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23.03.12 Three Steps to Survival and Profitability:

In an attempt to cut through the “noise” currently surrounding the under ten quota issue, NUTFA proposes a three pronged approach to resolving the present impasse:

There are three major aspects (as well as of course any number of minor ones) involved in moving the under ten fleet to a more sustainable and profitable position. These are:

1. increasing the amount of quota available [and making best use of it]
2. reducing the number of vessels accessing that quota [in a fair and equitable way]
3. improving the returns from fish landed [and reducing associated costs]

NUTFA has stated previously that attempting to address individual elements of the problems that beset the inshore fleet simply cannot work.
All through the following comments, reference will be made to an Inshore PO (IPO). Whilst not a solution in itself, it would act as the necessary vehicle for a number of the initiatives outlined below. Subsequent articles will explain that process in more detail.

Finding a way:
1: The Minister has made clear his intention to move a small amount of quota to the <10’s. Whilst welcome, on its own, this fish is not enough, so where does any more come from?
At present, a standard PO has sufficient resources to be able to swap quota not only with other UK PO’s but also with Europe. These internal resources come from the quota that members bought with them as well as that purchased and leased with the income derived from members subscriptions and through other means. An IPO would utilise the existing pool quota more effectively, certainly through a more focussed approach to utilisation and need, build resources in order to acquire more quota in the same way as existing PO’s as well as encouraging the Government to think outside of the box in terms of acquiring resources from further afield. In the long run, any additional quota that UK PLC can acquire will be good for the country as well as for the fleet and certainly an investment worth making.
Equally, all concerned agree that the under tens were disenfranchised from the outset and that their landings were not accounted for when TAC’s and quotas were decided. There is good reason to review this failure in both a domestic and European context as any positive outcomes would provide benefits without disadvantaging any other sector, i.e. there is nothing to lose.

2: Another area of common agreement is the need for an effective decommissioning scheme. Opinions differ as to whether it should be specifically focussed on under or over tens. In our opinion it needs to be a combination, decommissioning some over tens and redistributing the quota released as well as reducing the number of vessels reliant on quota species in the under tens, but importantly in a fair and decent manner.
Make no mistake, attempting to introduce any individual rights based system of allocation will bankrupt 100’s of boats almost overnight and so a just system of decommissioning is the only decent and acceptable way to go.
Government has made clear their problems with funding such a scheme in the current economic climate but again, there are potential alternative avenues of match funding, both within and outwith the industry that could and should be actively pursued.

3: Notwithstanding the recent drop in prices for some species, there is a growing desire for sustainably sourced fish, linked to the increased profile of inshore fisheries in the media. There is also a clear disparity between market prices obtained around the country. One of the original roles for PO’s was marketing and there is absolutely no doubt that given the right support, the inshore fleet can significantly improve returns through the efforts of an IPO in many areas. Government has thrown a great deal of money at studies and ‘sustainability’ projects so a bit more to greatly improve returns would be welcome.
NUTFA’s proposal for an IPO seeks only to create a way to pull all these threads together into a coherent model, a means of starting to address the range of problems and opportunities for this sector of the fleet. It is all about management by the fleet, for the fleet.
Up to now, the future of the under ten fleet has always been in the hands of others who have had their own aims and agendas. It’s about time that the under ten sector took responsibility for its own destiny instead of relying on others to do it for them.
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14.03.12: NUTFA Update

NUTFA has been deeply involved in discussions with Defra, the PO's and the NFFO with regard to quota allocation issues for a considerable time as the under ten representative body on the Minister's Industry Working Group.
After many months of debate and argument, the Minister decided upon a small reallocation and realignment of species from the PO sector to the under tens.
This approach was based very clearly and very conservatively [too much so in our view] specifically on those stocks that were obviously surplus to the PO requirements year on year.
The amounts to be reallocated did not even take into account the quantity of quota that had been leased to under tens by the PO's as the government decided, probablyunder pressure from the PO's, that quota that had been leased was deemed to be "used" and therefore not available for realignment.
 
We have constantly disputed this decision as it would seem entirely logical to us that if one sector has a significant surplus of quota over and above their needs that they are able to rent it out to fishermen in dire need of it then it is fundamentally under utilised and should have been included in that definition, thereby making a proportion of it available for reallocation or realignment.
 
The decision not to consider it in this way merely provides a government approved conduit for PO's to continue to charge under ten fishers for the privilege of trying to make a living and using a publicly owned resource with which to do so.
 
