The NFFO comments on where we are after the EU and UK have agreed arrangements for the 21 month…
Ten Point Plan for CFP Reform
As the European Commission prepares its proposals for CFP reform, the NFFO has published its 10 point plan for a new CFP.
- Don’t throw the baby out with the bathwater. The CFP is dysfunctional, over-complex, over-centralised, rigid and unresponsive. But there are features of the current arrangements that serve a purpose and should not be thoughtlessly abandoned. Amongst these is the principle of relative stability which provides a stable and predictable means of dealing with the realities of shared stocks; and the exclusive and preferential protection provided for inshore fleets by the six and twelve mile limits. The arrangements for in-year swaps and transfers of quota between member states could certainly be made more flexible without undermining the national quota shares that are the foundation of stability in the member states.
- Decentralise: Many of the CFP’s failures arise from the fact that it seeks to manage many diverse fisheries, in widely varying conditions, across 40 degrees of latitude, through a top-down, command and control approach. The central element in the reform must therefore be a transfer of decision-making responsibilities from the centre to the regional sea basins, to member states and to the fishing industry itself.
- Regionalise: the first move to a decentralised CFP should be to transfer as many responsibilities as possible to the regional sea basin level, (such as North Sea, Irish Sea and Celtic Sea) where fisheries managers from the member states and fisheries stakeholders, working with fisheries scientists, can tailor measures that are appropriate for their own fisheries. It is essential to move away from the one-size-fits all approach. It is only through radical decentralisation, including regional management, that fishing will escape the paralysis of micromanagement that is the inescapable consequence unless all but strategic decisions are devolved from the European institutions – the Commission, the Council of Ministers and the European Parliament. These bodies should set principles, standards and strategic direction. They should not be involved in day-to-day fisheries management or technical issues.
- Encourage rational quota arrangements in the member states: These should provide maximum stability and certainty and prioritise long-term planning. Effective forms of rights based management in the member states have evolved over the last 20 years, including some in the UK. These should be built on and extended to cover all fleets, irrespective of vessel size, but with appropriate safeguards against erosion of the small scale fleet’s fishing opportunities. It is important however to avoid a single, pan-European system of rights based management which would replicate all the problems of an unwieldy top-down system.
- Reboot the Science: many fish stock assessments are weak or flawed, mainly because the data on which they are based is missing, or inadequate, or the models used are too sophisticated for the data available. A reformed CFP will build on the initiatives already begun within the regional advisory councils working with fisheries scientists in ICES, and through fisheries science partnerships, to break free from the cycle of decline in which we have been trapped in for two decades.
- Adopt Long Term Management Plans: Breaking with crisis management and knee jerk responses that have dominated European fisheries for 20 years will require a move to management through comprehensive, long term management plans that have been developed collaboratively with the involvement of those in the fisheries that they affect.
- Abandon Effort Control: Restrictions on time at sea creates pressures that increase the intensity of fishing activity during the period that the vessels are allowed to go to sea. This is counter-productive and leads to perverse consequences such as capital stuffing and high grading. Effort control is complex to apply costly for the industry and there is very weak evidence that it either reduces fishing mortality or discards; in some circumstances it can lead to an increase in both
- Minimise Discards: Much has been achieved (discards in England are 50% lower than a decade ago) but there is much still to do. Initiatives such as the 50% Project and Catch Quotas show what can be achieved through a fishery by fishery approach based on engaging the support and involvement of the vessel operators and getting the incentive structures right.
- From Prescriptive Micro-management to Delegated Responsibility: Much could be achieved in simplifying the CFP by moving from the current system of management based on prescriptive legislation to approved and audited sustainable fishing plans through which the fishing organisations could be largely self-regulating within a framework of guarantees and safeguards. In effect this is reversing the burden of proof but it would for the first time put the fishing organisations in the driving seat with responsibility for their members’ destiny
- Adapt: The only constants in fisheries are change and uncertainty. It is vital that fishing deals effectively with changing environmental conditions, as well as changing public expectations about fishing. Our industry must be resilient to shocks from outside and to achieve that it is vital that the management system provides the flexibility to respond adapt and change.
Our current understanding is that the Commission’s reform proposals will be announced in late May or early June, although some slippage is always a possibility. The package will comprise:
- A Communication on CFP reform that will indicate the broad policy direction and the linkages between the different part of the reform package
- A new CFP Basic Regulation that will probably not differ in form much from the current basic regulation but will contain the main legal elements of the reform
- A Communication on European fisheries in External Waters
- Proposals for a new Regulation on the Common Organisation of the Market in European fisheries products
- A Communication on a new EU Financial Instrument for Fisheries, which will replace the current European Fisheries Fund