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Listen
Chapter 4 - Supporting our Communities
Question 8: Do you consider that our proposals will improve sectoral management in Scotland?
Proposals:
- Grant sectoral management responsibilities in Scotland only to Scottish recognised POs, and, for the most part, to allocate Scottish quota to those POs on the basis of FQAs associated with Scottish vessel licences and Scottish PO holding licences.
- Monitor the level of quota managed by Scottish POs collectively, to ensure that Scottish quota is not overfished.
- Develop new group arrangements designed to ensure that Business Plans and strategies properly reflect PO members' requirements.
- Revisit arrangements for PO Board membership (including possible widening of Board membership to include non-executive members).
- Improve transparency of monitoring quota uptake, and better demonstrate the effectiveness with which quota, an asset of national importance, is being managed.
- Revise the disciplinary process to ensure that all groups are provided with the requisite tools to carry through their responsibilities. Within this, we propose that a new common scale of penalties, both financial and in terms of quota, should be devised and implemented uniformly by all groups given responsibility for quota management. These arrangements should be underpinned by mechanisms to ensure that no individual can leave a group until the quota or financial penalty is paid.
- Formalise the submission of Operation Plan and Accountability reviews as part of a formal process of accrediting POs in respect of their functions.
- Maintain the current arrangements for deductions for overfishing of end-year PO allocations or quotas allocated to the UK.
Summary of views received:
There was broad support for these proposals alongside recognition of the importance of Producer Organisations in sectoral management. There was no support for organisations other than POs to have responsibilities to manage sectoral quota. The proposals to improve their accountability, governance and transparency also gained broad support. Some POs were wary of the proposal to include non-executives on Boards. Both POs and the broader industry favoured a substantial revision to disciplinary processes, PO powers and penalties. The optimal size of a PO was also raised by some in relation to the future development of sectoral management in Scotland.
A small number of respondents expressed concern that membership of Scottish POs should not be restricted to Scottish-registered vessels only. Many of those that responded to the required submission of detailed marketing plans from POs acknowledged the fact that most POs do little, if any, marketing. Some expressed the view that this should simply be left to sales offices/agents or processors. Others thought that the POs' marketing role could best be delivered through further engagement with Seafood Scotland and Seafish.
Most respondents recognised the important role POs play in fishing communities, and some believed it is worth exploring further how POs could help encourage new entrants into the industry.
Scottish Government response:
The Scottish Government considers that the underlying ethos of all POs should be to support their local fishing industry. We place great emphasis in Scotland on POs' link to the community through their recognition status and are pleased with the strength of response reinforcing the support for POs and their role in the fishing industry. Improvements, specifically relating to governance and transparency, are however required, and we consider that POs can additionally enhance their quota management and marketing role. We remain convinced that the proposals outlined in the consultation are the means to achieve such improvements. Only POs and Government should be responsible for managing quota in Scotland.
The responses to our consultation have helped provide valuable information to ensure that POs are equipped to deliver benefits to their members and communities that their recognition criteria merits.
In order to deliver these objectives we will establish a joint Scottish Government/industry PO Reform and Implementation Group. The Group will include representatives of the Scottish recognised POs, and the Scottish Government and some wider industry representation. The Group will be tasked with implementing the proposed changes in their entirety. This approach should help ensure that, when implemented, the proposed improved management arrangements, such as disciplinary procedures, are fit for purpose. This group will specifically look at how best to improve the delivery of the POs marketing role, including interface with Seafood Scotland. We anticipate that POs managing Scottish quota and operating under the Scottish quota management rules will require an operating licence to do so.
Question 9: Do you agree with our package of measures to help safeguard the viability of inshore vessels fishing quota species?
Proposals :
- Maintain the "pool" arrangements for 10 metre and under and non-sector fishermen, who prefer not to become members of a Producer Organisation.
- Introduce langoustine permits for Scottish non-sector and 10mu vessels. This measure to limit langoustine fishing effort is aimed to protect both the health of the stock and the livelihoods of those fishermen who depend on it. In due course, we may also consider other possible restrictions.