In the same way, Defra have constantly refused to follow their own Rules of Quota Management that permits them to reallocate on an in year basis only, quota from one sector that has an excess over and above their operational requirements, to those who are in need of it.
Their excuses for not doing so range, amongst other things, from the apparent threat that it may encourage the race to fish (laughable in light of the current situation for many under tens), might skew the market through producing a surplus of fish on the market (see comment above), encourage a race to fish through PO members attempting to catch all their allowance before its reallocated and importantly, because “PO’s have an obligation to provide their members with the best possible fishing opportunities and financial returns from the quota allocated to them”. [my underlining].
And there’s the rub.
Whilst it is in our view only right of course for the over ten sector to have an equitable share to meet their needs from this public resource, being permitted to use their excess to hold another sector that is in dire need of additional access to this resource to ransom is fundamentally iniquitous.
 
You will be aware that some have always tried to characterise our aspirations on behalf of the under ten metre fleet as attempting to 'rob Peter to pay Paul' and they have now accused Nutfa of misinforming the Minister with regard to the quota needs of the under tens. [It would seem on that basis that they have not bothered to look even as far as the ports in your area for evidence that clearly contradicts that view].
 
Now apart from the argument that one can only rob Peter in the event that Peter actually owns the quota in the first place, and the Minister has clearly stated that fish quota is owned by Government and not therefore by definition, by private companies and individuals, there are a number of questions that need answering with respect to the holding and use of quota generally.
 
Apart from the amount of quota that working fishermen in the over ten sector need and utilise, there are two other segments of their part of the ‘quota pie’ worthy of consideration.
 
Firstly, there is the amount of quota that is, for want of a better expression, the icing on the cake and secondly, a further quantity, held by both fishers and non fishers that is clearly surplus to their individual requirements because it is available to lease to other users, specifically including the under tens.
 
Whilst we can argue about the icing part and how one should attempt to balance the difference between needs and wants, the latter segment of quota referred to is certainly where consideration should be given to a fairer distribution based on something other than a form of historic rights or who has the deepest pockets.
 
The suggested reconsideration is also on the basis that this element is currently being used as an economic weapon in an attempt to subdue both Nutfa and Government efforts to consider the aforementioned balance.
It is also the case that the PO’s curtailed any gifts or swaps to the under tens as soon as the Minister announced his intentions to even consider a reallocation. This action also underlines the need to get away from the current situation whereby the under ten sector is beholden on the mood of a number of private companies as to whether they can survive or not.
 
The cost of leasing quota follows an inevitably upward trend and you will have seen from reports in Fishing News that it is a problem for both under and over ten operators. You will recall the front page of FN last year with a picture of a Grimsby based pair team having to discard the best part of a 1000 box haul of Cod on the basis that it was not worth their while to pay to lease in quota to cover the catch. At the same time, a number of larger Scottish vessels were being put out of business through being unable to afford to lease quota to maintain their businesses.
Although you would struggle to make up such situations, it begs the question of who actually sets the price of the quota?
The PO’s put themselves forward as caring for their membership and of course it is not that the quota wasn’t available to the aforementioned pair team. UK PLC had sufficient, or at least someone had sufficient quota to cover the catch, but only at a price, and in that instance, and no doubt many more that we don’t hear about, too high a price to make economic sense, hence the discarding.
 
I don’t need to remind you of course that when Government first mooted the idea some years ago of allowing under tens to lease quota “as a temporary measure to help the fleet in the short term”, NUTFA did highlight the potential threat in the long term of so doing.
Prior to leasing, the under tens benefitted from both gifts and swaps from the over ten sector as a matter of course. Whilst we have never considered this a viable long term method of supplementing the meager resources in the under tens, these benefits were gratefully received. At the same time, NUTFA recognized the desire of some under tens to lease quota to meet their individual financial requirements.
As predicted, we now have a situation where gifts and swaps have evaporated, leasing costs increase year on year, fishers are having to fish harder and make a reduced profit to pay the quota rent and on average, something of the order of 50% of leased quota is not fished due to weather and other constraints for smaller vessels.
 
Irrespective of our position as the representative body for the under ten fleet, we consider that this situation is neither tenable nor equitable and we can only hope that the Minister recognises that there should be an independent root and branch review, linked to an equal consideration of how to achieve a sensible balance of UK fishing capacity between the sectors within the available fishing opportunities.
 
