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Alternative management systems for the UK fishing industry
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Ocean & Coastal Management, Vol. 35, Nos 2-3, pp. 185-199, 1997 ~) 1997. Published by Elsevier Science Ltd All rights reserved. Printed in Northern Ireland S0964-5691 (97)00033- 1 0964-5691/97517.00+0.00
ELSEVIER
Alternative management systems for the UK fishing industry J e r e m y Phillipson I and K e v i n C r e a n 2 1School of Geography and Earth Resources, Universityof Hull, Hull HU6 7RX, UK 2Universityof Hull International Fisheries Institute, Hull HU6 7RX, UK
ABSTRACT The paper considers opportunities for institutional development within the UK fishing industry that aim to engender a more meaningful incorporation of fishermen's organisations within the policy system. Special attention is given to the location of responsibility within the policy process. This involves an exploration of an alternative approach to consultation and the scope for delegation of management responsibilities to fishermen's organisations. Mechanisms to improve coordination among fishermen's organisations and to strengthen their internal architecture are also considered. The analysis raises important questions to inform the continuing debate over the development and structure of devolved management systems, in particular regarding the assumptions underlying user participation and the representativeness, capabilities and aspirations of fishermen's organisations. ~) 1997. Published by Elsevier Science Ltd.
1. INTRODUCTION: U S E R PARTICIPATION IN T H E UK The UK fishing industry consists of a widely dispersed range of sectoral and regional interests. Scotland currently dominates the fishing scene in terms of its share of landings by volume, and this is only partly offset by higher unit values for landings and a slightly higher number of regularly employed fishermen south of the border. The northerly shift in the centre of gravity primarily took effect in the late 1970s, with the exclusion of deep sea fleets based largely on Humberside from distant water fishing grounds through the establishment of 200-mile Exclusive Economic Zones. Regional contrasts are also expressed in institutional arrangements for fisheries administration and political representation, which promulgate the 185
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sense that this is a deeply divided industry on several fronts. From an administrative point of view, there is a division of management responsibility between provincial government offices in England, Wales, Scotland and Northern Ireland, although within these arrangements, the Ministry of Agriculture, Fisheries and Food (MAFF) remains arguably primus inter pares. This situation, while offering arguably more sensitive management approaches, does not facilitate a united industry front or effective industry representation, particularly when regionalisation is along distinctly political, territorial and cultural lines. The administrative cleavage is emulated within the framework of professional organisations serving the industry, and principally through the existence of two separate 'national' representative federations in Scotland (the Scottish Fishermen's Federation) and England and Wales (the National Federation of Fishermen's Organisations). In addition, the administrative division does not lend itself to an effective consultative system; within the provinces, the industry could be seen to be one step removed from important decisions within MAFF. As a whole, there is a marked need for a more coherent and integrated framework for the management of fisheries in the UK, which would provide the industry with a strengthened role within the policy process and also rectify existing weaknesses within the consultation system. It is widely acknowledged that the organisations that make up the industry are not sufficiently involved within the management system; to date, their knowledge and expertise have been under utilised and undervalued. Whereas the assimilation of fishermen's organisations within the policy process is not a panacea for the problems facing the industry, it is clearly of importance to fishermen, on whose cooperation rests the successful realisation of management policy. Participation is arguably integral to a legitimate and responsive management system. Therefore, this paper assumes that organisational arrangements for policy formulation and implementation can determine partly the success of fisheries management; consideration is given to the development of some potential institutional designs for a more meaningful participation of fishermen's organisations within a UK context. The UK has made considerable progress in terms of devolved management and user participation at the level of policy implementation, through two important organisational forms--producers' organisations and Sea Fisheries Committees. Producers' organisations are fishermen's organisations with a marketing remit, which attempt to ensure that fishing is carried out along rational lines and improve the conditions for sale of members' catches. This occurs through product grading, supply management and through operation of the EC's minimum withdrawal price
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system. Of special significance to the debate concerning delegated m a n a g e m e n t is the fact that the 19 producers' organisations in the U K are also responsible for the administration of sectoral quotas. For inshore fisheries in England and Wales, m a n a g e m e n t is devolved to the 12 regionally based Sea Fisheries Committees comprising almost equal numbers of local authority and fishing industry representatives. Considerably less progress has been made towards effective user participation in the area of policy formulation; this signifies a clear paradox within the UK m a n a g e m e n t system where high levels of delegated responsibility for policy implementation are contrasted with weak levels of consultation over the formulation of fisheries policy. In fact, with both producers' organisations and Sea Fisheries Committees, the full benefits of user participation are diminished, given that their responsibilities are determined by central government. Furthermore, when it is considered that fishermen's organisation's in general are denied an effective consultative role in terms of policy formulation, the potential value of any existing 'participation capital' is thus reduced. Existing consultation arrangements between the UK government and industry lack significance, transparency and formality. Such deficiencies of negotiation are compounded, if not largely initiated, by the fragmented framework of industry representation and the lack of consensus between the two main representative fishermen's federations. Both provide an umbrella representation for a mosaic of fishermen's associations (FAs) located at local, regional and sectoral levels. Not all associations are federated for policy and financial reasons. Indeed, there appears to be an accentuated tendency for industry organisations to fragment during conditions of crisis, when strain is placed on the sheer diversity of sectional and regional interests involved. Clearly, there is a need for institutional reform. Integral to the alternative institutional designs considered in this paper is an in-depth analysis of the structural and strategic characteristics of UK fishermen's organisations together with their positioning within the wider decision making framework.t The alternative systems represent a potential institutional challenge, but they are not too distant from the current political and institutional realities within the UK fishing industry. Indeed, t The analysis is based, in part, on the returns from a questionnaire survey of 164 fishermen in northern England, southern Scotland and Northern Ireland, which sought their response to issues relating to the location of management responsibilities, the strengths and weaknesses of fisheries related organisations, regulatory measures inter alia. Follow-up interviews were also held with representatives of some 40 key organisations representing both industry and government. For further information on the results and the survey methodology, see Ref. 1.
