Cornwall Inshore Fisheries and Conservation Authority
St Clare Offices
St Clare Street
Penzance
Cornwall, TR18 3QW
Tel: (01736) 336842
Fax: (01736) 336661
www.cornwall-ifca.gov.uk
By email to cfp@defra.gsi.gov.uk
Frances Kirwan
CFP Reform
Defra
17 Smith Square
London
SW1P 3JR
25 October 2011
Dear Frances
Proposals Relating to the Common Fisheries Policy and the Common Organisation
of the Markets in Fishery and Aquaculture Products
Thank you for the invitation to respond to the proposals relating to the Common
Fisheries Policy and the common organisation of the markets in fishery and
aquaculture products, in your letter dated 10 August 2011.
The Committee of the Cornwall Inshore Fisheries and Conservation Authority
(CIFCA) agreed the following response at its meeting on 14th October 2011. The
response is made from the perspective of the fisheries inside the CIFCA’s six mile
District around the county of Cornwall. These fisheries are prosecuted in the main
by small local vessels under 12 metres that are based in about 50 commercially
active ports and harbours around our coast. Some of these ports and harbours
are very small, hosting just one or two vessels i.e. Port Quin, whilst Newlyn has
around 150 vessels regularly berthed (CSFC figures from port audit 2009).
Significant numbers of visiting craft from other parts of the UK often base
themselves in Cornwall for the summer months.
The Authority welcomes the recognition by the Commission that the current CFP
has deep inherent shortcomings. It is of the opinion that the current review has to
firmly address those clearly identified problems if a sustainable, profitable and low
environmental impact fishing industry is to become a reality throughout the
waters of the EU.
Continued page 2 …
… page 2 …
Turning to Defra’s questions the responses for questions relevant to this authority
are as follows.
Q1
Are the aims of the CFP set out clearly and appropriately in these proposals,
with the right balance between environmental, social and economic
objectives?
The aims of the CFP are set out clearly in the proposals and the balance
between environmental, social and economic objectives are relatively
sensible. However, the Authority notes that the Commission continues to
insist that the fleet is too large for the available resources. Although we are
not in a position to comment on the wider EU fleet numbers, Members note
that the indigenous inshore UK fleet has reduced significantly over the last
decade or so, to the point that some small ports are a shadow of their
former selves. It was hoped that the emphasis on reducing discards would
bring renewed thinking on this issue, as theoretically, more fish will be able
to survive for another day and therefore the stocks levels will benefit as a
result.
Q2
What are your views on the proposed content of multi-annual plans and the
process to deliver management measures under these plans?
No comments.
Q3
Have the proposals got it right on ending fish discards? If not, what changes
would you suggest?
There is general support to end discards. However, the proposals need to
be thought through fully, otherwise there will be a significant likelihood that
some smaller vessels will inadvertently contravene the principle due to them
landing in very small ports with no facilities for unsaleable fish. That even
assumes they will have capacity aboard their smaller vessels to store all the
fish that is caught so that it can be taken to a port.
Technical measures must be the preferred method of reducing discards,
through increased mesh sizes, restricted lengths of fixed gear/numbers of
pots, closed seasons, curfews etc. Fishermen also need to be helped and
encouraged to change to less impactive methods of fishing where that is at
all feasible and viable.
Increased minimum sizes for crustaceans are a particularly valuable
technical method for increasing stocks, as evidenced by the improved
situation in the Cornwall inshore zone over the last decade. Of course,
discards per se in the shellfish fishery is not an issue as all undersized animals
that are caught are very robust and will survive if returned to the water.
Continued page 3 …
… page 3 …
Q4
Do the proposals give sufficient flexibility to manage fisheries on a regional
basis, with an appropriate voice for stakeholders? If not, what changes
might be necessary?
Members are of the opinion that the importance of small-scale and coastal
fisheries needs to be fully recognised through a differentiated management
regime. Inshore fisheries in our view should be managed as small logical
units, or cells, around Europe’s coasts for the benefit of the marine
environment and all the stakeholders including commercial, recreational
and the general public.
The inshore commercial sector consists mainly of diverse micro-businesses
which are not represented very well by the Fish Producers Organisations
(FPO) or fishermen’s associations. This sector needs to be encouraged or
required to join such groups, otherwise its feeble voice will be drowned out
by the voices of the larger vessel operators who are much better organised.
The interests of the two sectors (inshore and offshore) are not always the
same and so there is a great danger that the smaller vessels will continue to
be under represented in national and international discussions unless there
is a concerted effort to address the situation.
Q5
What are your views on the proposal to introduce “transferable fishing
concessions” for vessels over 12m and those which used towed gear? Are
the provisions for Member States to decide on allocations and set
safeguards on trading appropriate/sufficient?
The Authority holds some concerns that the transferable fishing concessions
will ultimately create an relatively small, but highly efficient EU fleet that is
owned by just a few large companies. This is the experience of other
countries where this principle has been applied i.e. New Zealand, and
despite there being a political will to set safeguards on trading, where
quotas of any commodity are in effect made tradeable, the natural
economic realisation is always that the quota will eventually end under the
control of a few interests that have the financial resources to outbid other
interested parties. The fact that the EU fleet is riddled with “flag” vessels
despite various MS national measures being introduced to resist them,
demonstrates the reality.
Of particular concern is the exclusion of the under 12m trawlers from the
proposed exemption from the transferable fishing concessions. The inshore
trawlers have reduced significantly in our locale over the last two decades
and if that part of the sector is not exempted from the proposals, then it will
become all but extinct very quickly.
Continued page 4 …
… page 4 …
Q6
Are the proposals to help develop the aquaculture industry necessary, and
the steps suggested helpful?
The proposals for aquaculture are welcomed. Shellfish cultivation in
Cornwall is small but the product is of high quality. New investment has
been made over the last two or three years, and there is capacity to
extend aquaculture more in the county as identified in a South-West Pesca
report and other studies over the last decade or so. Future development
must be sympathetic with the local marine environment and with the
activities of other stakeholders. Nevertheless, unless a national strategic
aquaculture plan is fully developed and accepted by the industry and
government, significant investment to realise the potential is unlikely to
happen. Water quality issues are frequently the Achilles heel for the
aquaculture sector, despite huge investment by water utilities.
Q7
Do these proposals go far enough to ensure the sustainability of EU fishing
activity in external, non-EU waters? If not, what other measures are
necessary?
No comment as it is outside our remit and area of direct interest.
Q8
Do you think that quota management and marketing responsibilities for
producer organisations should be brought out and strengthened in the
legislation?
No comment as it is outside our remit and area of direct interest.
Q9
Are the proposals consistent with current, wider consumer information and
labelling requirements? (If not, how should they be made consistent or will
they place additional burdens on the industry).
No comment as it is outside our remit and area of direct interest.
Q10
Should additional voluntary information be included in the proposals?
No comment as it is outside our remit and area of direct interest.
Q11
Do you think that intervention mechanisms should continue to be part of the
new marketing regulation? (If so what form should this be in e.g. temporary
or permanent)
No comment as it is outside our remit and area of direct interest.
Continued page 5 …
… page 5 …
Q12
Will these proposals place additional burdens and costs on stakeholders? If
so can you provide an estimate of what those additional costs could be?
It is felt that the proposals will likely place some additional burden and costs
on stakeholders. It is not possible though for us to comment on what these
are likely to be and it is considered that the onus is on those that are most
likely to be impacted, to feed in what they estimate the burdens and costs
to be.
Yours sincerely
Edwin Derriman
Chief Officer