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Sustain Brexit Consultation responses

Sustain response to Labour Party fisheries policy consultation, February 2018

Catch of Atlantic Herring - Credit: NOAA FishWatch

Catch of Atlantic Herring - Credit: NOAA FishWatch

During December 2017 and January 2018, the UK Labour Party consulted on their policies for coastal communities, in particular fishing and the fishing industry.

The Government is due to announce proposals for new fishing policy after the UK has left the EU (likely a Fishing White Paper). We look forward to responding to this policy in due course, and working with all parties to inform their fishing policies.

Labour Party fisheries consultation

Please note: The questions in red are those set in the consultation.

How could fisheries enforcement be improved?

There is a genuine risk of illegal fishing in the UK. We support greater surveillance, particularly using technology to make the most of what can be done remotely (which is more cost effective). Enforcement and building greater scientific understanding should go hand-in-hand. Government should invest in Remote Electronic Monitoring systems to ensure compliance with fisheries management regulations and to improve data, including (but not limited to):

  • As a minimum, fisheries should be fully documented (ie all catches, the location and timing of all fishing activity and gear type recorded).
  • All commercial fishing boats should be fitted with CCTV and GPS trackers, and photo-recognition for catches. The data should be reviewed by the MMO on a risk-assessed basis. This would improve scientific understanding and allow some illegal fishing to be detected  immediately.

Enforcement should be concentrated in areas in which illegal fishing has been detected (such as Scottish Marine Protected Areas), and areas that are particularly vulnerable or fragile, or for which stocks are depleted.

Government should use a range of other methods to encourage and support compliance with fishing regulations:

  • Greater shares of quota for boats complying with technical measures such as installing CCTV, avoiding closed areas, adopting more selective gear etc.
  • Encouraging and supporting fisheries to gain Marine Stewardship Council Certification and to take part in Fishery Improvement Projects - this means that the fishery is independently checked for compliance with best fishing practices. This could be funded through a new fund, replacing the European Maritime and Fisheries Fund.
Our top priorities for any new trade deals the UK establishes after Brexit are:

1. MAINTENANCE OF HIGH ENVIRONMENTAL STANDARDS - the UK should not import fish that isn't verifiably sustainable. The EU currently have a ban on importing fish into the EU that doesn't have the required documentation to prove that it has been caught legally. This should be continued as a minimum. We could make this commitment stronger, to exclude the import of seafood considered 'Fish to Avoid' by the Marine Conservation Society

2. TRANSPARENCY & DEMOCRACY – trade deals and negotiations should be open to public debate, scientific review and parliamentary scrutiny and consent, fully including and respecting the devolved administrations

3. SPECIFIED IN PUBLIC SECTOR CONTRACTS - New international trade deals must not in any way undermine the ability of our public institutions – such as schools, hospitals and the armed forces – to buy well produced, healthy and sustainable food.

4. RESPECTING PRODUCT LABELLING – At the moment, EU regulations require that fish is labelled with the species and country of origin, which helps consumers to check whether it is from a sustainable source. The USA has identified this labelling regulation as a barrier to trade. As part of a trade deal, therefore, the USA may require that it is removed. Doing so would disempower consumers and decrease transparency in the fish supply chain.

Our main hopes for the upcoming Fisheries Bill

We hope that the Fisheries Bill will have sustainable fishing at its heart. The Greener UK briefing document outlines nine key elements that are the cornerstone of sustainable fisheries policy. These must be enshrined in primary legislation.

Please see also the report by the New Economic Foundation, which outlines the great potential benefits for jobs and incomes if all fisheries were managed at Maximum Sustainable Yield: 

A summary of our hopes for the Bill has been published already, but I would like to elaborate on a few points:

The Bill should include a clear and systematic approach to making all UK fisheries achieve market recognition for being verifiably sustainable.

