The NFFO comments on where we are after the EU and UK have agreed arrangements for the 21 month…
Maintaining the Diversity of our Fleets is the best Guarantee of a Resilient UK Fleet and Sustainable Fisheries for the Future - NFFO
NFFO Response to Greenpeace/NUTFA Report "Championing coastal waters".
The recently published Greenpeace/NUTFA report, Championing coastal waters, is perhaps a little less toxic and a little more measured than previous Greenpeace publications on the UK fishing industry. It is however, a mix of motherhood and apple pie, cynical manipulation, half-truths and naivety which does not stand up to much scrutiny. Nevertheless, we are concerned, because its recommendations, if ever implemented, would have serious adverse consequences; most of all for the small-scale fishermen that Greenpeace cynically purports to support. Naivety, especially when tied to an immovable self-righteousness, is capable of doing great damage – but only if taken seriously by decision-makers.
We therefore feel compelled to respond.
Greenpeace Action Plan
• Regionalise fisheries management
• Restore fish stocks
• Protect the marine environment
• Redistribute quota to the under 10 metre sector
• Prioritise access for low-impact fishermen in the UK’s 0-12nm zone
But let’s start with a positive. We are particularly pleased to see Greenpeace support a shift away from top-down management to regional management of fisheries. This change has come 15 years after the NFFO and Scottish Fishermen’s Federation explained in detail why micro-management from Brussels was a significant part of why the CFP was failing to deliver effective conservation measures. “Zonal” management, as we called it at the time, has during the intervening period, gathered widespread support, leading ultimately to the inclusion of important provisions in the CFP for member states to take the lead in policy formation at regional seas level. During the 2002 CFP reform, the regional advisory councils were a first tentative step in this direction and the process has now gone a further step. It’s good that Greenpeace has seen the light and supports this potentially important break with remote top-down attempts at management.
The advisory councils have been one of the great successes of the last reform and it is encouraging that Greenpeace now seem to value their worth. But where have they been? The other NGOs have been happy to sit down with the fishing industry and work positively and collaboratively, whilst Greenpeace has rejected this kind of fraternisation. Anyway, there is always room at the advisory council tables, they are by design broad churches - but advisory councils can only work in the context of mutual respect and a spirit of compromise. If Greenpeace are up for that so are we. The NFFO has been very active in the advisory councils and intends to continue to be so. We would be very happy to repeat our offer to meet Greenpeace to discuss any issues relating to UK fisheries.
Restore Fish Stocks
Another area where we see progress is in Greenpeace’s position in relation to steadily rebuilding fish stocks. It is heartening but probably not unexpected that even Greenpeace has had to abandon its catastrophe narrative which posited that all fish stocks are on a trajectory to collapse; although it continues to imply that recovery cannot possibly be happening in offshore fisheries where the bigger boats work. Even though Greenpeace’s acknowledgement is grudging, the evidence is now simply overwhelming that a turning point in European fisheries came around 2000. Right across the North East Atlantic, and across all the main species groups fishing pressure has been dramatically reduced by around 50%; and with a few exceptions, our fish stocks are rebuilding steadily as a result, some dramatically. We are now having to address the problems of fisheries systems in which fish-on-fish predation is a bigger factor than fishing pressure. This is very good news.
Greenpeace argues that small-scale fisheries are inherently more sustainable than large scale fisheries. But the truth is that there are many examples of well-managed, sustainable, large-scale fisheries (Barents Sea cod, Northern Hake, North Sea haddock) and also many examples of sustainable small-scale fisheries. Equally, there are examples of both small-scale and large scale fisheries which are mismanaged and which are therefore, in the long term, unsustainable.
There is no inevitable correlation between scale and sustainability, so let’s knock that one on the head.
Where we can agree with Greenpeace is in relation to fishing capacity. It is very difficult if not impossible to manage quotas, or limit environmental footprint, if there is a fundamental imbalance between fleet capacity and available resources. Important decisions on where there is overcapacity, and how to address it where it exists, are absolutely fundamental to fisheries and marine environmental policy. This applies equally to the under and over-10 m fleets.
Redistribute Quota and Prioritise access to low impact fishermen
There are complex ethical and legal aspects associated with redistribution of quota from one fleet sector of the fleet to another, perhaps best illustrated by imagining the issue in relation to quota forcibly transferred from a 10.1 metre vessel to a 9.9 metre vessel. If the latter’s owner had sold his larger vessel, along with licence and quota, to join the under-10m fleet, as has not infrequently been the case in the past, the ethics become even more complex. But leaving aside these moral (and legal) complexities, but acknowledging the large amount of latent capacity within the under-10 m sector, the evidence suggests that if substantial amounts of relevant quota were transferred to the inshore fleet, especially to those using passive forms of gear as Greenpeace advocates, the result would be:
- An increase in the numbers of under-10m vessels operating in the already pressured inshore zone, as unutilised or under-utilised vessels become active, attracted by the new fishing opportunities
- A reduction in fishing activity offshore, where fishing pressure is already less intense
- An increase in the amount of static gear on grounds that are already saturated with gear
- Increased competition on the inshore grounds for space and fish
- Pressure on under-10m vessels to fish to fish further from customary grounds and further from the coast, with associated safety implications
This would be an example of one of the classic unintended consequences with which fisheries management abounds. The authorities think that they are doing one thing for the very best of motives and the results are entirely different from what was expected. A shift of fishing activity from offshore fisheries to inshore zones would be very bad news for existing small-scale fishermen.
