Written evidence submitted by the Scottish Fishermen’s Federation (FS0040)

September 2022

Background to SFF

1. The Scottish Fishermen’s Federation (SFF) is a democratically constituted industry group set up in 1973 and its key aims are:

• Promoting and protecting the collective interests of the Scottish Fishermen’s Federation Constituent Associations.
• Supporting production of healthy and sustainable wild-caught seafood, ensuring a sustainable future for the industry and our marine environment.
• Advancing the reputation of fishing by championing responsible practice in meeting a growing demand for healthy, climate-smart food.
• Improving fishing safety through supporting and promoting professional standards of training and compliance with safety standards.
• Showing fishing as a positive career choice – one with a viable and positive future.

2. SFF isa comprised of eight Constituent Associations, with around 450 vessels within their membership, representing a wide range of fishing businesses, both inshore and offshore and catching a wide range of fish and shellfish species across demersal, pelagic and shellfish fleets.

3. The value at first landing of the Scottish fishing industry in 2021 was £560 million. Landings by value were 15% higher in 2021 compared to 2020 and 10% higher by tonnage for the same period. Scottish vessels accounted for 61% of value and 67% of landings of all fish caught by UK vessels.

Food Security

4. The fundamental purpose of marine fishing is food production, Commercial fishing produces high quality healthy protein from renewable resources, with a very low carbon footprint. Compared to other forms of food production, commercial fisheries require few external inputs, the main input being the fuel needed to power fishing vessels. There is no requirement for chemicals, fertilisers or water inputs.

5. Fish and shellfish are consumed across the globe, and it is widely acknowledged that seafood has an important role to play in feeding a growing population. It is important therefore not just to think of food security in the context of the UK but to look at the growing global demand for protein, and the inputs and resources needed to provide that.

6. In 2017, fish provided more than 3.3 billion people with 20 percent of their average intake of animal protein. Our global population is projected to rise to 9.8 billion people by 2050 - an extra 2 billion people that will need to eat. Sustainable wild-capture fisheries have a key role to play in ensuring food security for many people worldwide.

7. It was unjustified therefore to see commercial fishing being demonised in the Independent Review for Government[1] to inform the National Food Strategy. SFF was pleased to see that the Government’s Food Strategy[2], to apply to England, and published in June this year take a more balanced tone on fishing. It recognises the importance of fish and shellfish in a healthy diet and feeding a growing population, alongside the statutory framework that applies across the UK through the Fisheries Act for managing fisheries in ways that are environmentally and socio-economically sustainable.

Factors Affecting Resilience of Food Supply Chains

Management, Fishing Effort and Naturally Occurring Impacts

8. With limited exceptions (e.g. shooting of wild game) commercial fishing is unique in terms of modern protein production as it relies on completely wild, natural resources (fish and shellfish) that are not subject to any rearing, cultivation or husbandry by humans. Fisheries management is in place to manage the amounts of fish that can be harvested and the ways by which this is done, but fish and shellfish stocks are also at the mercy of many naturally occurring factors.

9. It is widely recognised that fisheries are impacted by factors over which no actors in the supply chain have any control. These include natural fluctuations in stocks caused by changes in population dynamics – e.g. increased or decreased predation by other species, competition between species for resources (food and habitat), changes in weather patterns and fluctuations in recruitment to a stock. There are examples where in the absence of any fishing pressure, stocks have decreased through naturally occurring factors.

10. For commercial fisheries to be able to contribute to sustainable food security, there should be effective co-designed management based on robust data and well-founded science that informs evidence-based policy making. On a global scale Illegal, Unreported and Unregulated (IUU) fishing remains a major threat to the sustainable management of fish stocks. But in the UK fishing is subject to management and regulations. In Scotland, there is a steadily increasing number of stocks that are fished at sustainable levels, rising from just over 30% in 1991 to almost 70% in 2020[3]. This represents an increase of 3 percentage points from 2019 and 35 percentage points from 2000. The percentage fished sustainably in 2020 is the highest level recorded since this data collection began (1991) and whilst there is more to do, it demonstrates the ongoing recovery of the commercial fish stocks in Scotland. 

