The NFFO has written to the Secretary of State, George Eustice, arguing that additional quota…
Are Days the Answer?
The NFFO looks at claims that, post-Brexit, we could ditch quotas.
Recently, the argument that, after the UK has left the EU, effort control (days at sea limits) could replace quotas as the main management tool in the mixed demersal fisheries, has been finding some currency.
It is not difficult to see the appeal.
At a stroke, the discard problem would be solved, as vessels could land everything that they catch. The messy business of quota management, with its fixed quota allocations, swaps, leasing, top-slicing etc. could be dispensed with overnight. Instead, vessels would be given an annual allocation of days at sea. Full stop. In some versions of the theory, quota shares are converted into effort shares, which admittedly makes things more complex than a flat-rate number of days for every vessel in the fleet.
But before we take the leap of ditching the messy quota system let's have a look at the other side of the coin. There are a few reasons why effort might not be the road that we want to go down. Here are some of the counter-arguments:
1. Joint management of shared stocks. Even after we have left the EU, over 100 of our most important fisheries are on stocks that are shared with other countries. That will require some form of joint management through international agreement. The quota shares that the UK received under the CFP haven't reflected anything like the proportion of the fish located in our waters but even post-Brexit we will still have a deep interest in controlling overall fishing pressure on these stocks, wherever they are caught and irrespective of who catches them. That means agreeing, through bilateral or trilateral international agreements, total catches and the shares that each country can take. How do you share the international cake without quotas? Norway has absolutely no interest in effort control; and the EU, that we will have just left, needs its Relative Stability to share its catch internally. To move to a system of effort control it would be necessary to persuade these countries to move to the same arrangement; either that, or persuade them that it's ok for the UK to fish without quantitative catch limits. That's quite a tall order.
2. How many days? Quotas serve two purposes. They are intended to place a constraint on overall fishing mortality on each species. Secondly, they are a convenient way to distribute fishing rights amongst different countries and groups of fishermen. If there is a shift to effort control, and the fisheries policy is still informed by fisheries science, there is a real likelihood that the number of days would be set in relation to the weakest not the strongest species in the mix: the lowest common denominator. Effort control is not so attractive when the permitted days is around 60, rather than the 150, 200 or 300 days currently used by vessels to catch their quotas. Before we buy a pig-in-a-poke, it will serve us well to look into how many days we would get, rather than assume that it will be roughly similar to present.
3. Effort is a blunt tool and our experience of it, as part of the EU cod recovery plan, has not been a happy one. After 10 years of effort control it has been all but ditched by the EU after the withering conclusion by a key scientific committee that “there is no linear relationship between a reduction in fishing effort and a reduction in fishing mortality.” This is science-speak for the fact that fishing vessels are businesses and will seek to maximise their income by, for example, targeting the most valuable species in the mix, or fishing more intensively during the time they are permitted to go to sea. There are also safety implications associated with limiting time at sea that aren’t there in a quota system.
4. The Faeroes Islands have applied a system of effort control to cod, haddock and saithe since 1996. The steady decline in the spawning stock biomass for cod does not inspire confidence that effort control provides a sound alternative to quotas.
All this doesn't mean that it would be impossible to replace quotas with effort as the principal means of managing the mixed demersal fisheries but it does provide food for thought about the consequences of making it work at a practical level.
Neither quotas, or effort (or anything else) will work if there is an imbalance between fishing capacity and fishing resources. So the most fundamental element in a post-Brexit fisheries policy will be to ensure that fishing capacity in each sector of the fleet is in line with the fishing opportunities that are available.
In questioning whether effort control does in fact provide us with a silver bullet to solve the problems faced in mixed demersal fisheries, there is little point in swinging the pendulum too far the other way to deny that the quota system comes with its own problems and complexities that have to be worked out. Here are some:
1. Discards. Discards have provided the lubrication that has made the system of EU TACs and quotas in mixed fisheries work. If the quota on one species is exhausted it has, until now, been possible to continue fishing whilst discarding catches of that species. Although discards have been significantly reduced over the last 20 years (a 90% reduction in the North Sea groundfish fishery), the EU landing obligation currently being rolled out will end all discards of regulated species unless a specific exemption is granted. There is a growing appreciation that this is going to create a major problem of multiple chokes in our mixed fisheries from January 2019, when the LO is extended to cover all regulated species. It is already clear that the flexibilities that are supposed to deal with the choke issue are going to be inadequate. But if the political will was there, it would be perfectly possible to provide the flexibilities and adjustments that would allow for a workable discard ban. Norway, for example has operated a discard ban for many years but applies individual quotas to many fewer species than the EU. And post-Brexit, the UK will be able to adapt the terms of the landing obligation applied in UK waters without having to go through the cumbersome EU co-decision process.
2. FQAs. The arrival of fixed quota allocations in the late 1990s, was one of the key policies, which allowed us to move away from the damaging and chaotic era of black fish. Over-quota landings were pushed to the margins rather than being central stage. Security of tenure encouraged a sense of stewardship that has served us well as we came through the difficult era of cod recovery. It has underpinned stability and planning for fishing businesses. The main criticisms have come from those marginalised by the FQA arrangements: from the under-10s excluded from the system, who have also been forced to deal with the consequences of effort displaced from the over-10 sector. Criticisms have also come from new entrants and those seeking to expand their businesses, and those facing high lease costs.
Bringing precision quota management to that part of the under-10metre fleet that needs it and exploring whether genuinely low-impact inshore vessels could be taken out of the quota system altogether (under a notional allocation set aside for them) is important work in progress.
Likewise, other elements of the FQA system will be part of the debate on the UK’s post–Brexit regime. There is likely to be a focus on constraints on concentration of quota ownership; how to provide stability and continuity for quota holders through a formal system of use-rights; the best way to encourage new entrants; and the introduction of licence charges.
Eyes wide open
It is good for existing arrangements to be challenged and the potential for alternatives to be thoroughly examined. But it is important to go into the future with our eyes wide open. Our conclusion is that the system of TACs and quotas comes with many challenges, especially within the context of the landings obligation. But a leap into an unworkable system of effort control could be a lot worse.