Currently many fisheries don’t have either; a recognised independent certification (for example MSC certification), OR a rating of 1-3 on the Marine Conservation Society’s ‘Fish Online’ traffic-light rating system. This, at the moment, is preventing access to the best markets in the UK and abroad, including:

  • Sustainable fish standards now apply for all central government procurement, Whitehall, prisons and defence spending, the NHS in England and Wales, and are recommended for schools in England and Wales.
  • Seven of the largest contract catering companies in the UK, covering over a third of the sector, now use demonstrably sustainable fish as standard across all their dining services in universities, workplaces, stadia and public-sector food.
  • Brakes - the largest foodservice wholesaler with roughly 20% market share have switched all their own-brand fish products to demonstrably sustainable options.

In our recent report, ‘Fishy Business’ we found that a number of the UK’s large contract caterers are avoiding buying fish from the UK where they cannot be sure that it comes from verifiably sustainable sources. Instead, they import it from oversees where these imported sources meet their sustainability policies. The species for which this was most notable were scallops, seabass, prawns, halibut, turbot, and to some extent salmon and white fish.

We would like to see a systematic and clear plan to make all UK fisheries verifiably sustainable, starting with plugging the data gaps that are currently a problem for many fisheries (see reports from Project Inshore, here:

UK Government as a consumer

The UK Government must ‘put its own house in order’ and support the UK fishing industry by strengthening and enforcing the Government Buying Standards. At present, these standards stipulate sustainable fish, but our research has found that private-sector contractors are only about 50% compliant.

We would like to see these standards properly inspected (OFSTED currently do this for the school food standards), reported on and enforced, and extended to cover school food.

No drop in environmental standards for UK fishing policy

There has been an extraordinary shift in the purchasing policies of retailers and foodservice companies in the last decade or so, thanks in part to high profile campaigns led by Greenpeace, Hugh’s Fish Fight, Sustainable Fish Cities, WWF, and many more. The emergence of credible, third-party ecolabels and certification schemes mean that businesses have a clear route to ensuring that they are buying sustainable fish, and have made strong public commitments accordingly. Currently, the UK has one of the largest number of Marine Stewardship Council certified fisheries of any country in the world. In addition, many UK-caught species are rated ‘Fish to eat’ by the Marine Conservation Society including herring, mackerel, crab, sole, mussels, cockles, saithe, haddock and hake.

Losing the sustainable status of UK fish stocks would greatly restrict fishers’ options in the domestic market and the best markets abroad. In turn, retailers and foodservice companies in the UK would be forced to look abroad to meet their longstanding and public sustainability commitments. UK fish species could lose their status as sustainable if:

  • The management of the stocks shared between the UK and other EU countries is no longer considered effective. This could happen if the UK drops out of the EU quota-setting system and as a result fishing levels exceed scientific advice
  • Fleets use damaging fishing techniques that result in harmful impacts on the marine environment (bycatch, damage to the sea bed etc). A fleet causing a high level of damage would not be categorised as sustainable
  • Investment in data collection, monitoring and enforcement drops. Data gaps and uncertainly in monitoring lower sustainability scores.

Instead, in the context of international trade uncertainty, there would be significant financial benefits if more fleets’ can improve their sustainability. A range of fisheries management scenarios was recently modelled by the New Economics Foundation, in their highly influential ‘Managing EU Fisheries in the public interest’ report. They aimed to determine the impact on jobs and revenue across the EU, including fishers’ wages, if fish stocks were allowed to increase to produce the scientifically-determined Maximum Sustainable Yield (MSY) They found huge opportunities for jobs and revenue, including:

  • 2,052,639 tonnes of additional fish per year, enough to meet the annual demand of 89.2 million EU citizens
  • €1,565 million additional gross revenues per year
  • €824 million additional net profits per year
  • Between 20,362 and 64,092 new jobs
  • €8,273 in additional fishing wages each year.

The UK’s share of these benefits could see coastal communities greatly boosted with good, long-term jobs.

Keep the good bits of the EU Common Fisheries Policy (CFP)

In 2012 citizens, fishers, businesses and politicians in the UK led calls for the development of a new EU Common Fisheries Policy. In fact it was one of the largest citizen-led EU policy changes ever with over 850,000 people asking for a fairer, less wasteful CFP. The revisions aimed to rebuild shared fish stocks by setting catches according to scientific recommendations, make quota allocation fairer, and phase-out the discarding of fish.

