The NFFO comments on where we are after the EU and UK have agreed arrangements for the 21 month…
Under-10s: Taking Stock
Now that the shape of the reformed CFP is known in broad terms, and the UKAFPO legal challenge to the Government’s proposed redistribution of underutilised quota is out of the way, this seems like a good time to take stock of where we have got to on the important under-10m quota issue.
The debate on the future of under-10m quota management has taken many twists and turns. However, most informed observers would agree that a number of important points have surfaced from the sometimes heated and confused exchanges over recent years.
- The quota problems facing parts of the under-10m fleet are not general but are focused on specific stocks and areas and times of year. The quota pinch-points for the under-10 fleet may vary within each year and between years. They are at their most acute in the south east where the opportunities to catch non-quota species are most sparse.
- The underlying problem in the Eastern Channel cod fishery - a major focus of the under-10m spotlight - is not caused by and cannot therefore be solved by tinkering with domestic quota shares. It is the international share out in which the UK receives only 7% of the EU allocation that is the root problem here. This requires a significantly different approach by comparison with other stocks. If any headway is to be made, the main focus in this fishery should be on international quota swaps and transfers.
- Around 70% of the under-10m pool quotas are caught by only 14% of the under-10m fleet – around 129 vessels
- The evolution of the under-10m fleet over the last 20 years, and in particular the emergence of a fleet of high-catching under-10s (often sheltering from the punitive management regime for over-10m vessels), is now much more widely understood. This class of vessel tends to be exclusively, or predominantly dependent on quota species and above all requires stability in its quota allocations. For this it requires to be able to plan its quota year, in much the same way as many over-10m vessels.
- The bulk of the rest under-10m fleet, however, require quota flexibility to be able alter target species and to adapt to constantly changing local abundance and market conditions. Many of these vessels need access to quota stocks only irregularly, whilst their main focus is non-quota stocks. The pool system, with monthly or bi-monthly catch limits, is well adapted to this requirement.
- The success of producer organisations in managing their members' quotas by maximising access to quota that is needed, by swapping and transferring its unutilised assets, has been recognised as a crucial feature beneficial to their members. This kind of regular ongoing intervention has largely been denied to the under-10m fleet, which have been managed centrally; although regional quota management meetings organised by the MMO have improved sensitivity recently.
- The interdependence of large-scale and small-scale fleets in terms of maintaining port infrastructures and continuity of supply is now recognised as essential for the well-being of the small-scale fleets. The lessons learnt when the larger vessels left Lowestoft and local infrastructures collapsed are well understood.
- The recent Judicial Review has confirmed that the Fisheries Minister has wide discretionary powers to change the quota management arrangements in England and to redistribute unutilised quota. It also confirmed that under European law Fixed Quota allocations are to be regarded as a "possessions" and not to be expropriated without compensation. In a sense, little has changed because ministerial discretion to change quota allocations through top-slicing has been used, not infrequently, in the recent past. The wisdom and equity of administrative redistribution is likely to remain a contentious area, even more so in relation to TAC uplifts associated with the forthcoming landings obligation for quota species.
- There is a broad recognition that the large number of unutilised under-10m licences represents a reservoir of latent fishing effort and that latent capacity has the potential to undermine and disrupt any initiative to manage under-10m quota allocations and prevent increase fishing pressure within the inshore zone to unsustainable levels. Discussions are ongoing about the best way to tackle this issue.
- The fishing power of an under-10m vessel can be many times greater than its counterpart 20 years ago. As with the fleet of larger vessels, technology has not stood still. Given that smaller vessels by their intrinsic characteristics often have a limited range, the management of fishing pressure within the inshore zone is of paramount importance that also needs to be taken into account when discussing access to quota.
- It remains to be seen what support for small scale fisheries is available under the new European maritime and Fisheries Fund but contrary to some of the wilder interpretations, actually very little in the reformed basic CFP regulation has changed or will have much of an impact on the issue of quota distribution. Member states retain the authority to manage their quotas as they see fit and may use a range of criteria to allocate quota
So, against this background, where do we go from here in addressing the issues confronting the under-10s?
Two contrasting approaches are emerging, both focused on bringing PO type self-management to the under-10m fleet:
The idea of a national inshore producer organisation has been proposed, with the aim of bringing the clear advantages of PO quota management to the under/10 m sector. Questions have already been raised about whether a national scale organisation run by a committee would be too unwieldy by comparison with the regionally focussed producer organisations, given the logistics and geography involved. The question of the actual level of support by under-10m fishermen for a national PO and the long-term funding required are important issues too. It is unlikely to aid matters that the main proponent for a national inshore PO is affiliated to Greenpeace. In recent years a number of grandiose schemes have been proposed, such as allocating FQAs to under-10s, a national pot limitation scheme for shellfish vessels, and further back, even a system of days-at-sea which would have included under/10m vessels. All failed to reach take-off speed. Time will tell. There is certainly nothing intrinsically wrong with a strong, effective, well organised inshore PO, if these hurdles can be overcome.
The alternative approach, favoured by the NFFO, is to start immediately at the local level and where the specific quota pinch points are at their most acute. Encouraging collaborative arrangements between groups of under/10m fishermen and specific POs offers the possibility of extending professional quota management to the high catching under-10s. The Fish Producers Organisation is currently supporting the Ramsgate Quota Pilot in this way and this could provide the model for future collaboration. Other POs offered to provide similar support at a meeting organised by the NFFO in April in London. This is the opposite of a Big Bang approach. It is incremental and based on the buy-in by all parties. But it is focused at where the problems are most severe, and hopefully will provide a model for the way forward.
For many under-10s, whose catch of quota species is comparatively small and sporadic, this approach will not be relevant or of interest but it ought to relieve the quota pressures where they are most severe. The general upward direction of TACs also ought to help.
The essence of the under-10m issue is that the quota shortages facing this part of the fleet do not have a single cause and are not amenable to single simplistic solutions. They require tailored solutions, regionally and by fleet sub-segment. They are more likely to be solved through industry collaboration than Government intervention. In many ways the solutions are in our own hands.