Environment, Food and Rural Affairs CommitteeWritten evidence submitted by the New Under Ten Fishermen’s Association (NUTFA)

Summary

The New Under Ten Fishermen’s Association is the recognized national body representing specifically small scale fishers. In the UK this is deemed to be fishing vessels of less than 10 metres in length, making up 75% of the overall active fleet in England and Wales.

It is our experience that previous Reform processes have been characterised by the initial presentation of a range of good intentions that have been so diluted during the subsequent debate that has lead to the current dire situation for EU fisheries.

We are again promised radical change. Member States, Commission and the European Parliament (EP) are all seemingly of one in their determination to finally reverse the decline of fish stocks and related industries but experience of past reforms gives little cause for optimism.

Has the Commission set the right general objectives for the future CFP? What additional tools are needed to deliver the CFP’s objectives, for example measures to restrict fishing in certain areas such as spawning grounds?

Whilst the general objectives set by the Commission are broadly correct, it will undoubtedly be the subsequent actions, rather than current words that produce the results so desperately needed by all concerned.

The Reform proposals lack sufficient detail for us to make informed comment. Much of what is proposed is predicated on a significant element of regionalization under the co decision process and we are less than clear just how practical or possible that is in terms of the Lisbon Treaty and the clear antipathy between the Commission and the European Parliament. The Commissioner is already backtracking verbally on internationally tradable Concessions although they remain within the proposals.

On the wider front in this respect, we are concerned that Article 26 of the proposals seeks to maintain the current inequity whereby MS’s can only regulate the activities of their own fleet within territorial waters whilst other MS fleets fishing under historic rights within that zone can choose not to allow sensible conservation regulations to affect the activities of their vessels.

Is a landing obligation the most appropriate way to address the problem of discards? What implications do the proposals have for the social and economic viability of UK fishers and coastal communities? What measures should be used to manage over-capacity in the fishing fleet? Does the proposed system of transferable fishing concessions contain sufficient safeguards? Will the Commission’s proposals to decentralise decision-making improve the governance of the EU’s fisheries?

Here is the nub of the problem, on the one hand it is clearly obscene and a crime against nature to extract a potentially endlessly renewable resource from the seas, often with wider environmental impacts and at great risk and expense only to then throw back often the majority of it unutilised. When this activity is also the major contributing factor to the potentially complete destruction of that natural resource then something has to change, and change both radically and quickly. Catching less yet landing more is entirely feasible and a progressive ban on discarding, preferably with discarding done at the seabed, at or before the point of capture [sic] would seem a sensible target.

At the same time, the majority of EU and UK catching capacity is based on the extensive use of heavy mobile gears in mixed fisheries and the economic aspects of these operations mean that there is currently no quick fix, certainly in the short term, without undue socio economic impacts.

My colleagues from the over 10 sector will no doubt have provided the Committee with a great many reasons for caution in the way that this problem is approached. From the perspective of the small scale fleet, we tend to use passive gears, nets, lines and traps, as well as mainly light mobile gears. Members will have received evidence already from the New Economics Foundation in regard to the wider socio economic and environmental costs of various gear types and will be aware of both the UK Government and the Commission’s own recognition of the overarching benefits of small scale operations in these terms.

We of course recognize that small boats cannot catch the overall amount of fish available in UK waters and that there is an obvious need for a range of sizes of vessel to capitalize on the annually available fishing opportunities. So rather than look at it from a specifically vessel size viewpoint, we suggest that it is the level of impact of particular operations that should determine access to these public resources.

Implemented and managed effectively, the gradual implementation of such an approach would not necessarily negatively impact on any one sector whilst at the same time, provide real encouragement for all concerned to implement change without further obfuscation or delay.

The proposal that MS’s can hold back 5% of fishing opportunities to provide incentives to fishing vessels deploying selective fishing gear that eliminates unwanted by catch sets a precedent for recognizing and rewarding vessels that have a low impact. However, this incentive is only available to vessels under the Transferable Fishing Concessions (TFC) scheme that will potentially exclude all vessels under twelve metres in length not using towed gear, ie those vessels that should be rewarded and supported.