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they embrace the existing contribution of fishermen's organisations rather than promoting radical restructuring or the creation of new organisational forms. The paper first outlines the principles that underlie the alternative management approaches, drawing upon the supporting evidence of the resource users. The designs are then elaborated, and finally, there is a discussion of the key challenges that would face their implementation. This process of model building informs the continuing debate on the development and form of devolved management systems, paying particular attention to the assumptions underlying user participation and the representativeness, capabilities and aspirations of fishermen's organisations.
2. MODEL PRINCIPLES The alternative management systems address organisational needs within the UK. They are underpinned by a number of interrelated key principles, each consonant with optimum institutional requirements of user participation. They recognise a need for a more meaningful system of consultation between industry and government as well as greater cooperation among fishermen's organisations (FOs). The models sanction the delegation of management responsibilities to FOs, and, where responsibilities are already partially delegated, there is an exploration of opportunities for refinement and extension of roles and for strengthening the internal architecture of fishermen's organisations.
2.1. Consolidating co-responsibility The alternative approaches involve the ascription of additional responsibilities to FOs. Where responsibilities are already shared between state and industry, opportunities to consolidate such arrangements are considered. A delegation of facets of policy implementation to FOs is seen by many fishermen as an important component of effective management. Most active fishermen believe that FO-based management would have a beneficial effect on compliance levels with quota and gear rules, illegal landings, the accuracy of catch data and the fairness of rules. At the same time, it is clear from Tables 1 and 2 that a sharing of management responsibilities between government and industry is the most popular option, rather than the allocation of total management control to the industry. This demonstrates, in part, an acknowledgement of a number of specific management needs relating to fishing resources, including the need
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TABLE 1 Preferred management system (%)" 1st choice
2nd choice
3rd choice
4th choice
No response
9.1
31.1
28.7
28.0
3.0
7. 9
31.7
25.0
32.3
3.0
47.0
29-9
14-0
6.1
3.0
34.1
22.0
18.9
22.0
3.0
Central government controls all aspects of management but where the industry's advice is listened to Local government controls management but where the fishing industry's advice is listened to Management responsibilities are shared between government and fishing industry Fishing industry has control over all aspects of management
"Four management systems were proposed, and 164 fishermen were asked to rank them from 1 to 4 in order of preference. For each alternative system, the figures indicate the percentage of 1st, 2nd, 3rd and 4th choice responses.
for some overarching view of a transboundary resource, an awareness of the need for mediation between highly competitive and often conflictive interests and an appreciation of certain organisational needs within the FOs themselves, which could threaten the viability and strategic development of a management system if not steered or supported. TABLE 2 Allocation of management tasks (%)" Tasks
Stock levels Technical measures Enforcement Licensing Decommissioning Quota allocation/management Monitoring of catches Fish quality and price control Average percentage
UK EU POS Local Federations government FAs
54.3 54.3 75.6 73.2 63.4 41.5
3.0 5.4 6.4 4.8 23.7 2.4
Local SFCs authorities
34.2 24.4 19.5 17-7 15.9 57.9
19.9 25.9 5.4 7.8 10.2 21.1
20.5 25-4 7.2 7.8 10.2 17.4
4.2 6-0 9.7 6.6 10.2 3.6
16.9 20.5 12.8 7.2 6.0 9-6
59.8 34.8
3-0 38.3 6.6 53.0
15.7 21-8
12-6 8.1
10.9 5.4
13.3 9.0
57-1
6.9 32-6
16.0
12-6
7.1
11.9
"164 fishermen were asked to identify where management tasks should be located across the organisations present within the UK. Figures represent the percentage of respondents choosing an organisation to perform a particular management task, either in combination with another organisation(s) or on an autonomous basis
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Just which FO should prevail as the key partner in policy implementation can be debated. It can be noted, however, that one category of FO--producers' organisations--already features highly within the perceptions of fishermen in terms of the existing organisational mix and in any potential devolved management approach. In part, this reflects a familiarity with the existing division of labour within the industry, where producers' organisations are seen as 'management' organisations.