It will also be important for this review to be undertaken before the proposals for Transferable Fishing Concessions in the CFP Reform Paper possibly come to fruition and finally cement this public resource as nothing more than a private commodity [although we are not far from this now in the UK]. I have little doubt that there are some out there who are hoping that the debate is delayed sufficiently for this to occur.
We sympathise greatly with Richard Benyon who has been put into an invidious position by the historic mismanagement of the quota issue in the UK. He has said on many occasions that if he was starting from somewhere in this regard, it wouldn’t be from here. It would seem sensible therefore for the whole quota allocation and access situation to be subject to an independent enquiry to be finally sorted out for the good of all concerned.
In the meantime, the Minister should use Section 15 to reallocate quota this year in order to protect under ten metre vessels from imminent disaster and to prevent any abuse of the system through holding an unfair advantage.
 
Also for your information, it is becoming increasingly clear that there is little if any appetite for the Community Quota Group Pilot that Defra sought to introduce recently.
Out of the 22 applicant Groups, six were chosen, ranging from Hartlepool in the north down and round the south east coast. There were none in the SW as the Cornish FPO, who had originally offered to run one, pulled out on the basis that they refused to include any reallocated quota in the scheme, thereby making themselves ineligible.
 
From the plethora of phone calls received, it certainly appears that the quota offers provided to the Groups, based on their previous individual track records, do not come close to what they have actually fished from the pool quota. I had e mailed Defra at the request of some members just to ensure that the offers provided were in fact all the fish quota that would be available. Defra has assured me that it is so although I gather that officials are touring the successful Groups in an attempt to persuade them to take up the offers.
Apart from any other considerations, the lack of an amount of quota at least equal to previous catches by the Group members does call into question the veracity and accuracy of the system of recording under ten metre catches bought in during the mid 2000’s under the Registration of Buyers and Sellers legislation. As you know, this puts the responsibility for reporting the landings of the under tens onto the shoulders of the first sale buyers.
We have never been comfortable with this approach, not only because it fails to give due responsibility to the fishermen themselves but also because there appears to be no checks on the effectiveness of the system. When we have questioned Defra with regard to their confidence levels in the data provided, they have only ever answered that it is the best they have. Hardly a ringing endorsement.
We take no pleasure at all in the apparent failure of the Community Groups. We do however maintain our view that there is no evidence that the introduction of a rights based system to the under ten sector will provide any lasting benefits but plenty of examples elsewhere in Europe and further afield that it will cause irreparable harm, not only to the fishermen themselves, but also to the wider fishing communities that they support.
At the same time, we recognize the need to consider a well managed and focused round of decommissioning for both sectors in order to address the outstanding capacity issues that Defra has failed to address over many years.
Any such scheme needs to also include the removal of quota linked to a fishing licence and not only the removal of vessel and licence themselves.
This has been the Achilles Heel of previous rounds of decommissioning whereby an over ten operator takes state aid to remove both vessel and licence from the Register yet is permitted to retain the quota entitlement.
He then has a choice of either becoming a ‘slipper skipper’, sitting back and leasing out the quota to working fishermen or using the state money to buy a more modern and efficient vessel with which to pursue his retained quota allocation.
 
It is little wonder therefore that the EU Court of Auditors was so critical of publicly funded decommissioning schemes across Europe. In the UK, by Defra’s own admission, they spent about £126 million on decommissioning in the over ten metre sector that in some cases actually increased fishing capacity.
In the event that we do manage to get a well managed and focused decommissioning scheme then it would provide a double benefit to the fleet. By decommissioning over tens, such a scheme would not only reduce the physical capacity of that sector but could also move the state aided quota acquired into the under ten sector to make a meaningful contribution to redressing the balance.
It would of course also be necessary to consider the balance between capacity and fishing opportunities within the under ten sector and as you know, NUTFA’s suggestion for an inshore PO type body begins to address this issue.
NUTFA will shortly be coming to a port near you, and everywhere else around the English coast to publicise the Inshore PO initiative, to answer questions in that respect and to take on board fishermen’s and others comments to hone the idea into a workable system. It will be of particular importance that we make clear that this idea differs from the standard PO model in one major respect, that it would not seek to allocate fishing rights to individuals but would ring fence, protect and manage the existing Pool quota in a more effective way. Management by fishermen, for fishermen.
There are the other benefits to the scheme that you are aware of and I am really looking forward to further refining the approach in discussion with the under ten fleet.
I was intending to also update you on CFP issues but suffice to say that NUTFA is fully engaged with the UK Government, the EU Commission and the Members of the European Parliament in this regard and are actively promoting real change to the current Policy in respect of the small scale fleet through the provision of a number of suggested amendments to the draft text of the next CFP and face to face discussions.