The Declaration presented to the European Commission and Parliament recently, signed by 160 individuals and organizations representing probably the majority of environmental, NGO and artisinal and coastal fishers in the EU (NB: 80% of EU fleet is deemed to be “small scale”) is attached at Annex I.

It is a genuine, important and successful attempt to bring together a range of factions to illustrate the strength of view in support of a move from the current management and allocation system to a position where access rights should no longer be based solely on historical catches, that replacing the more harmful fishing methods with those that are less so and that by giving primary access to fishers (of whatever size of vessel) based on social and environmental criteria would foster a dynamic that would lead to improved fishing practices and a more environmentally, socially and economically sustainable fishing industry.

With reference to socio economic sustainability and on top of the ruination of thousands of jobs and uncountable numbers of fish, the Commission is now stating that we can expect a further significant reduction in EU fisheries related employment over the next 10 years. At the same time, there is nothing within their proposals that can guarantee the revival of fish stocks and therefore the survival of a multitude of fishing communities. It is entirely fair, based on past experience, to expect that the “radical” reforms promised at the outset of the process will be so diluted as to make insufficient difference to what often seems like the inevitable outcome of serial mismanagement by all concerned in EU fisheries.

It is also perverse for some to argue in favour of rights based management on the basis that vessels are insufficiently profitable such that they have to employ third world crew when this will do little to provide available socio economic benefits to indigenous communities from a public resource. Rather than reduce employment opportunities, a gradual move towards a fairer system of access based on the aims within the Declaration could provide more jobs, more fish (certainly more than the CFP is likely to produce going on past performance) and very significantly reduce the environmental impact of the catching sector.

Of course, a Transferable Fishing Concessions scheme as proposed will maintain the system of rewards to those who have had and continue to have the greatest impact, in direct contrast to the aims within the Declaration. Whilst this approach may very well suit those who have and continue to benefit from what already amounts to an individual transferable quota system in the UK, it will do little more than continue the current inequity within the system and further hasten the decline of those, including a significant number of over 10 metre fishing vessels, who have been denied fair and equitable access to a public resource.

In recent months, a range of respected representatives from both under and over 10 metre sectors have made it clear that the current market based system of quota allocation has become untenable. There are any number of examples of fishers having to discard vast quantities of fish as the cost of leasing quota to cover a catch is impractical. Committee members have previously commented particularly wisely on these aspects and the implementation of transferable fishing concessions will only make things worse in this respect, not better.

Members should be aware that internationally tradable TFC’s, as proposed, are a certain recipe for disaster for UK fisheries. In the same vein, even internally tradable TFC’s would favour only the most economically powerful operators rather than the most sustainable.

Both Defra and the Commission have recently used the Danish example of the implementation of an RBM system in support of their desire for a similar system. Annex II is a report provided by Danish small scale representatives and academics that illustrates that such an approach in fact has had the opposite effect on small scale and coastal communities and has resulted in the loss of many such people and places.

Do the proposals set the right framework for implementing an ecosystem based approach, including improving the availability of scientific data?

Fisheries management and especially the required scientific support structure doesn’t come cheap and we are concerned that there are insufficient resources available to provide the necessary input. Notwithstanding the apparent inability or reluctance on the part of some MS’s to provide legally required data, a new co-management approach is needed if we are to collectively gather, consider and act meaningfully with reference to fisheries data. With the plethora of environmental, spatial and fisheries activities within the marine environment and their increasingly competitive interaction, we strongly suggest that fisheries science cooperation is greatly enhanced.

Nutfa is a member of the PISCES Project seeking to design recommendations for the implementation of an ecosystem based approach within the Irish Sea. On that basis we are entirely supportive of the aim within the proposals in this respect.

What actions could the UK Government take to encourage ambitious reform of the CFP?

Almost every commentator, MS, the Commission and the European Parliament et al have stated their identification of and support for a radical reform of the current policy. Much of what is in the proposals appears anything but radical for the most part and is likely to further benefit vested interests rather than the wider fishing community or marine environment.

We are in no doubt that despite the promises made by the many, over the life of both current and past policies, the deluge of suggested solutions based on tweaking, taking things cautiously, giving due consideration etc will not produce the desired outcomes. The UK must advocate direct and radical rewriting of the CFP if either the industry or fish stocks are going to survive for another 10 years of this policy.

October 2011