2.2. Consolidating the internal architecture of fishermen's organisations As a whole, whereas FOs display adequate capabilities to perform their respective roles, some organisational capacities would require consolidation in order that they might function more effectively in the existing policy system and in some of the alternative management designs. For example, the representative capacities of FOs can be criticised for a number of reasons. Frequently, the managerial backbone of FOs is provided by a small number of shore-based individuals, sometimes retired fishermen, who are not necessarily seen to reflect the views and attitudes of the 'fish room'. Within those federations and larger fishermen's associations that embrace an internal hierarchy (regional committees, branch structures), the twoway flow of information between members and the organisational elite can appear cumbersome and ineffective. Some fishermen are critical of power imbalances within FOs that may favour particular regional or sectoral interests. The two main national federations, for example, display membership nuclei from the main fishing ports, and from company or producer organisation vessels. The interests of smaller vessels, often with different priorities and a strong sense of independence, may be relatively marginalised within the organisational set up. Some mention should also be made of Sea Fisheries Committees, which are important in the context of user participation. The committees include Ministry-appointed members from industry, chosen for their expertise and not for a specific constituency interest. For a significant minority within the inshore sector, this is seen to be undemocratic, and a recent extension of the Committees' membership to include environmental experts has not helped to improve the level of respect. Finally, FOs in general are sometimes criticised for their lack of appreciation of policy process and the appropriate dynamics of interaction in decision making and negotiation. Linked to the question of representation is that of membership, and specifically non-membership of FOs, which may arise from some of the criticisms already outlined. Non-membership of fishermen's association and federations does bring into question their representative credentials.
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In the case of producers' organisations (POs), maintaining membership levels on a voluntary basis leads to difficulties in introducing strict internal marketing and disciplinary regimes. Whereas many fishermen view POs as managing and allocating quotas effectively, a significant minority believe that POs do not add value to their member's catches through effective marketing, and that when the in-house rules of POs were broken, there was little or no penalty.t M o v e m e n t of vessels out of the PO system or into other POs is a problem when a PO must maintain its aggregate vessel track record (which determines quota allocation) and financial base. Resource levels inevitably prevent some fishermen's organisations from playing a more active role; for POs, this may hinder marketing initiatives, and some small fishermen's associations are excluded from federation membership on this basis.
2.3. Consolidating linkages: consultation, cooperation, coordination Widespread perception of existing consultative arrangements within the UK is not good. The vast majority of active fishermen cite the government's unwillingness to listen to the fishing industry as being a basic causal factor of their problems. For many, industry advice is seen to be untimely and ineffective, and this is certainly partially attributable to a lack of formality, regularity and transparency within the existing system. In part, it is a product of the general importance that is attached to industry participation within the UK, as well as capability issues concerning lack of consensus and coordination. There is a clear institutional need for a sound and integrated institutional framework that incorporates a more fundamental consultative approach and the opportunity for enhanced cooperation between fishermen's organisations. Here, industry would be encouraged to unite or face a lost opportunity for a more proactive role in the policy system. Such principles form the backbone to the institutional approaches outlined below. 3. A L T E R N A T I V E M A N A G E M E N T SYSTEMS The alternative institutional designs consider how fishermen's organisations can be restructured or repositioned, so that they function more efficiently with respect to decision making and policy implementation t Mindful of these problems, the UK POs are to adopt a 'code of conduct' where the behaviour of individual members of POs would come under the scrutiny not only of the membership of that PO but also the 'peer review' of the UK Association of Fish Producers' Organisations.
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functions. Attention first turns to two potential foci for the delegation of management authority, producers' organisations and Sea Fisheries Committees (SFCs), given their existing prominence at the level of policy implementation. Consideration is then directed to the linkages within the policy system and, in particular, the incorporation of FOs at the level of policy formulation. This involves the development of a formal system for consultation between central government and the fishing industry and a means for promoting greater coordination among management organisations at the regional level.
3.1. Producers' organisations POs are perhaps obvious candidates for the ascription of additional management responsibilities given their existing remit of quota management, which is already consonant with the principle of devolved management, and their EC-wide status. They also feature highly in the perceptions of active fishermen in terms of existing or enhanced functions. There are limitations, however, to the level of management authority that could be delegated to POs. In part, this relates to capability issues addressed earlier, as well as to a lack of geographical coherence and noncomprehensive membership. More importantly, they are essentially commercial organisations dedicated to the pursuit of members' interests rather than resource management objectives. Certain sectors, notably the small boat interests, which are effectively excluded from PO membership, remain vigorously opposed to the idea of POs receiving additional responsibilities on this basis. Paradoxically, POs have tended to be entrenched in quota administration issues and, partly for this reason, have underplayed their commercial potential. In practice, it is also difficult to envisage what new management roles might be offered to POs, except perhaps for administering effort quotas in addition to, or in lieu of, catch quotas. Arguably, greater benefits might accrue to the management system if POs were to seek to maximise their existing potential in relation to commercial activities rather than the assimilation of new roles. This might involve a more proactive engagement in marketing initiatives with the assistance of European Community funding mechanisms. For example, they may have scope for investment in processing facilities and in the handling and selling of fish, or have opportunities to implement a more effective system of supply management. It is likely that if the PO leadership took the initiative in market development, this would in turn lead members to adopt a more positive attitude to supply management. A strengthened role for POs could also involve offering financial services to
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members or a greater interest in the 'ring fencing' of members' track records. Here, POs have the option to purchase the track record of a member leaving the industry, which can then be absorbed by the remaining vessels or held in a reserve fund for allocation to new entrants. Finally, to take on a more holistic commercial approach or new management responsibilities, POs might seek to strengthen their institutional structure through: • structural rationalisation and the creation of fewer and larger POs with corporate, as opposed to cooperative, forms of organisation, this would encourage benefits of economies of scale with regard to capital and senior management would be better positioned to take a more independent and strategic perspective; • improving their disciplinary record; possible methods may include independent arbitration panels or a code of practice; • strengthening their representation of the small boat sector; • increased transparency of behaviour through participation within Area Management Committees (see below).