The new CFP is still being rolled out, but early indications show that it is already leading to increased stocks, including, notably, North Sea Cod, once considered to be critically endangered and now certified sustainable:

Setting up new Marine Protected Areas

Some areas of the UK coast need greater protection, including a National Marine Park in Plymouth. A new plan for marine protected areas should be established. Their management should include:

  1. Completely closed areas in peak spawning times – working with real-time science to determine exactly when the fish are about to spawn then closing for all fishing – this could be for just a few weeks.
  2. Priority access in the MPA to smaller boats, and  / or those using less damaging gear , for example handline, static nets, and light trawls.
  3. Increased mesh size as a minimum requirement for fishing in MPAs
  4. Completely close off highly sensitive areas of the marine environment including coral / seagrass / nursery grounds
  5. Collaborate with science for real-time catch data and use this to determine fishing effort in real time.

Recent Government Commitments clarified:

We would hope and expect that Labour hold the Government to account for some of their recent promises on fishing:

The 25 year food and environment plan set out the following commitments:

"…the Government will publish an annual statement on the state of fish stocks of interest to the UK. (p106)

This is a great commitment, but at the moment this annual statement will be full of gaps. We don’t currently understand the status of many commercially-fished stocks in the UK, and they are managed to varying degrees of success through precautionary or data-limited means. Many are not considered sustainable. This annual statement will only prove to be useful if the government invests in carrying out these assessments (this would be for species including black bream, brill, cuttlefish, some species of dogfish, gurnard, halibut in the north-east Atlantic and monkfish). Sadly this commitment to carry out stock assessments was missing from the plan. We would look for Labour to call on Government to make this clearer in the forthcoming Fisheries White paper.

ALL stocks recovered and maintained at Maximum Sustainable Yield (emphasis added – p27)

A commitment to ensuring that fish stocks are recovered to scientifically-determined sustainable levels is worthless without a timescale. If we are to assume that the target date is in 25years (as per the timescale of the plan) this is a huge step backwards. The EU’s current commitment is 2020.

The commitment does, however, include all commercial stocks. This therefore commits Government to establishing the status of stocks that currently don’t have enough data, and this is a fantastic commitment. This would see a return to sustainability of some very important commercial fisheries in the UK, and restore some of the stocks that are significantly below sustainable levels including Scottish langoustines, some scallops, skates and rays, turbot and halibut, sea bass, ling, some monk fish. We would look for Labour to call on Government to make this clearer in the forthcoming Fisheries White paper.

Public sector procurement:

The Government could and should be using its power as a buyer to support a sustainable food system, and support British producers. The plan commits central government to use Defra’s ‘balanced scorecard’ when procuring food (see p90), but no commitments to monitoring and enforcing the standards. We would look for Labour to call on Government to make monitoring and enforcement clearer in the forthcoming Fisheries White paper.

Michael Gove’s speech to the Oxford Farming Conference, January 2018.

In this speech, Gove announced a new ‘Gold Standard’ label for British produce. We would like to see what this standard would look like for both wild-caught and farmed fish. We would look for Labour to call on Government to make this clearer in the forthcoming Fisheries White paper.

Our main concerns with regard to the upcoming Fisheries Bill are:

FISHING COMMUNITIES LEFT BEHIND - It is likely that the UK will face some tariffs for exporting fish to the EU after we leave (Norway pays between 2% and 13%). We are concerned that the Bill won't contain any provisions for helping these fisheries by developing a domestic market. One way this could be done is by enforcing government buying standards and stipulating that a % of fish bought in the public sector must be British and sustainable.

MSY TARGETS - The 25Yr food and environment plan mentioned an ambition of setting fishing effort at a level which will produce Maximum Sustainable Yield, but, very worryingly, didn’t set a time-bound target for doing so. The current target for the EU, as part of the Common Fisheries Policy, is 2020. The vague, non-time bound target in the 25yr Plan is therefore a very serious step backwards. We are hopeful that this will be clarified in the Fisheries Bill.

