Written evidence submitted by Greenpeace UK (FSH0226)

The UK’s inshore waters are some of the most productive and species rich in Europe. But decades of overfishing - the result of an excessively powerful European fishing fleet[1] and an unfair and poorly run quota system - has left the fishing communities that depend upon them at breaking point, with employment in the industry falling almost constantly in the UK since records began in 1938.[2] The perception that the EU Common Fisheries Policy (CFP) was responsible for this decline drove the pro-Brexit vote in fishing communities.[3] As the UK leaves the EU, it is therefore incumbent on the Government to reshape fisheries policy to tackle the problems at the root of this decline that have been neglected to date.  

After Brexit, UK fisheries policy must deliver on three fronts. First, the Government must directly address the expectations of UK fishing communities that Brexit will deliver an increased share of the catch in UK waters. Second, the Government must satisfy EU and other partner countries on the terms of access to UK waters and avoid harmful countermeasures that could result from acrimonious negotiations. Third, the Government must restore and conserve fish stocks and the wider marine environment in a way that delivers jobs, revenue and all the tangible and intangible benefits of thriving seas.

This is a huge challenge, but one that can be delivered through a twin commitment to social and environmental sustainability. Though Brexit presents risks to UK fishing and the fishing industry, it is also a historic juncture that provides policymakers with an opportunity to rethink fisheries policy in a way that delivers a win-win for fishers and the marine environment. This should be structured around the recognition that fish and the marine environment are public goods that should be managed in the public interest.  

What are the key issues the Government should address within their White Paper on UK fisheries?

Issue 1: The inequitable distribution of quota driving environmental degradation and economic hardship of fishing communities.

The problem: Although it is established in law that fish are a public resource,[4] the UK fishery and marine environment is not effectively managed as public good, with quota concentrated in too few hands and largely managed by producer organisations which lack transparency.[5] Whereas the majority of UK fishing boats (79%) are small-scale,[6] making 'a significant economic as well as social contribution to the lives of individuals and coastal communities,’[7] the small scale fleet holds only 6% of UK quota.[8] The remaining 94% is held by larger scale interests that include non-fishermen and commodity traders. A 2016 Greenpeace investigation found that just three multi-million pound companies hold almost two thirds of all English fishing quota, while half is held by companies based overseas.[9] Lack of access to quota and/or the high cost of renting quota harm local fishing economies and can drive more unsustainable inshore fishing practices.[10]

The opportunity: The UK Government should redistribute quota in such a way that local fishermen using more selective gear and providing local jobs are prioritised. This would help meet the expectations of local fishing communities whose primary concern remains focused on the historic inequality in access to quota.[11] Redistribution would be consistent with EU policy under the CFP which requires governments to include transparent and objective environmental, social and economic criteria in quota allocation (CFP Article 17) and so avoid a retaliatory response on market-access.[12] Redistribution would also deliver environmental benefits, as local fishers would have less need to resort to harmful practices to make ends meet.[13]

In particular, the UK should provide priority access within the 12nm zone to low-impact fishers and vessels providing economic and social benefit to UK fishing communities. This would be consistent with the spirit of EU policy (expressed in CFP Article 5[14]) while avoiding loopholes that make genuine protection of fish stocks and the wider marine environment unworkable across the fleet.   

As an inalienable public resource, fisheries are ultimately owned by the Government, which must protect and maintain these resources for the public's use. However, sustainable resource management is most effective where governance systems are participatory, transparent and democratic, with decision making devolved to the communities with a long term stake in the resource. Granting bodies like the Coastal Producer Organisation the authority to manage the non-sector pool could be a good first step towards this.

Issue 2: The overfishing of UK waters at huge environmental and economic cost

The problem: The EU has consistently set fishing quotas at unsustainable levels,[15] with 41% of assessed fish stock in the Atlantic and surrounding seas currently overfished.[16] Further, the EU fleet has been a major driver of overfishing with reduced vessel numbers offset by increasing technical efficiency.[17] Declining fish stocks have in turn led to decreasing annual catches, with fewer jobs and less revenue for the majority of the fleet. The subsequent shift towards more powerful vessels has been coupled with a lack of selectivity, leading to a massive discarding problem.

The opportunity: Overfishing is entirely solvable, and a recovered stock would provide society with increased food, jobs and revenue alongside environmental benefits. The UK Government should set quotas in accordance with best scientific advice that reflects stock status in fishing grounds, and introduce a legal requirement to fish below a level that allows fish stocks to fully recover. To avoid unwanted catches, the Government should ensure that in parallel with the implementation of a landings obligation, the use of more selective gear is incentivised through increased access to quota. After Brexit, and in line with the requirements of the UN Convention on the Law of the Sea,[18] the UK and the EU should work constructively to manage shared stocks in a sustainable manner according to best available science.  

Issue 3: The protection of the marine environment

The problem:  There are already important obligations under national, European and international law that have been established to protect our marine environment, species and habitats. However, it has been difficult to apply these conservation measures to areas impacted by fishing. To date the tension between these conflicting needs has been too great, leading to confrontation rather than co-operation. Generally, marine protection has played second fiddle to marine extraction.

The opportunity:  The Government should build on existing obligations to ensure that marine management is science-based and follows an ecosystem approach to fisheries. This involves identifying and protecting important fish habitats to ensure the protection of large concentrations of juvenile fish and spawning grounds, and working towards establishing an ecologically coherent network of marine protected areas.  

However, Greenpeace believes that in the hard fought battle to protect our marine environment, it is essential that we don’t penalise low impact fishing that involves selective and sensitive methods. Instead, we must work to prioritise these fishermen and maximise socio-economic benefit, engaging affected communities in the designation and management of protected areas. There are already emerging examples of this more inclusive and comprehensive approach including in Lyme Bay, where spatial management protects both vulnerable habitats and local inshore fishermen,[19]  and in Wales, where a new approach to the co-management of marine conservation zones works for fishermen and the marine environment.[20]

27 November 2017