3.2. Sea Fisheries Committees
Given their existing central position in inshore fisheries management, SFCs offer another potential focus within which to vest responsibility. Several possibilities exist for the development of the role of SFCs. They could be retained as organisations responsible for inshore fisheries management (with limited regulatory functions and byelaw making powers) and matters relating to marine conservation. Alternatively, some redefinition of their role may allow them to adopt more specialised functions, rather than attempting to perform both coastal zone management and fisheries management tasks. As with producers' organisations, there is also a considerable case for consolidating the existing devolved management functions of SFCs. A number of developments might serve to soften the negative effects of the limitations within which SFCs operate, including a widening of their powers and the administration of inshore licensing. At present, their regulatory powers are both rigid and slow to resolve problems. Greater flexibility of management response would arise from the adoption of precautionary and emergency byelaws. Statutory local organisations for inshore fisheries management apply only in England and Wales; the extension Of the principle, if not the precise form, of SFCs to Scotland and
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Northern Ireland would help to consolidate the basis for devolved management around the whole of the UK coastline.
3.3. Advisory Panels and Area Management Committees Whereas the restructuring of fishermen's organisations would improve their functional performance or extend their role in terms of policy implementation, there is a further need to provide a more structured, coherent and transparent system of consultation between industry and central government and to strengthen the framework for policy-making. One potential approach to meet this organisational need might involve a two-tier integrated framework, incorporating a series of what can be termed Advisory Panels (APs) and Area Management Committees (AMCs). 2 A system of APs, embracing AMCs, might help the formulation of broad strategies for the development and management of the industry as a whole. Within such a system, fishermen's associations and their national federations would continue to function as key political organisations representing members' interests at local, regional and national levels of negotiation. The political role of the national federations would, however, be elevated through their key positioning within the framework. APs would provide arenas for industry and government to discuss all matters relating to fsheries management, including the development of policies and regulations relating to conservation, marketing and structural management, as well as biological, economic, social or environmental issues. Government could present policy proposals to the appropriate panel(s) for discussion at the earliest possible opportunity, and certainly well in advance of their intended implementation. In turn, it would benefit from the professional advice and proposals from industry concerning resource issues. In terms of spatial extent and geographical location, the system could involve three APs constructed along ICES areas (IV; Via and b; VII) (see Fig. 1). Utilising ICES areas would place less emphasis on territoriality, which might help to avoid regional disputes. It would also provide the opportunity to relate advice to stock management information currently collected on an area basis. It would be particularly useful if AP meetings were timed to coincide with discussion of proposed, and subsequently agreed, Total Allowable Catch/quota allocations, thus reinforcing the notion of resource management as the central focus of their deliberations and enhancing existing consultation arrangements for these issues. In order to facilitate greater cooperation among different interests within the fishing industry and the opportunity for more integrated
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management approaches, it would be appropriate if panel membership was broadly constructed, including representation from central government, harvest and post-harvest sectors and statutory environmental organisations. However, in order to convey maximum legitimacy, the balance of membership should favour the harvesting sector. An essentially political remit would suggest an emphasis on federations and fishermen's associations in the 'seating' arrangements. As a whole, the intention would be to provide a transparent, timely and formal consultation process. Crucially, the system would also offer greater regional sensitivity in the policy generation system. It is also the case that the delineation of APs in terms of ICES areas could openly suggest that they might ultimately evolve or be replicated to include the fisheries management apparatus of other member states linked to the particular
o
500 km
ADVISORY PANELS
I~
V,
VII
(-
[
.:.....,.,...%.....
AREA M A N A G E M E N T
IV
ii iiii i.e. ;.fi
COMMITTEES :i a N E. Scotland i b Anglo- Scottish C E a s t Anglio
Vl
West of S c o t l a n d
VII a f +g e +h d
I r i s h Sea C e l t i c Sea Channel West Channel East
Fig. 1. Advisory Panels and Area Management Committees.
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J. Phillipson, K. Crean
ICES area or 'regional sea'. 3 This would offer an important step towards a more regionally sensitive policy process throughout the EC as a whole. To provide greater co-ordination among management organisations at the regional level within the UK, a case might be made for the creation of a sub-set of AMCs. The AMCs would encourage liaison among local organisations, including POs and SFCs, and, in turn, facilitate more coherent and transparent management approaches and initiatives. Through overlapping membership, they could also be used to generate local information and expertise to enhance the advisory functions of the APs. Within both AMCs and APs, membership would generally comprise primarily those with a significant management interest in the respective ICES areas and sub-areas. In both cases, interests representing the 'region' would be present. AMCs, however, would be smaller in size than the APs and their membership focused on management organisations in the harvest sector, with the chair taken by a senior representative of one or other (or, in some cases, both) of the federations. AMCs could be based on ICES sub-areas (possibly IVa; IVb; IVc; VI; VIIa; VIId; VIIe&h; and VIIf&g), again to place less emphasis on territoriality and to link AMCs to identifiable fish stocks (at least in statistical data terms). They could also benefit from attendance by the regional fisheries inspectorate and government scientists, together with representatives from local government and downstream sectors as observers or through co-option. It would be invaluable for positive linkages to be generated between APs and AMCs, on the one hand, and between different APs and different AMCs, on the other. Interaction between the organisations might be encouraged through careful timetabling of meetings to ensure a phased cycle of discussion, so that issues raised at one AP or A M C meeting, which are of relevance to other neighbouring groups, could be passed on for further discussion either at the same level or raised from AMC to AP level.