- Review the Scottish North Sea langoustine quota allocation to 10mu and non-sector groups. This has been problematic in recent years, largely because of relatively low quota levels in the pool, against a backdrop of under-fishing of langoustine generally. We proposed to increase the initial "pool" allocations of North Sea langoustine, from 2009, by transferring a small amount of quota from Scottish Producer Organisations. This arrangement will be reviewed and consulted on each year.
- Introduce an "exit" scheme that would enable vessels with the necessary capacity and ambition to quit the 10mu and non-sector pools and join a Producer Organisation. Such an arrangement would enable them to leave the pool with some quota on a temporary basis, and therefore make it easier to join a PO.
Summary of views received :
Just over half of the respondents to the consultation commented on the proposals to help safeguard the viability of inshore vessels fishing quota species.
Maintain the pool for 10 metre and under and non-sector vessels
There was general support for maintaining the "pool" arrangements, with most respondents citing the important route the pool provides for those coming into the industry, and the welcome flexibility such arrangements offer to the diverse inshore fleet. One or two disagreed with the current arrangements, believing them to be under resourced and thereby creating ongoing uncertainty for many inshore vessels.
Scottish Langoustine permits
The introduction of Scottish Langoustine (Nephrops) permits had some support, though issues surrounding flexibility, appropriateness and access were all raised. Those supporting this proposal suggested that without a nephrops permit, capacity and effort would grow and the problem facing fisheries managers of matching available quota to the non-sector and 10 metre and under fleet would become more difficult in the future, particularly with the prospect of reducing TACs/ quotas. The importance of regulating the number of permits was emphasised by some, along with an acknowledgement of the potential role Inshore Fishery Groups may have in the future administration of such arrangements.
A view was expressed that the permit should be extended to the sector, and that including all vessels targeting nephrops would help encourage a sustainable fishery. It was suggested that a permit scheme should be structured in such a way so as to discourage part-time fishing for nephrops (e.g. by increasing substantially the landings criteria for permits), and indeed that permits should only be given to vessels which fished full-time. It was also proposed that a permit should be linked to a maximum KW cap for 10 MU vessels. Other suggestions included extending the permit scheme reference period to three years, complemented by a facility for pipeline cases, and that there should be a system of ''one in, one out' for permits, operated possibly at a local level.
Those who commented on additional effort restrictions focused mainly on the regulating of creel numbers operated by a single vessel and or in specific areas which could be fished at particular times or seasons.
Review the Scottish North Sea Langoustine annual allocation to 10mu and non-sector groups
Views expressed regarding this proposal were fairly evenly split, with, as expected, inshore interests generally supportive, and sector interests against any transfer of quota from the sector to the 'pool'. An argument put forward by some of those against such a transfer of quota, was that many of those now fishing against the pool had decommissioned their vessel, benefitted financially, sold their FQAs, and then downsized and entered the 10 metre and under fleet.
The additional pressure on POs' quota allocation as a result of possible TAC reductions in the future was highlighted by some respondents along with the concern that this proposal could be extended into other stocks.
Those who agreed with the proposal suggested that this was simply making the best use of the available resource for the benefit of fishermen and processors. This proposal it was argued, would also help some of the smaller, more vulnerable fishing communities. Some inshore interests indicated the proposal to transfer 400 tonnes in 2009 was not sufficient for a full year fishery (a figure of 600 tonnes was suggested). It was also noted that the transfer of tonnage from the sector to the inshore fleet is only possible at the moment, due to the significant under fishing in the sector, and this is likely to change in the near future. Some questioned where the quota would be sourced from in the future. One respondent made the point that quota should only be sourced from those POs that have not fully utilised their allocations. It was suggested that any "top-slicing" of quota could be based on POs' uptake compared to initial quota allocations over the last three years.
Introduce an exit scheme to encourage vessels currently fishing in the Scottish 10mu and non-sector to join a Scottish Producer Organisation
Views on the proposed "exit" scheme were mixed. Although some supported the principle of encouraging the larger catchers currently working from the pool, into POs, many thought the proposal was not attractive enough to either encourage vessels to move or to encourage POs to accept these vessels into membership. It was felt by some that this proposal shifted the onus of responsibility into the hands of the PO, creating greater pressure on some POs' existing members' quota allocation. There were suggestions that simply lowering the quarterly catch limits for NS and WS nephrops (the stocks of primary importance to the Scottish inshore groups) would "force" these vessels into POs. It was also suggested that the scale of the problem did not warrant further resources being targeted at a handful of vessels.