All this is not to say that there are no quota shortages in the under-10m fleet that require addressing. There are shortages but they are not of generalised character Greenpeace and NUTFA assert. For propaganda purposes Greenpeace frequently refers to the fact that the under-10m fleet in the UK has access to only 4% of the total national quota. But as this figure can only be reached by including the vast tonnages of mackerel, herring, horse mackerel blue whiting and North East Arctic cod, which the under-10 meter fleet could never access, quota redistribution or not, it is all a bit meaningless.
Quota shortages in the under-10m fisheries tend to be regionally specific, stock specific, and vary from year to year. They are most acute where vessels have few alternatives (non-quota stocks) such as is the case as in the Thames estuary.
We have spelt out elsewhere our remedy for quota pinch points in the under -10m fleet and the success of the Ramsgate quota pilot underlines the validity of this approach. The essence of our approach is:
- Differentiating between the 14% of under-10m vessels which catch 70% of the under-10m quota allocations and the rest of the under-10m fleet which need flexibility to access to a variety of different quota species on a sporadic basis
- Encouraging the larger under-10s to form cooperative groups, with or without links to producer organisation to manage their quotas; producer organisations can however, provide professional quota management through which in-year quota allocations can be significantly enhanced through swaps, transfers, lease etc.
- There are therefore ways to address pinch-points in the quotas available to the under-10m fleet as they arise. But if Greenpeace/NUTFA are going to advocate the use of Article 17 of the new CFP to transfer quota to the inshore fleet, it is important that all involved do it with their eyes open and at least try understand the consequences.
It is probably timely for the NFFO to restate its position on fleet diversity. In the UK, and especially in England, we have an extremely diverse fleet in terms of vessel size, target species and areas of operation. We have a few very large vessel which fish the distant water grounds, or target the massive shoals of Atlantic mackerel, herring, horse mackerel and blue whiting; but we also have many small and medium sized vessels which prosecute a range of different grounds and species. That diversity is important in terms of:
- Vessel safety (larger vessels working the offshore grounds)
- Distributing fishing effort across stocks and grounds on a sustainable basis
- Providing the supply chain with continuity of supply, and a wide range of supply (larger vessels can fish in worse weather)
- Supporting port infrastructures (buyers, ice supply etc. depend on continuity of landings to provide critical mass)in
- Supplying very high quality niche markets (small-scale fleets are well adapted to serve this part of the market)
In fact there is often an interdependence between fleet segments. This was seen most clearly when the large beam trawlers left the port of Lowestoft in the 1990s; there followed a drastic reduction in the local small boat fleet. Without the larger vessels providing continuity of supply, fish-buyers and port infrastructures could not be sustained. A healthy diversity is therefore one of the best ways of ensuring that a port, region or whole fishing industry has resilience. Removing that diversity would be to undermine an important balance. Greenpeace’s attempt to exploit artificial divisions within the fishing industry such as the entirely artificial administrative dividing line at 10 metres is as unhelpful as it is contemptible. But if taken seriously and larger vessels were removed from the fleet, the result would be:
- Uncaught UK quota
- The failure of important UK fishing ports
- The failure of those small-scale fleets which are currently dependent on supply chains and port infrastructures sustained by the continuity of supply provided by larger vessels.
A big vessel
To make its case for redistribution of quota the Greenpeace report spotlights a large Dutch owned UK registered freezer trawler. The case study is a wonderful case of misinformation and comparing apples with oranges. It is difficult to see how the vessel’s entitlements for mackerel, northern blue whiting, and horse mackerel have any bearing whatsoever on under 10m fisheries. This is a red herring, presumably included in the report because the vessel is large (pelagic vessels generally are) and because the ultimate owners are Dutch. It is important that non-UK vessels on the UK fishing register contribute appropriately to ensure that the economic benefits associated with quota accrue to the UK. What Greenpeace chose not to highlight was that despite Dutch ownership the vessel has a crew of 63 fishermen, all of them domiciled in the UK and the vessel is managed by an English company, with offices in England and paying UK taxes. It also chooses not to draw attention to the EU rules which prevent discrimination on the grounds of nationality in the allocation of quota or fishing licences.