4. ISSUES OF IMPLEMENTATION The alternative management systems elaborated above represent possible avenues through which a number of institutional needs may be addressed. Whereas specific details may require refinement and elaboration, their underlying objectives are sound. The proposals are certainly not overly radical; the existing hegemony remains intact, through recognition of established boundaries of responsibility and the positioning of the leading fishermen's organisations. Overall control over fisheries management remains with the central state and there are no significant challenges to
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existing forms of property rights. Whereas ultimately, radical reform may be what is required, the realities of institutional change and the legitimacy of organisational development necessitate an incremental and practicable approach. At the same time, if there is acknowledgement of the institutional and political context, within which the model designs would operate, the systems do represent significant challenges. Implementation of the alternatives would pose a number of problems. Perhaps the greatest is found in a general reluctance on behalf of state and industry for any significant shift in the loci of responsibility within the policy system. Both lack trust in each other. The state admits that it is reluctant or unable to fully assimilate FOs within the policy process, given widespread division and politicisation among FOs and doubts relating to the representativeness of their membership and their capacity for internal discipline. This attitude is also symptomatic of the wider political culture within which approaches to governing and user participation are framed. When compared to other European states, such as Denmark or Norway, the UK appears more centralist and government led. Existing forms of user participation and delegation are clearly centrally determined, controlled and structured. Proposals that work against this established style of governance clearly face difficulties, particularly when one considers the lack of economic and political power shown by the fishing industry within the UK. Whereas it is doubtful whether government would concede effective responsibility to FOs, it is also uncertain whether the industry is in a position to induce change itself. This is not solely a question of capabilities, divisions, levels of professionalism or even simply a resistance to change p e r se. For large sections within the industry, there is unease with suggestions of institutional change. There are a number of reasons for this situation. Institutional change is simply not a high priority for many FOs or government. There are clearly more pressing problems, such as fleet overcapacity and structural adjustment, regulation issues and fisheries resource levels. For many FOs and fishermen, conceptualising new institutional forms is too distant from their day-to-day fight for survival. Numerous FOs remain understandably preoccupied with quota, resource or membership levels. Aspirations of FOs and fishermen remain modest and reflect organisational capabilities and resources. Leading FOs, already positioned favourably within the industry set-up or decision-making framework, are anxious to protect the s t a t u s q u o and prevent any erosion of their position. Fishermen's federations, with established informal channels to government, would certainly be concerned at a widening of the scope for representation within any new formal consultative arena. Already, some are concerned that too many competing voices are
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approaching central government and thus undermining the 'national' representation of the federations, Formal assimilation within the policy process may be seen to tie the hands of the industry, which has traditionally performed a role of resistance. Furthermore, there is concern with becoming more responsible for a management system, which already faces crisis, and for a range of socially unpopular decisions in the short and long term. Others are sceptical that there would be a real change in attitude towards user participation and that some of the structures elaborated above may simply be no more than talking shops, with little real impact on the policy system. Any implementation of the alternative models would require a feasibility study and further definition of detailed structure and design. Here, the wide range of choices and dilemmas surrounding the architecture of devolved management systems in general, such as the scale and breadth of representation, would come to the forefront. Elaboration and negotiation of such detail would itself be a significant challenge, especially in reaching agreement over the formula for representation on APs and AMCs. Indeed, whereas AP membership may, on paper, appear to be representative of interests across the board, this would clearly be a matter for much debate and would lead, in practice, to difficulties with respect to obtaining legitimacy for the advice generated. Would it suffice for the AP to make recommendations on the basis of (narrow) majority agreement? How could the decision-making process be configured to engender confidence in the outcomes? It is possible that the existence of Area Management Committees might smooth the decision-making processes at the AP level but, in their role as co-ordinators at regional level, they could be confronted by serious representational and consensus limiting factors. Implementation would also raise a number of practical concerns that may prove barriers to successful user participation. Arrangements for consultation may, for example, place an unacceptable burden on the established decision-making procedures in both Whitehall and Brussels. Although the additional financial burdens are unlikely to be significant, the question of who pays could prove contentious. Both government and industry would be beneficiaries of the system; the government would gain from professional advice engendered by APs and AMCs, and from potentially reduced enforcement costs through more legitimate and informed management approaches. Finances would be required to cover the initiation and maintenance of APs and AMCs or to support additional PO or SFC functions, including the skills enhancement of personnel within the constituent organisations. FOs clearly face a challenge in consolidating their own financial base in order to maximise their potential and remit.
