Memorandum submitted by English Nature,
Scottish Natural Heritage, Countryside Council for Wales and the
Joint Nature Conservation Committee (T18)
The Joint Nature Conservation Committee (JNCC)
is the forum through which the three country agenciesEnglish
Nature (EN), the Countryside Council for Wales (CCW) and Scottish
Natural Heritage (SNH)deliver their responsibilities for
Great Britain and internationally. These responsibilities contribute
to sustaining and enriching biological diversity and sustaining
natural systems, they include:
Advising ministers on the development
of policies for, or affecting nature conservation.
The provision of advice and knowledge
to anyone on nature conservation issues.
The establishment of common standards
throughout Great Britain for the monitoring of nature conservation
and for research into conservation and the analysis of results.
The commissioning and/or support
of research to support the above.
The JNCC and the country agencies established
a marine fisheries working group in the early 1990s. This group
has used its combined experience to inform the development of
national policies and legislation relating to fisheries and nature
conservation. The focus of the group includes the revision of
We believe that the following issues are the
greatest presently facing the UK fishing industry.
The need to integrate fisheries and
environmental policy at all levels.
The need for a rapid and significant
reduction in fishing effort in nearly all fisheries. We believe
that this should be carried out through a properly resourced decommissioning
scheme, rather than through temporary "tie-up".
The management of European Seas should
be devolved to an appropriate "regional seas" level.
The need for significantly improved
management of new, particularly deep-sea, fisheries.
The greater use of non-take zones.
We agreed largely with the five essential objectives
of the 1999 report on Sea Fishing. However, we consider that the
scope of the Inquiry precluded the essential aspect of addressing
the environmental effects of the fishing on the marine environment
and, hence, none of these five objectives deal directly with environmental
issues. We recognise that the Committee did not wish to repeat
the work of the previous Agriculture Committee in 1992-93, but
consider that the complexity of the issues involving the fishing
industry cannot be addressed adequately without taking account
of environmental issues. It is plain to us, and indeed most fisheries
managers, that environmental objectives must be integrated into
any fisheries management scheme.
Despite this omission from the 1999 report,
we are pleased to note that both the UK and the European Commission
have made some progress in this integration. For instance, a ban
on drift nets is scheduled to come into force early in 2002 and
sandeel fishing off eastern Scotland is being regulated to help
ensure that the needs of sandeel predators are being met.
There is however little doubt that the fishing
industry has a greater effect on the marine environment than any
other human activity; there therefore needs to be greater and
deeper account taken of the needs of the environment within fisheries
management. We consider that this is best achieved by much greater
integration between environmental and fisheries policy. We were
pleased that the Government placed such integration at the head
of their list of objectives to improve the CFP. To a relatively
large extent, the objectives of fish stock conservation and those
of nature conservation coincide. Because of this coincidence,
many of the necessary measures to make fishing more sustainable
are the same as those needed to reduce impact on the marine environment.
The Committee called for an objective to promote
sustainability of resources to safeguard the long-term success
of both the stocks and the industry. The primary policy response
to this objective must be to reduce fishing pressure on the stocks
and the environmental substantially. Independent scientists have
consistently advised that such cuts in fishing effort need to
be in the order of 50 per cent, with some stocks being in such
bad shape that a greater cut is required. We believe that the
only rational way to achieve this is to cut the size of the fleets
that exploit these stocks by a similar amount. This can only be
carried out through a properly funded decommissioning scheme accompanied
by focussed efforts to assist those communities and diversify
the economy in areas that are particularly dependent on fisheries.