10.12.11: Community Quota Group Pilot Project Response

As an integral part of the Industry Working Group, set up by the current Fisheries Minister, and following the Defra consultation earlier in the year, the New Under Ten Fishermen’s Association (Nutfa) continues to be at the forefront in terms of seeking changes to the current imbalance of fishing opportunities.

Every reader of Fishing News will of course be aware of the extensive tour undertaken by Nutfa to give inshore fishers the opportunity to have their say in relation to Defra’s proposals for the introduction of fixed quota allocations (FQA’s), based on an individual’s track record, and have their say they did indeed!
Nutfa take their lead from these fishermen and continues to put forward a strong case for changes to the status quo, not least as under ten metre fishermen around the coast gave an almost unanimous thumbs down to the Defra proposals for individual FQA’s.
Jerry Percy, Chief Executive to Nutfa told Fishing News, “since fishermen heard of Defra’s recent proposal to undertake pilot projects based on FQA’s, we have been seriously overwhelmed by the number of calls from members and others asking what is going on.
Many of the comments suggest somewhat bluntly that as they expected, Defra are taking no notice of the response to the consultation by the fleet and are intent of pushing through their own agenda, ignoring the wishes of the majority.
Although it’s too early to talk about the proposed pilots in detail as Defra have yet to announce the basis for them, the under tens can be assured that Nutfa have made clear their opposition to the FQA route for their sector and remain unclear as to what Defra is seeking to achieve against such a solid rejection by fishermen during the consultation.
At the same time, everyone recognises that things need to improve dramatically and very quickly for the under tens and Nutfa have put forward their own ideas, based on the view of many around the coast, for an inshore PO, importantly based not on individual FQA’s but for the inshore sector taking over, improving and enhancing the existing pool system, genuinely managed by the industry, for the industry.
The level of frustration illustrated by so many calls from fishers at what they see as Defra just carrying on regardless and wasting yet more time whilst they struggle to survive is hardly surprising. We will continue to reflect the anger of the fleet to Government and demand a fairer deal for these fishermen. I hope the calls keep coming as it shows that fishermen are waking up to what is going on and that this is the last chance for us to finally get a fair deal for them for their futures”.

9.12.11: Need for Appeals Procedure

Defra’s recent proposals for the under ten sector are based on the allocation of individual quota allocations (FQA’s) based in turn on a boat’s (or more specifically, an individual licence’s) track record over the reference period between 2007 and 2010 inclusive.

During Nutfa’s extensive tour of English ports earlier this year, a very significant number of fishers around the coast asked what the situation would be as they had sold or bought a boat during the reference period or since and had therefore unknowingly sold away their track record or bought a boat without an appropriate track record. Indeed, no one had thought of this scenario at that time as under tens had never previously operated on an individual track record basis. Defra’s response during the consultation was that there would have to be an appeals procedure to consider cases on an individual basis.

Nutfa has recently made specific enquiries with Defra on behalf of a member who, like so many others, had changed boats (in this instance, the member had built himself a new one) and was now looking for a licence as he had previously sold his old boat and licence (and of course unknowingly, his long term and local track record). Did he go for a straight under ten licence without any track record on the basis that Defra’s proposals may not come in or should he hunt around for a licence with a suitable track record, should one actually be available, to ensure that he could actually go fishing from his home port?
Defra are unable to satisfactorily answer the questions posed and have merely suggested that the fisherman concerned will have to make a business decision in the real world, hardly a helpful response and not least when a suitable licence would be many thousands of pounds and yet could turn out to be worthless to the fisherman concerned, depending on the outcome of Defra’s ongoing pursuit of the FQA route for under tens.

Nutfa have also raised concerns regarding the time it will take for the recently publicised Defra FQA pilot projects to be implemented and trialled, especially against a background of numerous ongoing vessel transfers that will potentially leave long term and experienced fishermen with no track record as it goes with the boat rather than remaining with the fisher.
Nutfa estimates that there are literally hundreds of under ten metre fishermen around the coast that will be queuing at the appeals desk having unknowingly given up their local track record or bought a licence with nothing useful on it (and God knows what’s going to happen with licence transfers between England, Scotland, Wales and Northern Ireland!!) Defra have said that if you’ve bought a licence that turns out to have an inappropriate track record on it then you could potentially sell that track record to someone who needs it and use the money to buy something suitable locally!
A further question with regard to the fisherman above and others is in terms of the Appeals procedure, how would it work and where would the fish come from to continue to provide a livelihood in the event of a successful appeal?
It would, according to Defra, of course have to come from within the existing under ten metre pool. This in turn would further reduce the fish available to existing licence holders who would see their own FQA’s reduce to provide fish for every successful appellant.