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Some alteration to primary legislation may be necessary, which, given the pressures on parliamentary time, would be likely to prove a reason for indefinite delay. Such would also be the case for any strengthening of the powers for SFCs or the extension of inshore management structures to Scotland. A strategic restructuring and strengthening of the current institutional configuration within the UK would lend significant benefits to the management system through meeting a number of specific needs. Clearly, however, there would be substantial obstacles and institutional challenges to such a course of action, not least the difficulty of initiating change in an industry dogged by crisis and steeped in apathy. Immediate difficulties would be faced in reaching agreement over the detailed structure and functioning of the system. Of perhaps greater importance would be issues of capability, aspirations and traditions that exist throughout the political and institutional environment. Both state and industry are reluctant to place institutional reform high on their respective agendas. Furthermore, enthusiasm for a more active participation of FOs within the policy system, widespread at grassroots level among fishermen, is only occasionally present within the industry's managerial class.
ACKNOWLEDGEMENTS Some of the issues referred to in this paper were developed as part of the EU-funded project on Devolved and Regional Management Systems for Fisheries (AIR-CT93-1392, D G X I V SSMA) based at the University of Hull.
REFERENCES l. Symes, D., Crean, K., Phillipson, J. and Mohan, M. Alternative Management Systems for The UK Fishing Industry, EU funded Research project (AIR2CT93-1392:DGXIV SSMA) Devolved and Regional Management Systems for Fisheries, Working Paper 5, School of Geography and Earth Resources, University of Hull, 1995. 2. Symes, D. and Phillipson J., The imperative of institutional reform: alternative models and the UK fishing industry. In Proceedings of the Vllth Annual Conference of the European Association of Fisheries Economists, Portsmouth, UK, 10-12 April 1995. CEMARE: University of Portsmouth, 1996, pp. 229-244. 3. Symes, D., Towards 2002: subsidiarity and the regionalisation of the Common Fisheries Policy. Paper presented at the Colloquium on the Politics of Fishing, Newcastle, 1996.
Ocean & Coastal Management, Vol. 35, Nos 2-3, pp. 185-199, 1997 ~) 1997. Published by Elsevier Science Ltd All rights reserved. Printed in Northern Ireland S0964-5691 (97)00033- 1 0964-5691/97517.00+0.00
ELSEVIER
Alternative management systems for the UK fishing industry J e r e m y Phillipson I and K e v i n C r e a n 2 1School of Geography and Earth Resources, Universityof Hull, Hull HU6 7RX, UK 2Universityof Hull International Fisheries Institute, Hull HU6 7RX, UK
ABSTRACT The paper considers opportunities for institutional development within the UK fishing industry that aim to engender a more meaningful incorporation of fishermen's organisations within the policy system. Special attention is given to the location of responsibility within the policy process. This involves an exploration of an alternative approach to consultation and the scope for delegation of management responsibilities to fishermen's organisations. Mechanisms to improve coordination among fishermen's organisations and to strengthen their internal architecture are also considered. The analysis raises important questions to inform the continuing debate over the development and structure of devolved management systems, in particular regarding the assumptions underlying user participation and the representativeness, capabilities and aspirations of fishermen's organisations. ~) 1997. Published by Elsevier Science Ltd.
1. INTRODUCTION: U S E R PARTICIPATION IN T H E UK The UK fishing industry consists of a widely dispersed range of sectoral and regional interests. Scotland currently dominates the fishing scene in terms of its share of landings by volume, and this is only partly offset by higher unit values for landings and a slightly higher number of regularly employed fishermen south of the border. The northerly shift in the centre of gravity primarily took effect in the late 1970s, with the exclusion of deep sea fleets based largely on Humberside from distant water fishing grounds through the establishment of 200-mile Exclusive Economic Zones. Regional contrasts are also expressed in institutional arrangements for fisheries administration and political representation, which promulgate the 185
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sense that this is a deeply divided industry on several fronts. From an administrative point of view, there is a division of management responsibility between provincial government offices in England, Wales, Scotland and Northern Ireland, although within these arrangements, the Ministry of Agriculture, Fisheries and Food (MAFF) remains arguably primus inter pares. This situation, while offering arguably more sensitive management approaches, does not facilitate a united industry front or effective industry representation, particularly when regionalisation is along distinctly political, territorial and cultural lines. The administrative cleavage is emulated within the framework of professional organisations serving the industry, and principally through the existence of two separate 'national' representative federations in Scotland (the Scottish Fishermen's Federation) and England and Wales (the National Federation of Fishermen's Organisations). In addition, the administrative division does not lend itself to an effective consultative system; within the provinces, the industry could be seen to be one step removed from important decisions within MAFF. As a whole, there is a marked need for a more coherent and integrated framework for the management of fisheries in the UK, which would provide the industry with a strengthened role within the policy process and also rectify existing weaknesses within the consultation system. It is widely acknowledged that the organisations that make up the industry are not sufficiently involved within the management system; to date, their knowledge and expertise have been under utilised and undervalued. Whereas the assimilation of fishermen's organisations within the policy process is not a panacea for the problems facing the industry, it is clearly of importance to fishermen, on whose cooperation rests the successful realisation of management policy. Participation is arguably integral to a legitimate and responsive management system. Therefore, this paper assumes that organisational arrangements for policy formulation and implementation can determine partly the success of fisheries management; consideration is given to the development of some potential institutional designs for a more meaningful participation of fishermen's organisations within a UK context. The UK has made considerable progress in terms of devolved management and user participation at the level of policy implementation, through two important organisational forms--producers' organisations and Sea Fisheries Committees. Producers' organisations are fishermen's organisations with a marketing remit, which attempt to ensure that fishing is carried out along rational lines and improve the conditions for sale of members' catches. This occurs through product grading, supply management and through operation of the EC's minimum withdrawal price
