Fishing is essentially a pretty simple business: Vessels go to sea, deploy gear, catch fish, sell fish. Wild fish form a hugely important source of nutrition whose qualities have come to be even more valued in recent times. Fishing plays a vital economic role in coastal communities.

We in the fishing industry are perfectly conscious that it is indeed possible to destroy the basic ingredient of our industry – fish stocks – but we would ask our critics to also recognise that we want to conserve the fishing way of life as a legitimate objective too!

Fisheries policy and management – in contrast to fishing itself –  is pretty complex. The ability of man to deplete fishing stocks has increased with technology in vessels, fish-finding equipment and fishing gear. Because the resource is not capable of being corralled into identifiable areas, there is a basic need for regulation and management in the wider public interest – interest that originally was solely concerned with preservation of stocks at acceptable levels but has increasingly come to be recognised as an issue of biodiversity and habitat conservation.

The EU Common Fisheries Policy (CFP) was negotiated in the late nineteen-seventies and came into force in 1983. It is of course a political agreement  that reflects the interests and relative strengths of the different contracting parties. The policy is made up of over 700 different pieces of EU legislation that have built up incrementally over the years and that govern fleet sizes, fishing quotas, fishing gears, market organisation, control regimes and access by various nations to resources in different areas.

The current policy might be best described as a “cacophony of mis-directed co-operation”, insofar as it is incredibly complex, is costly to operate for everybody concerned, has not succeeded in conserving fish stocks (with some exceptions which may or may not be attributable to the CFP) and has lead to a fishing industry which contnues to lose jobs.

To summarise the main problems:

• The problem is that the fish are under the sea. We can’t see them or tell how many of them are there except in pretty hazy terms. They move around in a most inconvenient way. They are subject to biological processes we only partially understand. In EU waters we have fishermen from dozens of countries trying to catch them. The fishermen are pretty good at what they do.
• We have devised regulations to manage stocks and when we think they haven’t worked, we devise more complex regulations. Nobody believes anyone. Some people respect the rules, others don’t. Some people adapt as technology changes, some don’t. Everything has to go to Brussels for decision. Countries jockey for advantage. Rules change from year to year.
• Solutions deemed to work for a stock in one area are imposed on others where conditions may be completely different. No-one knows where they stand and the biggest impulse is to catch more – now. Attempts are made to circumvent rules.  More rules. More confusion.
• The system consumes the energies of a lot of good people but we rarely seem to get positive outcomes. Indeed, practically every participant in the system is deeply unhappy. Some fish stocks are indeed in considerable trouble in the EU. Others, mind you, are patently not.  Many parts of the European and indeed Irish fishing industry are in deep and continual crisis.

There remains however an absolute imperative of having an effective CFP because the resource is shared between many countries and interests.  An essential prerequisite to reversing the current abject state is that responsibility for that failure must be clearly acknowledged by policymakers, by managers, scientists, by fishermen and indeed leaders of fishermen’s organisations. We have all made mistakes. It is not good enough and not true for anyone to imply that the fault for failure lies solely at the hands of allegedly irresponsible fishermen and irresponsible politicians.

We need to concentrate on solutions, but any such solutions will not be found if we do not have a clear and honest analysis of how we got here.  The 2009-2013 CFP reform can only be effective in producing results if the process itself is designed to change the nature of the dialogue between the stakeholders. It is unclear that this fact is understood by those who should understand it.

While some key aspects of existing policy are superficially common on an EU wide basis, we have a multilateral system with widely different systems of administration, resource allocation and wildly different levels of controls and sanctions for misbehaviour in place. Harmonising some key pillars of a renewed CFP is essential as is implementation on a genuinely common footing.

The policy has to be seen as a process in itself, which sets a clear road-map towards achieving biological sustainability in an achievable timeframe, but in a manner which concurrently seeks to maintain the optimal economic and social benefits of having a healthy fishing industry.

A  key feature of such a process must be the achievement of the maximum level of consensus among all the stakeholders. There is little or no common understanding at present, with the result that stakeholders are often at complete cross-purposes and policies are incapable of being implemented and thus have no legitimacy. Management should be a participative process not a form of backstreet surgery.

This can be facilitated by a credible “audit” process that examines the state of biological knowledge of fish stocks and the marine ecosystem, and that also examines and quantifies the economic and social dimensions. Only when such an audit is credible can the requisite policy imperatives be identified.

Features which will need to be a part of a renewed CFP should include:

• Establishing an appropriate hierarchy of decision-making is a key element to avoid the excruciating reference of practically all management issues to the top. We need tiers of subsidiarity which would mean decisions – and responsibilities – being taken at appropriate levels. The ground rules and scope for such regionalisation must be properly thought out or we will end up with a set of mini-CFPs which will be even more incoherent and ineffective.
• We have an environmental dimension which is increasingly important. That is essential and welcome. Care for biodiversity and the future existence of the resource is seen quite correctly as being essential for society and indeed is good for fishermen.
• The implications of legislation such as the Habitats and Birds Directives will also      require to be factored into the CFP process.
• A major difficulty for the fishing industry is that the environmental “bar”, if I may call it that, is not fixed and we have to contend with ever-changing demands which undermines confidence and leads to continued instability. There must be reasonableness and balance in the decisions arrived at. It is notable that half of the online responses to the EU Green paper to date are part of an orchestrated campaign to make 40% of Europe’s waters Marine Protected Areas and to ban bottom trawling for fishing. This is not reasonable.
• Commercial fishing is an economic activity which seeks to make profit. It is a vital part of the economy and fulfils a vital consumer need. We need people making profits, earning incomes and sustaining the economic and social life of the coastal regions.  The current ever-changing management landscape is crippling to the fishing industry.  The economic questions also extend to dealing with who has access to the resource. There are value judgements to be made. Such decisions should not be left entirely to the market, with those with access to capital being the only ones who benefit. It does not make sense economically, regardless of how the simplicity of it might be attractive to some.
• The EU Commission’s green paper on CFP reform seems to lean heavily towards international transferability of individual vessel quotas on a vessel-to vessel basis, something we in Ireland are quite concerned at as it could lead to an effective migration of fishing rights away from Ireland to other countries.
• We should maintain a degree of economic and social diversity to be protected in a new CFP. We need to  take a pragmatic look at the appropriateness of long term assignment of rights: we need to have a frank and reasoned debate.

