormous effort and commitment to bring into reality. Work has begun on a tranche of frontrunner fisheries plans, including for shellfish, bass, flatfish in the Channel and Southern North Sea and mixed demersal species in the Channel.

The NFFO’s work within Parliament to secure a Fisheries Act that was fit for purpose has been widely acknowledged. This has been followed by an extensive and balanced response to the draft Joint Fisheries Statement. Work is underway on frontrunner fisheries management plans. Together these three strands represent the architecture of our future fisheries policy and so deserve maximum attention.

2026 marks the end of the transitional period which allows EU fleets to operate freely within the UK EEZ. After that point access will be a feature of annual fisheries negotiations. We can expect both the EU and the UK to manoeuvre for best position ahead of and during those negotiations, complicating the already complex task of managing shared stocks through the Specialised Committee for Fisheries.

Mixed Fisheries

A disproportionate amount of time is spent on managing the mixed demersal fisheries. Single species stock assessments provide only limited guidance when setting TACs in fisheries where stocks may be exhibiting different trends and conservation status. Zero TAC advice is not particularly helpful for fisheries managers in these circumstances. There are signs of a more flexible and subtle approach may be viable using real time catch information to help skippers avoid hotspots of vulnerable species. Cod in UK waters and spurdog are two front-runners for this particular approach.

Meanwhile, ICES continues to develop advice that shifts away from single species advice which allow sustainable harvesting across the range of species in a mixed fishery

Fisheries Science Partnerships

The NFFO has championed cooperation and mutual understanding between fishermen and fisheries scientists for over twenty years. The original Fisheries Science Partnership was a ground-breaking initiative through which data gaps were addressed through projects involving fisheries scientists and fishermen working collaboratively.

The concept has been picked up by the UK Seafood Fund. Although there are concerns that research organisations are better placed to access the necessary funds, there are signs that the fund will help to underpin fisheries management with good data. The bottom line is that is not possible to manage a fishery effectively on the basis of inadequate of inaccurate information. FSPs address the gaps.

NFFO Services Limited/ NFFO Training Trust

Our commercial division continues to make a major contribution in support of the Federation’s representative work and to minimising frictions between fishing operations and major offshore infrastructure development in the oil/gas or renewables sectors. The company regularly makes donations of £100,000 to the NFFO Training Trust to help young fishermen through certification and for fishing vessels to purchase certain types of safety equipment and for the education of the public about the fishing industry.

We owe a debt of gratitude is to Mr Bob Casson, chairman of the NFFO Training Trust and the other trustees whose efforts make the Trust work.

Markets

Leaving the EU single market and customs union carried the inevitable consequence of increased export documentation and higher costs. Although the initial period of disruption and delay at the border lasted only a few months, there has been some consolidation as smaller firms making smaller consignments have struggled with the new regime. Steps to streamline the export process have been taken and must go further. There has been, however, a very strong rebound from these changes and the covid lockdown and demand from the continent and elsewhere overseas is generally high. The exception to this broad picture is with those firms dealing in bi-valve molluscs who have had to face an obdurate and immovable Commission and have suffered badly.

The degree to which trade sanctions will be used as a political tool in the future in relation to the Northern Ireland Protocol, Ukraine, or post-TCA adjustment period changes is an open question. There is however, one fundamental feature in this relationship. The UK has immense fish and shellfish resources in its waters and there is huge demand in Europe for those resources. Numerous businesses on both sides of the Channel depend for their survival on that trading relationship to work smoothly.

Conclusion

There is only one conclusion. With all that is going on across multiple fronts, and what we can see is coming towards us in future years, it is absolutely essential that the fishing industry in England and Wales has a vigorous, inclusive, responsive, organisation at national level to ensure that its voice is heard.