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system. Of special significance to the debate concerning delegated m a n a g e m e n t is the fact that the 19 producers' organisations in the U K are also responsible for the administration of sectoral quotas. For inshore fisheries in England and Wales, m a n a g e m e n t is devolved to the 12 regionally based Sea Fisheries Committees comprising almost equal numbers of local authority and fishing industry representatives. Considerably less progress has been made towards effective user participation in the area of policy formulation; this signifies a clear paradox within the UK m a n a g e m e n t system where high levels of delegated responsibility for policy implementation are contrasted with weak levels of consultation over the formulation of fisheries policy. In fact, with both producers' organisations and Sea Fisheries Committees, the full benefits of user participation are diminished, given that their responsibilities are determined by central government. Furthermore, when it is considered that fishermen's organisation's in general are denied an effective consultative role in terms of policy formulation, the potential value of any existing 'participation capital' is thus reduced. Existing consultation arrangements between the UK government and industry lack significance, transparency and formality. Such deficiencies of negotiation are compounded, if not largely initiated, by the fragmented framework of industry representation and the lack of consensus between the two main representative fishermen's federations. Both provide an umbrella representation for a mosaic of fishermen's associations (FAs) located at local, regional and sectoral levels. Not all associations are federated for policy and financial reasons. Indeed, there appears to be an accentuated tendency for industry organisations to fragment during conditions of crisis, when strain is placed on the sheer diversity of sectional and regional interests involved. Clearly, there is a need for institutional reform. Integral to the alternative institutional designs considered in this paper is an in-depth analysis of the structural and strategic characteristics of UK fishermen's organisations together with their positioning within the wider decision making framework.t The alternative systems represent a potential institutional challenge, but they are not too distant from the current political and institutional realities within the UK fishing industry. Indeed, t The analysis is based, in part, on the returns from a questionnaire survey of 164 fishermen in northern England, southern Scotland and Northern Ireland, which sought their response to issues relating to the location of management responsibilities, the strengths and weaknesses of fisheries related organisations, regulatory measures inter alia. Follow-up interviews were also held with representatives of some 40 key organisations representing both industry and government. For further information on the results and the survey methodology, see Ref. 1.
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they embrace the existing contribution of fishermen's organisations rather than promoting radical restructuring or the creation of new organisational forms. The paper first outlines the principles that underlie the alternative management approaches, drawing upon the supporting evidence of the resource users. The designs are then elaborated, and finally, there is a discussion of the key challenges that would face their implementation. This process of model building informs the continuing debate on the development and form of devolved management systems, paying particular attention to the assumptions underlying user participation and the representativeness, capabilities and aspirations of fishermen's organisations.
2. MODEL PRINCIPLES The alternative management systems address organisational needs within the UK. They are underpinned by a number of interrelated key principles, each consonant with optimum institutional requirements of user participation. They recognise a need for a more meaningful system of consultation between industry and government as well as greater cooperation among fishermen's organisations (FOs). The models sanction the delegation of management responsibilities to FOs, and, where responsibilities are already partially delegated, there is an exploration of opportunities for refinement and extension of roles and for strengthening the internal architecture of fishermen's organisations.
2.1. Consolidating co-responsibility The alternative approaches involve the ascription of additional responsibilities to FOs. Where responsibilities are already shared between state and industry, opportunities to consolidate such arrangements are considered. A delegation of facets of policy implementation to FOs is seen by many fishermen as an important component of effective management. Most active fishermen believe that FO-based management would have a beneficial effect on compliance levels with quota and gear rules, illegal landings, the accuracy of catch data and the fairness of rules. At the same time, it is clear from Tables 1 and 2 that a sharing of management responsibilities between government and industry is the most popular option, rather than the allocation of total management control to the industry. This demonstrates, in part, an acknowledgement of a number of specific management needs relating to fishing resources, including the need
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TABLE 1 Preferred management system (%)" 1st choice
2nd choice
3rd choice
4th choice
No response
9.1
31.1
28.7
28.0
3.0
7. 9
31.7
25.0
32.3
3.0
47.0
29-9
14-0
6.1
3.0
34.1
22.0
18.9
22.0
3.0
Central government controls all aspects of management but where the industry's advice is listened to Local government controls management but where the fishing industry's advice is listened to Management responsibilities are shared between government and fishing industry Fishing industry has control over all aspects of management
"Four management systems were proposed, and 164 fishermen were asked to rank them from 1 to 4 in order of preference. For each alternative system, the figures indicate the percentage of 1st, 2nd, 3rd and 4th choice responses.