A major conundrum in fisheries management and the effective operation of the CFP is the difficulty in achieving reliable estimates of stock levels and trends. The state of fish stock biology at present is terrible – not the fault of scientists, but of the system and a culture that does not provide scientists with the requisite data on a reliable and consistent basis. Rectifying this by internalising and incentivising it into the new CFP over time is essential.

People who are given responsibility are far more likely to act responsibly. Enlightened co-management, with appropriate regulation where fishing interests are at the heart of decision- making relevant to them, must be part of the new dispensation – not on every issue, but  certainly in managing particular regional stocks.

While there always will be tension between managers, regulators, environmentalists, scientists and fishermen, we can go a long, long way if we have the will and the patience to achieve a partnership approach and a commonality of control which would make everyone’s job a lot easier. A few demonstrable successes would help too.

We need a CFP that is properly resourced. While the development of a new CFP can in time achieve more cost-effective management, it must be recognised that there are likely to be up-front additional costs in achieving that transition. This is a key test of the political will to achieve change. Such financing has to be based on leveraging structural change, rather than short term maintenance and in this I think I might agree with the EU Commission – although I am not sure, as usual, whether I am  seeing the world the same way as they do!

We are not starting from a blank canvas. That adds to the challenge of reform. Different countries’ governments and the industries in them are in fact quite happy with elements of the current set-up, often based on large investments in individual quota. They might fear that certain types of change will disadvantage their countries.

We must have a reliable assessment of the appropriate fleet size and profile that can profitably fish the resource on an economically sustainable basis. This involves assessing fishing capabilities on a realistic basis and not simply on the basis of nominal Gross Tonnage or KW measures as is currently the case.

How the management of the market for fisheries products is to be organised within the EU is a further component which must be re-defined at an EU level, having regard to the viability of the producers, processors and distributors, food security and trade issues. This is an essential further component of the process in which clear and unambiguous timelines are established.

To summarise: the CFP reform needs to set out the high level strategy which balances economic and environmental  sustainability with social dimensions, national access to resources, uniform controls and sanctions insofar as legally possible. In addition, there must be a clear trajectory for implementing these with respect to central and regional management, achieving acceptable levels of reliability in scientific analysis and the various management tools which can be applied at the appropriate levels.

On some more of the ideas raised
in the Green Paper:

• The question of overcapacity – “too many boats chasing too few fish” —is a gross oversimplification. Too much fishing potential, which is presumably what is really meant, is a problem that applies differentially in different fisheries and different countries. So we need to be cautious about how we define the issue and how it should be solved.
• The possibility of moving away from catch limits to effort control sounds superficially attractive but is fraught with danger. Apart from the obvious risk that the available effort would be subject to the same fluctuations as we have in quotas, there is the potential for a real threat to stocks from such a move. The issue is also bound up with fishing potential and with the distribution of fishing rights and with discards policy.
• Regarding discards, it is a fallacy to strive for the elimination of discards of fish. People forget that many discards are the result of legally imposed minimum landing sizes. We should concentrate on landing fish that people want to buy, not rubbish. We should of course seek to minimise unwanted discards through more sophisticated use of adaptive zonal management and technical measures such as increased mesh sizes. But this is a complex issue which should not be dictated by ill-informed sentiment as I fear it is.
• National limits – i.e. the coastal areas in which national fleets have exclusive or priority access —are essential and I believe there is a considerable case for extending such limits on regional, social and indeed environmental grounds. The question of intra-national access to these resources is key and inshore management is essential.
• I am of course totally in favour of additional quota shares for Irish fishermen. I strongly suspect however that my colleagues in France, UK and Spain might have their own views on the subject.

While not wishing to muddy the waters or diminish the need for real reform of the CFP within Europe, a word of caution that doing so while continuing to allow unregulated fishing in other areas of the world and a flood of imports from areas which have been environmentally trashed in the process is hardly a credible solution on global terms.

The trendy and simplistic notion that “big” boats are the cause of all the problems and that “small” boats should be encouraged in their stead is likewise a fallacy. The fact is that mixed profile fleets of a size appropriate to the different waters in which fish can be caught is likely to be a far more beneficial outcome. Deciding the appropriate mix is partly a public value judgement but also a function of economics and biology. Considerations such as local and regional policy, distribution of ownership, optimising employment and economies of scale need to be factored into such decision-making.   

Survival of many parts of the European fishing industry is in considerable doubt due to the immediate short term pressures that exist right now, but the long term future for the stocks, the marine environment and for fishing communities hangs on the outcome of the collective deliberations of stakeholders throughout the EU in coming months.

The debate on reform will continue from now until 2012. It is essential that the various viewpoints be heard in that debate and that the often impassioned proponents of opposing views pause to take account of the real and genuine concerns of each other.

It should not be beyond the combined efforts of political representatives, environmental organisations, biologists, economists, social scientists as well as those committed to the future of a fishing industry and fishing communities to devise a vastly improved outcome and processes for delivering it.

Lorcán Ó Cinnéide, Chief Executive, Irish Fish Producers Organisation (IFPO)

ifpo@eircom.net