Environment, Food and Rural Affairs CommitteeWritten evidence submitted by the New Economics Foundation (nef)
nef (new economics foundation) welcomes the invitation to submit written evidence to the Environment, Food and Rural Affairs Committee’s enquiry on the reform of the Common Fisheries Policy (CFP).
nef is an independent think-and-do-tank that inspires and demonstrates real economic well-being. Our aim is to promote economics as if people and the planet mattered. Applying this approach to sustainable fisheries management is a key priority.
nef generally agree with the failings identified by the European Commission’s Green Paper, but we believe it should go a step further and recognise that most of the failures of the CFP emerge from a wider systemic problem, an economic system which fails to deliver for people and for the environment. A reformed Common Fisheries Policy must take into account the shortcomings of the economic systems within which fisheries operate if it wants to succeed in delivering its economic, social and environmental objectives and must value its natural capital.
1. Has the Commission set the right general objectives for the future CFP?
Fish, as a free bounty for humankind, should be managed to deliver sustainable and fair economic well-being, and should be managed to create maximum value to society. The Commission identifies that environmental objectives are not being met by the current CFP, although there is still a lack of emphasis on placing long-term environmental objectives as the central pillar of the policy. Without meeting environmental objectives, the policy will not be able to meet its social and economic objectives either.
2. What additional tools are needed to deliver the CFP’s objectives, for example measures to restrict fishing in certain areas such as spawning grounds?
Marine resources must be managed to deliver the maximum value1 to society. Fishing rights are currently allocated on “track records” and fishing history, paying no regard for which fishery delivers maximum value. The reformed CFP needs to address this issue.
Fisheries that deliver the best value to society should be given priority access to resources and fishing rights, with public funds targeted towards these types of fisheries.
Fleet capacity issues must be addressed by setting legally binding and timetabled capacity limits for each fishery, both qualitatively and quantitatively.
Fishing limits must be set in line with available resource, informed by legally binding scientific advice.
Measures to restrict environmentally damaging processes within sensitive habitats (such as spawning areas/seasons) must be implemented.
3. Is a landing obligation the most appropriate way to address the problem of discards?
The inherent problem is a current fixation with discarding, and not reducing the unwanted by-catch which results in discarding. There are a number of initiatives underway that are attempting to reduce by-catch levels (such as Project 50%, or the use of eliminator trawls), yet these practices rarely receive an incentive in the way of increased access to fish. A reformed CFP must promote by-catch reduction, and utilise the resulting catch in the best way to society. Fish of little commercial value, with high chances of survival if returned to the sea, should not be landed.
4. What implications do the proposals have for the social and economic viability of UK fishers and coastal communities?
The current economic indicators, such as GDP, fail to account for depreciation of natural and social capital. As a result, fishing activity that leads to overexploitation of resources, and the resulting increase in the vulnerability of the fishing sector, is treated as a positive contribution to the national economy. Unless the CFP addresses the issue of the true value of its fish stocks, fishers and coastal communities throughout the EU will continue to bear the brunt of the pressures.
5. What measures should be used to manage over-capacity in the fishing fleet?
It is assumed that market forces will take care of excess capacity. The Commission is being extremely prescriptive with Transferable Fishing Concessions (TFCs) being the sole method for addressing overcapacity, setting aside other practical tools, such as mandatory capacity ceilings, and capacity reduction programmes. We are concerned that the proposed system is not designed to ensure that capacity reduction is addressed in a qualitative way, ie ensuring that the most socially responsible and environmentally friendly methods are promoted or prioritised.
In order to achieve the fundamental objectives, a reformed CFP should require capacity reduction programmes that:
Evaluate the balance between fishing capacity and fishing opportunities on a fishery-by-fishery basis;
Establish qualitative and quantitative capacity management objectives and implementation plans, with mandatory, time-bound reduction targets for each fishery;
Create a combination of financial, legal and other instruments that allow a restructuring of the fishing fleet based on criteria prioritising environmentally and socially sustainable fishing;
End subsidies that support fleet capacity and overfishing; and
Acknowledge that, even once the fleet has reached a sustainable size, there is a need to mitigate the impacts of increased capacity due to technological improvements in order to maintain sustainable fleet capacity in the long term.
