The Royal Society of Edinburgh (RSE) is pleased to respond to the Scottish Executive Rural Affairs Department consultation on the future of the Common Fisheries Policy (CFP). The RSE is Scotland’s National Academy of Science and Letters, comprising Fellows elected on the basis of their distinction, from the full range of academic disciplines, and from industry, commerce and the professions. This response has been compiled by the General Secretary with the assistance of a number of Fellows with substantial experience of fisheries and marine science.

The Society agrees that there is a need to reform the CFP and has concerns about the present stock levels of many species of commercial importance, and the potential negative socio-economic impacts that could result from partial or total collapse of this sector of the economy. While many aspects in the Green Paper are to be welcomed, including the integration of improved ecosystem-based science into fishery management, the Green Paper lacked any market or commercial analyses of the demand for wild and farmed fisheries products. The current policy proposals could be a recipe for a continued decline of stocks, albeit at a somewhat slower rate than in the recent past. It will be important that in reforming fisheries regulations that the regulations should be simplified and made more transparent and accountable and work with, rather than against, market forces.

The specific questions identified in the consultation document are addressed below:

The European Commission Green Paper (COM(2001)135)

Areas of emphasis

The state of the main fish stocks
The Society agrees that many fish stocks of commercial importance are at the threshold of sustainability and that urgent action is required.

With regard to the causes, the regulations on mesh size and "Total Allowable Catches" (TAC) have been largely discredited, possibly contributing to, rather than helping, safeguard over-fishing. The mesh size regulations have not been uniformly enforced across the Community and the TACs have resulted in the discard of under-size fish and non-target species with negative ecological impact on populations. With regard to the use of closed areas and closed seasons, these have had some success. However, as happened with TAC setting, often the scale of closure recommended by fisheries scientists has not been implemented in full.

Extensive research and knowledge in marine ecology does exist, but most of that which does exist may be found in institutions that are not primarily charged with providing advice for fishery management. Under the revised policy proper communication across areas of scientific responsibility would help to ameliorate the situation. In addition, fishery science has not been well supported by Research Councils and most Governmental funding for fishery science goes towards the provision of routine statutory advice. If the integration of the environmental dimension is to form a greater part of the CFP, then funding should be reviewed to allow for research of more ecosystem-based management measures.

The environmental dimension
The Society welcomes the environmental dimension coming at the top of the list of priorities with the state of the main fish stocks. This inter-linking of the fish stocks with the marine environment is very important and the CFP should recognise that fish stocks depend upon the environment which in turn depends for its quality on a sensible management of those fisheries.

With regard to the statement that "many problems in the marine environment are not due to fishing activities only and that fishing has suffered from environmental damage", it should be recognised that fishing activity is the major anthropogenic influence in many marine systems and that many environmental concerns could be remedied rapidly through policies of large-scale closure or partial closure (e.g. through the limitation of certain gear types) of the fishery. A major uncertainty that may impact on future sustainability of some fisheries, however, is possible short- or long-term influences of climate variation.

Fleet policy
The Society agrees with the three conclusions in this section. In particular, that funding for technological progress, and subsidies to the industry, have far outweighed funding in areas of research appropriate to understanding the effects on the ecosystem.

Monitoring and control
The Society believes that monitoring and control would be made easier and more cost-effective if there were physical restrictions or partial closure to fishery access.

The economic and social dimension of the CFP
The document refers to the European Union PESCA programme which was a very small highly targeted programme, administered locally, with close stakeholder involvement. PESCA was a minor programme and its most innovative aspects were poorly used, but the latter was largely due to its small size which meant main line aspects were tackled first. In Scotland it was generally perceived as very positive and despite its small size, much more small-community friendly than the Financial Instrument for Fisheries Guidance (FIFG). One very valuable aspect was the emphasis on coastal zone management and funding of first efforts at an Integrated Coastal Zone Management Plan for each PESCA area. This had not been attempted in Scotland before. By involving all stakeholders, in some cases, it resulted in both valuable and useful documentation and also a very salutary and positive experience for fishermen, aquaculturists and those promoting tourism who were all forced to accept that the coastline was a multi-use zone.

Aquaculture
In relation to aquaculture, the paper acknowledges the contribution of the industry to economic development, but not its size and significance. In Scotland aquaculture contributes 40% of all agricultural exports, worth £280M at farm gate and over £600M as processed product. As such it is very much larger than sheep or cattle production and dwarfs fishing per se. The situation is even more marked in rural Greece, where only tourism is bigger.

This failure to recognise the scale, importance and potential growth of aquaculture in comparison to the inevitable shrinkage of the fishing industry means that it does not receive sufficient support as a major economic engine in rural communities. For example, although salmon is the largest single livestock production product in Scotland with numerous veterinary staff employed, neither of the two Scottish Veterinary Schools has any investment in aquaculture research.

There are great concerns for the environmental effects of aquaculture. However, research into these concerns should be funded to a considerably enhanced degree, in an enabling, rather than in the currently negative fashion; and, particularly, into the three-way interaction between cultured fin fish, wild fin fish and the environment. This aspect is not sufficiently emphasised in the Paper.