It is obvious that the current capacity of the
fishing industry is too large as, despite the efforts of many
scientists and regulators, many stocks (about 2/3rds of those
in European waters) are classified as being over-fished and have
only become so in the last few years. Due to the urgency of the
situation and the likely lag that there will be introducing the
necessary decommissioning scheme, we recommend that a tie-up scheme
might be introduced as a first stage in a decommissioning scheme
for those fishing vessels targeting those stocks in the most dire
straits. Even if stocks were allowed to recover through temporary
tie-up schemes, it is plain that fleets are too large and this
problem is exacerbated by continual improvements in the technology
of fish capture. A reduction in fleet size would also go a long
way to achieving the remainder of the Committee's essential objectives:
efficient exploitation of stocks; improving profitability; minimising
the cost to the public purse and minimising regulatory complexity.
Whilst we consider that small-scale inshore
fisheries may need some insulation from the large-scale cuts we
are concerned that owners of decommissioned vessels do not reinvest
their money in new inshore vessels, thus increasing fishing pressure
on stocks and the marine environment. We note that the Canadian
government spent in the order of 1.3 billion Canadian dollars
on decommissioning, retraining and community support measures
following the collapse of the eastern Canadian cod stocks. A recent
evaluation has shown the result of this has been an overall increase
to 140 per cent of previous capacity of the fishing fleets. We
recommend that such counter-productive scenarios be avoided.
Fleet size reductions plainly have to be co-ordinated
with other EU member states to ensure fairness. The latest EU
wide scheme to reduce effort was the five year MAGP IV. The fleet
targets within this programme were set so low by member governments
that most countries met their obligations within a year or two
of the start of the programme. We would support strong political
measures to establish a much more radical scheme to cut fleet
size in the next round of co-ordinated EU decommissioning.
The Committee endorsed the precautionary approach
but registered concern at the way that it had been introduced,
but nevertheless endorsed the approach. We consider that the precautionary
approach should also be applied when considering environmental
issues in the fisheries management decision-making process.
We believe that the best way to achieve a more
holistic management regime is an ecosystem-based approach. This
would be best achieved by devolving fisheries management to regional
seas (eg Baltic, North, Irish Seas) and including more formally
a range of stake-holders in the decision-making process. Such
stake-holders would include representatives of fishers and of
statutory nature conservation organisations.
We feel that the current management of the CFP
is much too centralised and exclusive of those affected by decisions.
We recognise though the legal difficulties that would come with
applying the principle of subsidiarity to fisheries management
for offshore seas, so suggest that regional seas advisory bodies
be established initially. The inclusion of fishers in this process
should help reduce the concern surrounding new approaches to fisheries
We were disappointed that the Government has
considered that the inclusion of statutory nature conservation
agency advice in the current consultative committees that include
fishers is not needed. In particular, the opportunity to include
environmental considerations into the current process that has
been developing recovery plans for severely deleted stocks has
not been taken.
We note that the Committee recommended that
the fisheries research organisations assist in the development
of new fishing grounds through proper stock assessments. The Committee
further believed that the environmental impact of fishing of new
stocks or new grounds should be taken fully into account. Despite
the Governments agreement with this recommendation, we have been
scant evidence of this occurring in practice. We are particularly
concerned with the development of deep-sea fisheries where several
fish stocks have been successively targeted and then depleted
to below a commercially viable size. These fish stocks, as with
many organisms in the deep sea, are particularly susceptible to
fishing as the species are long-lived and have a very low reproductive
rate. Fishing capacity and technology in this sector has continued
to increase as has the impact of fishing on previously untouched
(by fishing gear) environments. The biological nature of these
stocks makes management through the setting of TACs and quotas
inappropriate, and it is likely that only strict management of
effort at a fraction of its current size would be sustainable
in the long term.
We agreed with the Committee's support of the
principle of no-take zones and closed areas. However we were disappointed
that both the Committee and the Government failed to acknowledge
the further benefits to the environment that would come from such
closed areas. We believe that, as with cuts in fishing effort,
there is much to be gained for both fish stock conservation and
nature conservation from no-take zones, particularly permanently
closed areas. We are disappointed that no no-take zones have been
introduced since the publication of the Committee's report.
1 May 2001