Fuel Prices

11. Every business and household in the UK has no doubt felt the impact of increased fuel and energy prices, driven largely by the impact of Russia’s illegal war in Ukraine. Scotland’s fishing fleet, just starting to make its recovery from the Covid pandemic was badly hit earlier this year by the increased price of fuel, one of the industry’s biggest input costs.

12. Whilst fuel prices have dropped from the highs seen following Russia’s invasion of Ukraine, they remain higher than pre-invasion. Price increases varied in different parts of Scotland, and those sectors of the fleet that are more heavily reliant on fuel are most vulnerable to fuel price increases. Analysis by Seafish[4] showed that fleet profitability would be affected by fuel price increases, and in the worst case scenario that overall operating profit would be negative for the UK fleet (excluding pelagic). Some parts of the fleet are particularly vulnerable to fuel price rises (e.g. nephrops trawlers, scallopers and beam trawlers). In summary, fishing businesses are very exposed to increased fuel prices, making fuel prices a significant factor impacting on the sector’s resilience.

Labour Supply

13. Again, parts of the Scottish fishing fleet are not unique in suffering from problems with labour supply, but commercial fishing is specialised and skilled, and faces particular challenges. Over time, parts of the fleet have become increasingly reliant on crewmen originating from outside of the UK. There are a number of reasons for this, but it is a practical reality, and is likely to remain so for those fleets.

14. The UK’s new immigration system is not working effectively for these businesses, meaning that some businesses are wasting considerable time and money trying to make the Skilled Worker route work, but finding that barriers such as an overly-demanding written English language test are preventing them from recruiting the crew needed to run their vessels effectively and safely.

15. Industry has spent considerable time developing ideas and suggestions, practical and legal solutions, but has found it very hard to engage with the relevant parts of the government. Labour shortages in these fleets is certainly impacting on their resilience to produce healthy, nutritious and affordable food.

Spatial Squeeze in our Crowded Seas

16. Whilst factors such as fuel prices and labour issues are currently at the immediate forefront of concerns for many fishing businesses, there is a major issue in the medium to longer term that greatly threatens the industry’s ability to produce food and contribute to food security: the ‘spatial squeeze’ on our fisheries. Our industry operates in increasingly crowded seas, where there is a multitude of other activities and policies that are increasingly encroaching on our ability to fish. These include the rapid expansion of offshore wind farms, the designation of vast areas of our seas as Highly Protected Marine Areas (at least 10% of Scotland’s seas are to be designated as such by 2026).

17. SFF along with NFFO, our counterpart body in England and Wales, commissioned a report on the current and future spatial pressures facing out industry[5]. The report, produced by authoritative and highly regarded expert consultants made for sobering reading – by 2050 in the worst-case scenario, trawling could be excluded from more than 50% of Scotland’s seas through a combination of legal prohibitions (e.g. HPMAs) and the practical effect of other activities in the sea being completely incompatible with fishing (e.g., floating offshore windfarms). Clearly we need energy security for the future, but we also need food security. Our industry, producing low carbon, healthy and sustainable protein must not be sacrificed to allow the expansion of another.

18. It was particularly telling that industry had to commission this work itself, as neither government north or south of the border has yet made any attempt to assess the cumulative impact of spatial pressures at sea on our industry. There is much in this report that SFF would be very keen to discuss with the Committee in more detail.

Consequences

19. There are voices that oppose commercial fishing and would like to see it constrained and limited further. That much was evident from the Independent Review for Government[6] to inform the National Food Strategy mentioned above.

20. Similarly the factors outlined above – high fuel costs and lack of labour in the short term, coupled with spatial pressures in the years ahead could very seriously affect the supply chain’s ability to produce food. All of these would have consequences for consumers both here in the UK and overseas who eat Scottish seafood, and would likely push consumers towards other sources of protein with much higher carbon emissions and a much greater demand for inputs such as fertilisers, feed and energy.

21. Commercial wild capture fisheries of well managed fish and shellfish stocks have tremendous potential to help feed a growing population both at home and abroad with increasing demands for protein. Fishing businesses need a supportive and enabling regulatory landscape to help the fleet function efficiently, sustainably and safely. With this, we can continue to bring healthy and low carbon food to consumers from natural, renewable resources.

22. SFF would be very happy to explore any of these issues further with the Committee, and we hope that this submission is helpful in your deliberations.

Scottish Fishermen’s Federation

September 2022