Sustainable Fish Cities sought clarification from Defra on this point and were advised that MSY is part of a ‘long term plan’. We are concerned that this is an attempt by Government to allow overfishing in the short and medium term.

FUNDING: Previously ring-fenced funding for fisheries (from the European Maritime and Fisheries Fund) will be cut, or bundled together into a shared fund, with fishing communities not guaranteed the support that they need to improve nets, conduct research, build port facilities etc. We believe that the scope of this funding should be increased to assist all UK fisheries to achieve sustainability certification.

THE BILL WILL BE TOO NARROW – concentrating only on the parts of fishing legislation currently managed by the CFP, and failing to address other urgent issues faced by UK fishing. These issues include:

  • Data deficiency
  • Failing to distribute quota according to transparent social and ecological criteria
  • Lack of effective management of some of our most productive fisheries and fragile habitats. (We suggest that you refer to, or contact, Project Inshore for more information about the pressing management issues and how they can be addressed)
  • Support for sustainability certification
  • Support to create or increase the market for UK sustainable fish (including enforcement of  public-sector procurement standards)

How long do you think the consultation on the Fisheries Bill needs to be and what format should it take?

The consultation should be as wide as possible, include participation from stakeholders from the scientific community, as well as NGOs and the fishing industry. We think that the longer the consultation can be, the better.

The upcoming Fisheries Bill should seek to address the following three failings in current policy:

Lots of UK fisheries aren't demonstrably sustainable at the moment, for a number of reasons, with a number of different solutions. This is the main failing of the current policy. The EU-managed stocks are actually doing quite well but there are still many UK fisheries that aren't verifiably sustainable.

Data Deficiency - a number of fisheries don't have enough data on stock status or the impact of the fishery to be considered sustainable. Government should fund the data collection required – CCTVs and GPS trackers on boats as a first step - to allow sustainable fleets to demonstrate that stocks are in good shape, and to highlight a need for action in others. This up -front injection of resources will reap dividends for the long term future of the UK’s fishing industry and coastal economies.

Lack of incentive to improve - boats could switch to nets with larger mesh sizes, or lower bycatch, or less contact with the sea floor, but there is little incentive to do so. Government could incentivise such improvements by offering more quota, and funding gear modifications etc. One incentive to improve is to get the benefits of a better price and access to good markets from achieving sustainability certification. The costs of this could be supported by government, to make the scheme accessible to all boats.

The three main principles for quota management with the EU and other countries going forward:

THE OVERALL TOTAL ALLOWABLE CATCH (TAC) MUST NOT EXCEED SCIENTIFIC ADVICE. ICES should set all TACs, and fishing must always be within this TAC, regardless of who is fishing it, in whose territorial waters.

QUOTAS SHOULD BE ALLOCATED based on transparent social and ecological criteria. More quota should be allocated to boats that demonstrate that they are fishing sustainably

LOCAL QUOTA ALLOCATION SHOULD RESPECT SCIENCE AND CONSERVATION - to avoid overfishing in some areas, to protect fragile habitats and avoid spawning grounds.

On what basis should foreign vessels be granted access to UK waters for fishing after Brexit?

All boats in UK waters must adhere to UK conservation and sustainability policies including (but not limited to): - Banning discards - Recording all catches - On-board monitoring systems such as CCTV and/or GPS.

EU Boats could have access to UK waters if tariff-free access is granted for UK products.

The three main principles for a fisheries management regime after Brexit should be:

ALL STOCKS AT SUSTAINABLE LEVELS, BY 2020 – total catches should be set my scientists, and not exceed levels that would produce Maximum Sustainable Yield

MINIMAL HARM TO THE MARINE ENVIRONMENT – including minimising bycatch, avoiding sensitive or vulnerable habitats or areas of high biodiversity, using low impact fishing gear

GOOD MANAGEMENT – fishing effort should be well regulated, informed by sound data and scientific understanding, boats should be monitored with CCTV and GPS trackers, management should respond quickly to new data and changes in the stock.

