30/03/15
​The Cornish Fish Producers Organisation Ltd (CFPO) is a producer organisation based in Newlyn, Cornwall. We have approximately 180 vessels (current membership list is attached for information) in membership ranging in size from 5 metre single-handed cove boats to beam trawlers over 30 metres in length. Our vessels use a diverse range of fishing techniques including trawling, beam trawling, crab/lobster potting, gill-netting, longlining, drift-netting, scallop dredging, ring-netting and hand-lining.
 
The CFPO is the largest regional fishermen’s organisation in England and represents the majority of over-10m demersal fishing vessel owners operating out of Cornwall as well as significant proportion of the active under-10m vessel owners.

We therefore fully appreciate and understand the full range of issues confronting DEFRA in this consultation.



Capping
It is a reality that there is a level of latent capacity in the under-10m fleet (both fin fish and shellfish). The level to which this latent capacity has the potential to undermine future management measures is unclear and unquantifiable at this stage.

A further capping round as proposed by DEFRA in the consultation paper is not supported by the CFPO. It is not a sensible way to proceed at this time, especially given the imminent landings obligation and the challenges it will provide. The relationship between capped licence regime and the landings obligation requirements have clearly not been adequately considered or thought through properly.

Alternative Approach
As an alternative we would suggest a change to the current fishing vessel licencing regime to permit then aggregation of under-10m licences with ovr-10m vessel licences.

This in effect would amount to an industry funded decommissioning scheme.

Overcapacity in the over-10m sector has been dealt with in the past through a combination of publicly-funded decommissioning and consolidation by vessel owners to match their capacity with their quota holdings. It is very important that the licensing policy that we advocate does not undermine the progress that has been made in this part of the fleet.

For this reason we suggest stringent safeguards are put in place for example that approval of any licence aggregation which involves under-10m and over-10m licences is subject to approval of a detailed fishing plan which would ensure that the fishing opportunities necessary were available to the vessel concerned.

A further restriction concerning shellfish would be necessary. The aggregation of licences onto any over 15m vessel holding a shellfish entitlement should not be permitted at this time. (Particularly given current Western Waters effort regulations).

It would be fundamentally important that this type of scheme does not undermine the progress that has been made in the over-10m sector.

Aggregation Restriction
In addition to this consideration should be given to a temporary restriction on the aggregation of two or more under-10m licences. The objective of this should be to prevent the further expansion of the high catching capacity sector of the under-10m fleet. In reality this part of the fleet developed rapidly in response to the arbitrary division of the fleet at 10m and the management pressures in the over-10m fleet.

The CFPO remains committed to full engagement with DEFRA on the sensible and practical management of the Under-10m fleet.