Whatever happens, there are an increasing number of under ten metre fishers who are in licence limbo and urgently need some answers in order to be able to make informed business decisions or know whether they are even going to be in business in the future at all.

7.11.11: Nutfa provide details of their proposals for an Inshore Producer Organisation

The New Under Ten Fishermen’s Association (Nutfa) has reached agreement with Defra to pursue an initiative for the creation of an inshore Producer Organisation (PO) for the benefit of inshore fishermen, alongside the government proposals for community quota groups.
The inshore PO will however differ significantly from existing PO’s in one vital aspect, by maintaining the collective, rather than individual holding of quota.

Jerry Percy, Chief Executive to Nutfa said, “we have spent a great deal of time talking with Defra and others on the Industry Working Group in an attempt to find a route through the historic inequalities of quota allocation and management, in an attempt to get a better deal for inshore fishermen. It has been anything but easy, not least as civil servants and those that benefit from the status quo are never keen to implement change that will have an effect on vested interests. Defra have proposed community quota groups that Nutfa consider simply a way for government to privatise a public resource through introducing rights based management to the inshore fleet. There are any number of global examples that demonstrate time and again that small scale fishers inevitably lose out to larger and more powerful economic players with this approach.
We are all starting from anything but a clean sheet and unless there is a way for inshore fishers to ring fence and protect the existing pool quota as a first step, subsequently augmented by quota from other sources, equally protected, then we believe without doubt that fishermen will suffer in the long run”.
Nutfa’s proposals to Defra include taking an incremental approach, recognising that setting up an inshore PO is more complex than a simple community group, but at the same time, significantly more beneficial to under ten metre fishers once sorted.
Taking over the management of the pool quota as a first step will for the first time give under tens effective influence over their own destiny through management by the industry, for the industry.
Jerry continued, “this is not an easy process to explain in brief but this approach will allow an industry wide group to manage allocations for wider purposes than the MMO is permitted to do, it will be focussed entirely on industry needs and will give inshore guys a seat at the table on equal terms to the existing PO’s. It will include the reallocated and realigned species mentioned in the Defra proposals and with EFF and Defra financial support, along with membership fees in keeping with existing PO’s , will finally allow under tens to begin to develop a resource base that it is currently lacking. Of course we cannot hope to immediately achieve the same level of resources as PO’s enjoy at present but we have to start somewhere. You get what you pay for in life and it is little wonder that the inshore sector has been shafted so royally over the years when they have not recognised the need to have effective representation. An inshore PO will also need to develop resources for marketing as all concerned have realised that first sale prices to fishers in some areas are woefully inadequate”.
Comments from fishermen during Nutfa’s recent tour of ports confirmed the need for the inshore fleet to take charge of their own destiny, recognising that there are a number of issues that will need to be faced in the immediate future if the inshore fleet is ever going to become economically viable. Based on these comments, it is Nutfa’s view that whilst local community quota groups run the risk of pitting fisherman against fisherman and group against group, a single inshore PO would have the critical mass necessary to have a real influence on policy and procedures that have been for too long biased against them.
Issues that only an inshore PO can address fairly and favourably for under ten metre interests include dealing with potential latent and dormant capacity, the acquisition of quota, the protection of quota within the inshore “family, including avoiding aggregation by more powerful economic interests within the sector and being able to stand up on both the national and international stage in support of inshore fishermen.
Jerry concluded, “under ten metre fishermen need to realise that they are valid businesses and act accordingly. The current RBS catch reporting system is a failure and has seriously undervalued the landings of inshore boats. We need to take responsibility for recording and reporting our own catches, we need to collectively decide on access to fisheries because if we don’t you can be sure that others will! Importantly, fishermen need to understand that there is an alternative on the table to the community quota groups and although Defra support the idea, they only took one line to describe it in their recent proposals document. Fishermen really need to be telling Defra to support Nutfa to get the project up and running alongside the community schemes in order to provide a real and genuine alternative option for them.

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