6. Does the proposed system of transferable fishing concessions contain sufficient safeguards?
Rights-Based Management, in particular transferable quotas, can be a tool within a more comprehensive management system that strengthens conservation and supports coastal communities, but should not be an exclusive tool. We therefore strongly recommend that rather than focusing on a single market-based system for fleet management, the EU adopts a different fishing access approach based on qualitative environmental and social criteria. Such criteria should include:
Selectivity—Different fishing methods result in different amounts of by-catch which are often discarded. Fishers using fishing methods with low by-catch should be given priority access to the available resources;
Environmental impact—The impact of different gears and practices on the environment vary widely, for example damage to the sea bed and pollution. Fishers using less destructive fishing methods should be given priority access;
Energy consumption—Some gear and vessel types require enormous amounts of energy compared to the fish they catch. Fishers using vessels and fishing methods consuming less energy per tonne of fish caught should be given priority access;
Employment and working conditions—Fishing methods that provide more employment, as long as they are also less damaging for the environment, should be given priority access. Working conditions should comply with relevant international standards;
Quality of product—The gear type used affects the quality of the fish caught. Fishers using gear types providing the best quality of fish for human consumption should be given priority access; and
History of compliance—Past compliance with the rules of the CFP by fishers as well as Member States should be considered when allocating access to fishing rights.
7. Will the Commission’s proposals to decentralise decision-making improve the governance of the EU’s fisheries?
While the Commission’s proposal aims at introducing some degree of decentralised decision-making, it does not live up to the expectations raised in its 2009 Green Paper. Lessons on how to realise a regional fisheries management approach could be learned from experience in other parts of the world, including the U.S. Regional Fisheries Management bodies. In the U.S., the Magnus Stevenson Act2 establishes a framework for regional fisheries management, as well as the high-level objectives and principles by which fisheries are managed. Regional councils are delegated the responsibility to create Fisheries Management Plans (FMPs) and regulations that are consistent not only with national standards, but other relevant environmental legislation.
8. Do the proposals set the right framework for implementing an ecosystem based approach, including improving the availability of scientific data?
The new CFP must make ecosystem-based fisheries management fully operational across all regions and within a set timeframe. The integration of EU environmental legislation (ie the Marine Strategy Framework Directive and the Habitats Directive) under the general objectives is a step into the right direction. The reformed CFP should also include firm timelines for the development and adoption of multiannual plans which are ecosystem-based and consistent with the requirements under the Marine Strategy Framework Directive to co-ordinate management regionally. Data collection and co-operation between fishers and scientists should be supported through the future European Maritime and Fisheries Fund. Member States failing to comply with their obligations under the data framework regulation should not be eligible for public funding.
9. What actions could the UK Government take to encourage ambitious reform of the CFP?
The UK Government should build on its recent work to value its natural capital and ecosystem services,3 as “getting the economics right” is an essential first step to move towards fair and sustainable fisheries. As such, the UK government has the potential to spearhead a pan-European review of its economic models:
Measuring the national capital—“Fisheries accounts”—describing the status and trends of the fish stocks and marine ecosystems—should be developed to describe whether the national capital is increasing or decreasing.
Pricing correctly—Current market prices do not reflect environmental or social costs. Any costs not paid for by the consumer are, in effect, borne by someone else (future generations, the marine ecosystem, a fisherman losing his job).
New guidance must be implemented on discounting natural resources as environmental benefits tend to occur in the mid-long term.
Businesses need to be financially viable. Public authorities must use every available lever (legislation, regulation, fiscal policy etc) to construct a framework that encourages fisheries related businesses to innovate towards social and environmental performance and create a context where being successful is synonymous with environmental best practice. For example, the vessels taking part in the successful Project 50% are not given any practical reward for innovation, which has led to the adapted gear not being adopted on a wider scale. The UK fisheries minister needs to fight to promote and reward the good practice currently being displayed within some sectors of the UK fleet.
29 August 2011
1 Economic, social and environmental value