APPENDIX 18
Supplementary Memorandum submitted by
the Scottish Fishermen's Federation (J 31)
Thank you for your letter of 18 January addressed
to Mr Alex Smith, the Federation's President.
1. MAGP IV
You ask specifically for our opinion of the
UK approach to MAGP IV. The UK Government has been scrupulous
in the imposition of all capacity reduction measures but has ignored,
almost entirely, the countervailing facilities for Fleet Modernisation.
This contrasts sharply with the attitude in competitor countries.
In the Federation's opinion the size of the
Scottish Fishing Fleet is now broadly in line with its sustainable
fishing opportunities. The continuing trickle of new investment
will further erode the fleet's size through aggregation penalties.
Of course those penalties must be reassessed as part of the Federation's
campaign to secure a programme of Fleet Modernisation. Engine
power and capacity restrictions must acknowledge technological
advances, the trend towards more comfortable and spacious crew
accommodation, and above all, safety considerations.
In the circumstances, the Federation does not
accept the need for further, substantial, capacity reductions
and believes that the way forward lies in an Industry-led regional
management system reinforced by improved scientific assessment.
Taken together these measures would form a secure basis for the
modernised fleet to which the Federation is committed.
2. SPANISH FLEET
MODERNISATION
The Spanish Fleet renewal programme is a matter
of public record, with frequent reports of progress carried in
the Fishing Press. Precise details will be available from the
Spanish Government or the Commission. There is no suggestion by
the Federation that Spain is behaving in any way improperly. The
Federation's regret is that the UK Government is unwilling to
make use of the facilities which have been taken up, so enthusiastically,
by the Spanish.
3. AGENDA 2000
The Federation has not yet considered, formally,
the Commission's proposed Regulation to recast the rules for Structural
assistance. At earlier stages in the generation of these draft
regulations the Federation was consulted, in a general way, by
Scottish Office.
The general concept of varying the rates of
financial assistance according to the "Objective" status
of the area concerned does not seem appropriate to the Fishing
Industry where the assets are mobile. Because of this proposed
change, it will be necessary to have two separate guidance funds
dedicated to the same purpose, albeit in different geographical
areas. The Federation would prefer the existing system of financial
aid for fishing vessels to be available on a sectoral rather than
a geographic basis.
The provisions for providing financial assistance
to enterprises involved in supporting the fishing fleet or processing
and distributing its products should also remain the subject of
sectoral assistance. If such activities are included in general
regional development programmes then they risk being "crowded-out"
by more fashionable manufacturing and tourism projects.
4. ENFORCEMENT
The Federation was anxious to make the point
that policy development on input and output controls appears to
proceed without any cross reference amongst the controls. In the
worst case, the mackerel fishery, it is possible to anticipate,
within a year or two, that a combination of capacity and effort
controls will make it impossible for the Pelagic fleet to catch
its quota. Such a situation would result, inevitably, in a claim
from Norway that their share of the TAC should rise and that ours
should be reduced. Some work is required to integrate the various
controls on the fleet.
The actions of the Scottish Fisheries Protection
Agency present no fundamental problem, although arguments can
always be made for greater flexibility and discretion in the policing
of regulations. The real problem is the multiplicity and interaction
of the regulations.
5. DESIGNATED
PORTS
The designated ports scheme is designed to treat
the symptoms rather than tackle the causes of overquota fishing.
Progress towards an Industry-led regional management system, reinforced
by improved scientific assessment, is the most effective way to
correct the underlying problem.
The introduction of the designated ports scheme
has passed off, so far, without serious incident. There have been
the usual examples of Fisheries Officers applying the regulations
to the letter and thereby, making an ass of the law. To the extent
that "more rigorous Community requirements will apply to
vessels landing abroad", the Federation is reassured. It
remains to be seen what effects these new requirements will have
on quota-hoppers and pelagic freezer trawlers.
Individual ports outwith the designated list
will, of course, suffer commercially as a result of the scheme
and those economic effects should be monitored closely by local
enterprise agencies. Amongst fisherman directly affected by the
designated ports scheme there remains a deep seated hostility
to the whole project, based on the fact that this is a restriction
which is not imposed on their European competitors.
9 February 1999
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