NFFO South East Committee Response to the Defra Consultation Paper “The English Inshore Fleet – Looking to the Future”

15th September 2008 in Inshore, South East

The NFFO South East Committee represents fishermen from the ports of Folkestone, Rye, Hastings, Normans Bay, Eastbourne, Newhaven and Selsey, many of whom operate vessels under 10 metres in length.

NFFO South East Committee Response to the Defra Consultation Paper “The English Inshore Fleet – Looking to the Future”

The Committee welcomes the consultation paper as an indication that after many years of neglect, the Government is now committed to dealing with the problems facing the under 10 metre fleet. We have serious concerns however that the approach chosen will not be effective in achieving a balance between the capacity in the under 10metre fleet and available quotas. We consider that viable alternatives are available.

Decommissioning
We consider that the sum of £5 million allocated to provide a targeted decommissioning scheme is inadequate to deal with the legacy of compounded problems in the under-10 metre fleet. As many of those problems stem directly from deficiencies in previous government policy towards the under 10 metre fleet, we consider that Government does have a responsibility to allocate resources on a scale that would offer some prospect of solving some of the central problems facing this segment of the fleet.

Taking this central point into account, we agree that:

  • a decommissioning scheme could contribute to rebalancing capacity and quota in the under-10 metre fleet
  • any decommissioning scheme should be targeted at vessels that fish for stocks that are under particular pressure. In our case Area VII b-k cod is of critical importance.

However, we consider that:

  • Despite its intentions, the decommissioning scheme, as proposed, will not remove higher catching vessels from the fleet on a scale that will release significant quota to the pool. This is because a) the overall sum allocated for decommissioning is inadequate and b) because the £1000 per VCU ceiling will act as a disincentive to owners of vessels in this category that might otherwise have applied.
  • Decommissioning should not, in our view be restricted to higher catching vessels because almost all active vessels catch up to their quota limits on the sensitive stocks. Removing a large under 10 metre vessel or a small under 10 metre vessel, will be broadly equivalent in terms of the additional quota released to the pool through uncaught quota. For this reason we consider the eligibility criterion of a capacity of more than 50 VCUs is misguided.

Latent Capacity
We accept that there is a large amount of latent capacity in the under-10 metre fleet. We also accept that government action is required to prevent latent capacity attached to under-10metre licences from becoming active and fishing against the pool thereby exacerbating the difficulties of maintaining a 12 month fishery.

However we do not accept that the approach outlined in the consultation paper, centred on dividing the under-10 metre fleet into two categories, full quota and limited quota licences, is fair or will achieve its objective. In particular, we are concerned thata considerable range of active under-10 metre fishermen who targeted non-quota species in the reference period will be seriously disadvantaged. Economic survival in the under-10 metre fleet has customarily required flexibility in target species and fishing gear, and frequent adaptation to changing stock and market circumstances. If the policy is adopted as proposed, fishermen who during the (short) reference period happened to target bass, crab, lobster, whelks, scallops or oysters rather than quota species, will be trapped in a licence category that restricts fishing of quota species to a “hobby”level. The impact of this policy, if implemented, would therefore be arbitrary and capricious and reflect often temporary decisions as to the choice of target species. The impact would be very far from that suggested by the Impact Assessment. These are full time commercial fishermen whose interests would be permanently harmed if assigned to the limited quota licence category. In short, the definition of a “latent licence” is inadequate and freezing the fleet in a snapshot of time will lead to real hardship and real injustice.

Discards
Neither consultation paper or impact assessment discusses the increase in discards that will accompany the approach as proposed. Fishermen targeting non-quota species such as bass will inevitably have a by-catch of quota species. If vessels in this category are limited to 300Kgs of all quota species annually but continue to fish intensively on non-quota species, any quantities above this amount will have to be discarded. During a period in which the European Commission has prioritised the reduction of discards on a fishery by fishery basis this must be of concern.

An Alternative Approach
We accept in principle that there are active and inactive licences in the under-10 metre fleet and that dealing with latent capacity is an integral part of the solution to the problems confronting the under 10 metre fleet. We are surprised that a licence buy-back programme appears not to have been considered as part of the Government’s deliberations on how to put the under 10 metre fleet on a sustainable, profitable and legal footing. Licence buy-backs have been successfully implemented in various fisheries world-wide, including South Africa, Australia, Canada and the United States. The advantages of a licence buy-back would be:

  • Active and inactive licences could be withdrawn, permanently reducing the active and latent capacity in the under 10 metre fleet
  • A fixed price or bid system could be used
  • The scheme would be voluntary and would avoid the creation of further arbitrary bureaucratic lines through the fishing fleet
  • Future problems of policing a two-tier under-10 metre licensing scheme could be avoided
  • The rough justice associated with the creation of a two-tier system and associated cumbersome appeals system would be avoided.
  • This arrangement would not lead to an increase in discards

Clearly, there will be public expenditure implications associated with such an approach but it seems to us that resolving the issue of capacity imbalance and latent effort in a way that would bring permanent benefits to the under 10 metre fleet would provide value for money, provide necessary safeguards are put in place.

Leasing

We support the arrangements that allow under-10 metre vessels the opportunity to lease quota and think that this should be continued indefinitely. We do not think that it is reasonable to disallow such vessels that can take advantage of this arrangement, from fishing against the pool for the remainder of the year.