Proposed objectives for the CFP
The Society believes that the CFP does need a new set of objectives. It was unfortunate that the Treaty establishing the European Community did not have a specific fisheries chapter. By deriving the objectives from the Common Agricultural Policy, the promotion of technical progress has resulted in marked increases in the efficiencies of fishing boats and gears often to the detriment of fish stocks, and there was no reference to environmental management.
The new proposed objectives are, therefore, to be welcomed and the objective of "sustainable fisheries that ensure healthy marine ecosystems" is rightly placed first. The objective 'to improve the quality and amount of data to support decision-making and to promote multi-disciplinary scientific research which will provide scientific information and advice on fisheries, associated with ecosystems and relevant environmental factors, is also important.

Policy options

Strengthening and improving conservation policy
The Society suggests that the Community should consider adopting the successful Icelandic approach to fisheries management. All the catch should be landed and quotas should be set for the number of fish caught, regardless of size and species. It is the mortality of each species which is the biologically important parameter in any population model. The movement towards multi-annual, multi-species and ecosystem orientated population models is, therefore, to be welcomed. However, this will require much more basic research within the member States. Such models should be used to predict the likely proportion of species caught in different geographical zones which can be subsequently verified from catch statistics. Discarding fish should become an illegal practice and subject to heavy fines. This measure, in itself, will alter the economic benefits of different fishing methods and encourage a shift to more ecologically friendly capture techniques, such as long-lining, which only takes large fish and minimises by-catch. It is only through an assured sustainability of stocks that the socio-economic objectives - important as they are - can have any foundation

Promoting the environmental dimension of the CFP
The integration of the environmental dimension within the CFP is to be welcomed. There should, however, be a much greater recognition of biodiversity. Given the Convection on Biological Diversity, which applies equally to biodiversity in the sea as on land and fresh waters, there should be more mention of biodiversity in the consultation paper.

Promoting animal and public health and safety in the fisheries sector to ensure consumer protection
In order to improve the market price for wild caught fish, research is needed on biological markers on freshness. Fresh fish should be subjected to a labelling system for date of capture and shelf life according to method of storage. Products should also be compulsorily labelled as wild caught fish or of farmed fish. The technological capacity already exists to introduce such a food labelling system, which should lead to a higher priced but more consistent quality product. Fish should also be randomly tested for levels of key pollutant residues to give consumers greater confidence in food safety.

Improvements are also needed in the current EU disease control arrangements for fish. Current policies pay little attention to the uncontrolled movement of aquarium fish (one of the most dangerous of all potential infectious routes) and also apply controls to aquaculture adapted straight from terrestrial management, which take little account of wild fish migration, nor of shared waters with third countries. The implementation of the present policy also differs from country to country, both structurally (for example, there is no compensation for seizure of healthy fish in UK, but full compensation in Denmark) and in terms of quality of enforcement.

Fleet policy
Subsidies to fleets should be removed and market forces allowed to determine the size of fishing fleets and any subsidy should only be to ameliorate local unemployment impacts.

Improving Governance within the CFP
The Society welcomes the establishment of regional advisory committees in association with elements of decentralisation which should lead to more involvement of stakeholder groups in decision-making. The Society also agrees with the need for better integration of scientific advice into the decision-making process.

Monitoring, control and enforcement
The Commission should seek to establish a European-wide Fisheries Protection Service, applying common policy and common level of enforcement. More widespread use should also be made of temporary closures of fishing grounds For example, in Iceland there is a random inspection of fishing vessels, and the ground is immediately closed if more than 25% of the fish are under-sized.

Strengthening the social and economic dimension of the CFP
The provision of fisheries products through aquaculture plays a relatively minor part in the Green Paper and contrasts with the policy of the Norwegian Government. Norway plans to substantially increase the value of sea products so that it overtakes the oil and gas sector in terms of net contribution to GDP within 30 years. Although the Commission is right to stress environmental problems, these can be overcome with appropriate technology and management policies, for example with respect to waste management and recirculating systems. Greater use should also be made of seafood products, for example, pharmaceuticals could be obtained from the offal which is currently discarded. Overall, more research is needed in the aquaculture of alternative species to offset current reliance on salmonids and on alternative sustainable feeds which are not dependent on capture fisheries.

UK priorities
In general, the Society supports the UK set of priorities. They strongly reflect a more holistic approach to the management of fisheries and the marine environment. The only other issue which could be pursued in the context of this review relates to marine protected areas. In Australia and New Zealand the fishermen originally opposed such protected areas, but they have now come to realise that these areas can 'seed' the surrounding fisheries, and are important breeding grounds for many of the commercially important species. The UK has no particularly effective legislation for marine protected areas. The concept of the Marine Nature Reserve (MNR) in the 1981 Act has been so difficult to apply that there are still only a handful of MNRs around the UK coast after 20 years. Movement to make it easier to establish marine protected areas, whether they be MNRs or some other form of designation, may in the long term be seen to be an important plank in the conservation of biodiversity and the sustainability of a viable fishing industry.

Additional Information
In responding to this inquiry the Society would like to draw attention to the following Royal Society of Edinburgh responses which are of relevance to this subject: The EU policy on Biodiversity (May 1999); Conservation of Salmon and Sea Trout (August 2000); Protecting and Promoting Scotland's Freshwater Fish and Fisheries (August 2000); Sixth Environmental Action Programme (May 2001) and The Nature of Scotland (June 2001).

June 2001

Further information is available from the Research Officer, Dr Marc Rands