In what three ways should the government be investing in the fishing sector, including the processing industry?

  • Providing funding for the improvement measures, data collection and auditing regime required to achieve a recognised standard of sustainability. This should be the top priority for investment, even if it means paying boats to fish less in the short term. The sooner we restore fishing stocks to sustainable levels the quicker UK boats can benefit financially. The New Economics Foundation estimate that if stocks recover to their Maximum Sustainable Yield, we can generate €1,565 million additional gross revenues per year across Europe.
  • Funding or subsidising sustainability certification, including Marine Stewardship Council Certification and Seafish’s Responsible Fishing Scheme, to help UK produce get better markets in the UK and abroad, and to give a clear reward for fishing sustainably.
  • Supporting the market for UK-landed sustainable fish, including through government procurement and by requiring large businesses to report transparently on the sustainability of the fish that they buy

Questions for wider submissions

What are the long-term, strategic aims for British Fishing after Brexit?

The UK should aim to have the best-managed fisheries in the world. This would have the following benefits:

  • Significant economic benefits from increased catches, as stocks rebuild (see the report by the New Economics Foundation, which outlines the potential for jobs and incomes if all fisheries were managed at Maximum Sustainable Yield:
  • The best international markets for UK produce. Increasingly, oversees buyers are looking for sustainable, high quality produce
  • Secure domestic markets for UK produce, because UK fish meets the sustainable buying standards of retailers and caterers.

How should the Government be looking to bridge the skills gap and train the next generation of men and women working in the fishing industry?

The skills gap that we face, particularly in the wake of Brexit, is not confined to the fishing sector, and we believe that a wholescale overhaul, and comprehensive vision for skills and training in food, farming and fishing is needed. We need to make these careers more attractive, and support and cherish excellence. We believe this needs a twin approach around the quality of training and the quality of the jobs themselves.

On the latter point this requires better pay and job security in these professions, which may be possible with a smaller market for labour, but only if that labour movement is well coordinated and vocal in demanding better protection.

On training, we believe the time is right for a Royal College of Food. Other disciplines have royal colleges, but strangely not food (in which we would include farming and fishing). By creating a higher pinnacle for achievement and excellence within this sector, it creates the space for competition, and would create a cascade of demand for higher education, A levels and GSCEs in food related topics. For a sector that is arguably the largest employer in the country, from farm to factory, supermarket shelf to hotel dining, the lack of institution on a par with the greatest colleges and places of learning in the land is damning evidence of how we see this sector.

We believe this could be a multi-site and multi-disciplined establishment, and should include training for future and existing chefs, bakers, farmers, fishers, and food entrepreneurs as well as the nutritionists, planners, policy makers and procurement managers of the future. The ‘siloed’ approach currently between these trades and disciplines is one of the barriers that we need to overcome. The next generation of those going into these sectors need to understand that concerns about the environmental and social impact of food and how it’s produced, reared, caught, processed, etc. need to be woven into their training in order to better respond to the demands of policy, consumers, and citizens.

But to help the fishing industry we need to see an understanding and appreciation for this across other sectors. Better training for chefs not just on on how to prepare fish, but on what fish to buy, what to ask suppliers, how to use under-utilised species and create a market for sustainable UK fish. This kind of knowledge wouldn’t go amiss in other parts of the food and farming industry, and with procurement managers who make the choice over what to buy and where from. Crucially this needs to be ongoing training, as the information on stocks changes regularly.

We need to get behind new ideas that promote a positive vision for the future of the country, particularly when faced with the uncertainties and posturing around Brexit. A Royal College of Food should be just the start of this ambitious approach.

Ruth Westcott, Sustainable Fish Cities

Brexit: We stand at a cross-roads. When the UK leaves the European Union, will our leaders uphold good standards for our food, farming, fishing and trade deals? And will they agree a sensible deal with the EU? We need to make sure that they do!

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