The system of Fixed Quota Allocations in the UK evolved in a pragmatic, largely unplanned way, in response to various pressures and opportunities. On the whole, it is one of the most advanced quota management arrangements in Europe, with a high degree of decentralisation and flexibility. The transition to the current arrangements certainly played an important role in ending the blight of over-quota landings prevalent in the 1990s. It is not perfect, few things are. But it is very far from being the perfidious, property heist that Greenpeace would want us to believe. The allocation of quota will always be controversial, whether between member states, devolved administrations, fleet segments and vessels within groups because to a large degree it determines share of income. Fisheries managers have a responsibility to allocate quota in a way that is perceived to be broadly equitable but also in a way which is consistent with broader management objectives, such as sustainability. Historical track record has been widely used because it provides a claim based on use. In the UK, the allocations system evolved into one in which this underlying approach has been supplemented by decentralised management, quota trading, as well as allocations based on environmental criteria (for example the Catch Quota system). The new CFP reaffirms member states’ authority to allocate on any basis that they deem fit but requires that the criteria employed, economic, social, environmental etc. are explicit. Member states continue to face decisions on the degree of support for artisanal fishing one hand and providing security of tenure as a basis for investment and sustainability. Generally speaking, the extremes of this debate (unconstrained market forces vs social engineering) are not very helpful in finding a fair and proportionate balance. Neither is the quality of the debate helped by wild and unsustainable assertions. Greenpeace, for example, states that UK “quota is often held and controlled by non-fishermen.” In fact the UK quota register suggests that the percentage of UK quota held by non-fishermen is very small, about 4.5%. The future of quota management in the UK, will we hope, be based on a sober analysis of options, weighing the benefits of what we have in relation to the advantages and disadvantages of change in a particular direction. We will probably not be able to avoid the more voluble contributions of Greenpeace but we can at least see them for what they are. Poorly thought through, somewhat naïve, somewhat disingenuous, somewhat manipulative and certainly divisive interventions which don’t really help, least of all small-scale inshore fishermen.
An exclusive 12 Mile Limit?
Greenpeace argues that the historical rights of some other member states’ fleets to fish between the 6 and 12 mile limits should be extinguished. There is no doubt that removing competition from other member state fleets would be a very popular move amongst inshore fishermen, including many NFFO members, not least in the Thames estuary and Bristol Channel. However, any honest assessment of the pros and cons would reveal the major obstacles to achieving this objective, which Greenpeace choose not to discuss, despite their centrality to the issue. Greenpeace must recognise this, which makes this part of their report little more than opportunistic posturing; either that or they anticipate the UK leaving the EU. The CFP reform having been settled last year, politically, there is no realistic prospect of changing the historic access rights before the next CFP reform within the next 10 years. Even then, there is the question of whether this item can climb to the top of the UK’s CFP priorities. Furthermore, the Government would face a price for other member states to agree. It is obvious that other member states will not voluntarily surrender an established right enshrined in the basic CFP regulation, which they benefit from, unless they can be persuaded that they want something else more. During the last two CFP reforms the status quo on historical rights has not been challenged, in fact it has not been raised. Any discussion that has taken place has been in relation to whether the existing derogations from equal access which gives member states exclusive control out to 6 miles should be retained. Sometimes it is better to let sleeping dogs lie.
It is easy to see the populist appeal of demanding the expulsion of all foreign vessels from UK territorial waters but it's not going to happen any time soon.
In this sense, this part of the Greenpeace report is just dishonest. By raising expectations that non-UK vessels can easily be stripped of their historical rights, is a cruel hoax; cheap words with nothing to back them up.
Greenpeace in this report concedes, perhaps somewhat reluctantly, that progress is being made to put our fisheries on a sustainable footing. The weight of evidence is now simply too heavy for them to come to any other conclusion. Greenpeace remains committed however, to a divisive narrative which splits fishing vessels into two categories: small (good) and big (bad). This is not supported by the evidence which suggests that our fleets are in fact a continuum of vessel sizes, methods and target species, exploiting both inshore, offshore and indeed, distant waters; in any event, it is not the scale of the vessels in a fishery which matters in terms of sustainability but how the fishery is managed. To support its divisive narrative, Greenpeace uses misleading and spurious statistics to suggest a massive imbalance in quota allocation; and to suggest an injustice of historic proportions that leaves the small-scale fishers of this country starved of quota. In fact, with the exception of Channel cod where the problem is the UK’s low national quota share, quota shortage in the under-10m sector is regionally specific, and varies by species, and from year to year. The NFFO has advanced positive suggestions on how these quota pinch-points could be addressed in real time. The Greenpeace report concludes that a transfer of quota from the offshore fleet to the inshore fleet would not only rectify an historic injustice but it would lay the foundations for a different kind of fishing industry in the UK – a cottage industry. The reality is that such a policy approach, if pursued, would be disastrous for the very people that Greenpeace purports to support. Pursuing the Greenpeace solution would draw in additional vessels into the inshore fisheries for quota species. Many of the inshore fishing grounds are already saturated with gear and the existing small-scale fishermen could only be worse off under these circumstances. Maintaining the diversity of our fleets is the best guarantee of a resilient UK fleet and sustainable fisheries for the future.