The leasing of quota was supported by some, but generally viewed as a temporary solution. One respondent viewed it as a half-way house, by allowing vessels to retain non-sector/ten metre and under management and to supplement the quota available from the pools by leasing. It was also suggested that leasing of quota should only be an option for vessels that are part of a community quota scheme, so the community leases the quota and not the boat.
Scottish Government response:
Following careful consideration of the responses received and views expressed we remain convinced that these proposals should be viewed as a package of measures. We are clear that management improvements are required to help optimise the economic and social contribution the inshore vessels make to many fishing communities. Further discussions with the other UK Fisheries Administrations will take place during this year regarding these proposals.
We recognise the important economic and social contribution the diverse inshore fishing fleet makes to many of our fishing communities. The Scottish Government remains convinced that the 10mu and non-sector nephrops pools should be reserved for only those genuine inshore vessels that catch a relatively small amount of these quota stocks. A package of measures is required to maintain the viability of the current pool arrangements, and importantly to keep an entry point into the fishing industry open. We remain convinced that effort controls (permits) are required to achieve this aim.
Many non-sector and 10mu nephrops vessels have enjoyed relatively high, effectively unrestricting, for most vessels, quarterly nephrops quota limits in recent years. This situation cannot be relied upon to continue, and is an unsustainable long term position. It is therefore prudent to take steps now, whilst there is still a significant underfish in the sector, to encourage those vessels with relatively large capacity, currently fishing against the pool, to move into the sector.
Having carefully considered the responses received and views expressed to this package of measures, we propose in due course to:-
Maintain the pool for 10 metre and under and non-sector vessels
Create a Scottish 'pool' for both the 10 metre and under and non-sector.
Scottish langoustine permits
Whilst we acknowledge that unrestricted effort needs to be addressed and the introduction of langoustine permits for Scottish non-sector and 10mu vessels is one possible measure to prevent an increase in effort, we do not propose to introduce such measures at this stage. Instead, we propose to establish a working group (perhaps using the already established Langoustine Sub-Group) to consider what, if any, effort controls are required to maintain the viability of the inshore quota pool arrangements. Langoustine permits are one possible measure.
Review the Scottish North Sea Langoustine annual allocation to 10mu and non-sector groups
We understand the arguments made for and against this proposal, and following careful consideration, believe that to ensure we make best use of the available resources, and optimise benefits to our fishing communities from this available resource, it is sensible and reasonable to review on an annual basis the need to allocate North Sea Nephrops quota from the sector to the 10mu and non-sector pool. A decision on any transfer of in-year North Sea Nephrops quota will be taken following full and proper analysis at the beginning of the quota year. In order to have minimal impact on the sector, we consider that any transfer of quota from the sector should only come from those POs that have demonstrated under-utilisation in previous years. This could, for example, be based on uptake compared to initial quota allocations over the previous three years or, as an indication of interest in the stock, on a basis which considers POs' landings rather than their FQA holdings. Stakeholders will be consulted in due course regarding the details of this proposal.
Introduce an exit scheme to encourage vessels currently fishing in the Scottish 10mu and non-sector to join a Scottish Producer Organisation
Introduce an exit scheme to encourage some vessels currently fishing in the Scottish 10mu and non-sector to join a Scottish Producer Organisation. As noted above, the current privileged position of underutilisation of nephrops quota may not always be the case. Steps should be taken to give those larger catching vessels a greater opportunity to leave the pool and join a PO. This scheme should be attractive to both vessel owners and POs alike. We propose that a vessel owner who is committed to leaving the pool, would for a three year period be entitled to transfer 90% of his vessel's recorded landings (average over the preceding three years) of in-year quota to a PO at the beginning of each year. Any in-year quota transfer would be done under strict conditions to ensure the benefits remain in the appropriate fishing community. Consideration would also be given to a group of vessels wishing to take up this offer on a case by case basis. We are clear that, in the long term, the pool should be for only smaller inshore vessels which do not catch significant amounts of quota stocks. We envisage and expect that those vessels that have left the pool to join POs would have secured sufficient FQAs to maintain their membership at the end of the three year period.
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