for some overarching view of a transboundary resource, an awareness of the need for mediation between highly competitive and often conflictive interests and an appreciation of certain organisational needs within the FOs themselves, which could threaten the viability and strategic development of a management system if not steered or supported. TABLE 2 Allocation of management tasks (%)" Tasks
Stock levels Technical measures Enforcement Licensing Decommissioning Quota allocation/management Monitoring of catches Fish quality and price control Average percentage
UK EU POS Local Federations government FAs
54.3 54.3 75.6 73.2 63.4 41.5
3.0 5.4 6.4 4.8 23.7 2.4
Local SFCs authorities
34.2 24.4 19.5 17-7 15.9 57.9
19.9 25.9 5.4 7.8 10.2 21.1
20.5 25-4 7.2 7.8 10.2 17.4
4.2 6-0 9.7 6.6 10.2 3.6
16.9 20.5 12.8 7.2 6.0 9-6
59.8 34.8
3-0 38.3 6.6 53.0
15.7 21-8
12-6 8.1
10.9 5.4
13.3 9.0
57-1
6.9 32-6
16.0
12-6
7.1
11.9
"164 fishermen were asked to identify where management tasks should be located across the organisations present within the UK. Figures represent the percentage of respondents choosing an organisation to perform a particular management task, either in combination with another organisation(s) or on an autonomous basis
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Just which FO should prevail as the key partner in policy implementation can be debated. It can be noted, however, that one category of FO--producers' organisations--already features highly within the perceptions of fishermen in terms of the existing organisational mix and in any potential devolved management approach. In part, this reflects a familiarity with the existing division of labour within the industry, where producers' organisations are seen as 'management' organisations.
2.2. Consolidating the internal architecture of fishermen's organisations As a whole, whereas FOs display adequate capabilities to perform their respective roles, some organisational capacities would require consolidation in order that they might function more effectively in the existing policy system and in some of the alternative management designs. For example, the representative capacities of FOs can be criticised for a number of reasons. Frequently, the managerial backbone of FOs is provided by a small number of shore-based individuals, sometimes retired fishermen, who are not necessarily seen to reflect the views and attitudes of the 'fish room'. Within those federations and larger fishermen's associations that embrace an internal hierarchy (regional committees, branch structures), the twoway flow of information between members and the organisational elite can appear cumbersome and ineffective. Some fishermen are critical of power imbalances within FOs that may favour particular regional or sectoral interests. The two main national federations, for example, display membership nuclei from the main fishing ports, and from company or producer organisation vessels. The interests of smaller vessels, often with different priorities and a strong sense of independence, may be relatively marginalised within the organisational set up. Some mention should also be made of Sea Fisheries Committees, which are important in the context of user participation. The committees include Ministry-appointed members from industry, chosen for their expertise and not for a specific constituency interest. For a significant minority within the inshore sector, this is seen to be undemocratic, and a recent extension of the Committees' membership to include environmental experts has not helped to improve the level of respect. Finally, FOs in general are sometimes criticised for their lack of appreciation of policy process and the appropriate dynamics of interaction in decision making and negotiation. Linked to the question of representation is that of membership, and specifically non-membership of FOs, which may arise from some of the criticisms already outlined. Non-membership of fishermen's association and federations does bring into question their representative credentials.
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In the case of producers' organisations (POs), maintaining membership levels on a voluntary basis leads to difficulties in introducing strict internal marketing and disciplinary regimes. Whereas many fishermen view POs as managing and allocating quotas effectively, a significant minority believe that POs do not add value to their member's catches through effective marketing, and that when the in-house rules of POs were broken, there was little or no penalty.t M o v e m e n t of vessels out of the PO system or into other POs is a problem when a PO must maintain its aggregate vessel track record (which determines quota allocation) and financial base. Resource levels inevitably prevent some fishermen's organisations from playing a more active role; for POs, this may hinder marketing initiatives, and some small fishermen's associations are excluded from federation membership on this basis.
2.3. Consolidating linkages: consultation, cooperation, coordination Widespread perception of existing consultative arrangements within the UK is not good. The vast majority of active fishermen cite the government's unwillingness to listen to the fishing industry as being a basic causal factor of their problems. For many, industry advice is seen to be untimely and ineffective, and this is certainly partially attributable to a lack of formality, regularity and transparency within the existing system. In part, it is a product of the general importance that is attached to industry participation within the UK, as well as capability issues concerning lack of consensus and coordination. There is a clear institutional need for a sound and integrated institutional framework that incorporates a more fundamental consultative approach and the opportunity for enhanced cooperation between fishermen's organisations. Here, industry would be encouraged to unite or face a lost opportunity for a more proactive role in the policy system. Such principles form the backbone to the institutional approaches outlined below. 3. A L T E R N A T I V E M A N A G E M E N T SYSTEMS The alternative institutional designs consider how fishermen's organisations can be restructured or repositioned, so that they function more efficiently with respect to decision making and policy implementation t Mindful of these problems, the UK POs are to adopt a 'code of conduct' where the behaviour of individual members of POs would come under the scrutiny not only of the membership of that PO but also the 'peer review' of the UK Association of Fish Producers' Organisations.
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functions. Attention first turns to two potential foci for the delegation of management authority, producers' organisations and Sea Fisheries Committees (SFCs), given their existing prominence at the level of policy implementation. Consideration is then directed to the linkages within the policy system and, in particular, the incorporation of FOs at the level of policy formulation. This involves the development of a formal system for consultation between central government and the fishing industry and a means for promoting greater coordination among management organisations at the regional level.
3.1. Producers' organisations POs are perhaps obvious candidates for the ascription of additional management responsibilities given their existing remit of quota management, which is already consonant with the principle of devolved management, and their EC-wide status. They also feature highly in the perceptions of active fishermen in terms of existing or enhanced functions. There are limitations, however, to the level of management authority that could be delegated to POs. In part, this relates to capability issues addressed earlier, as well as to a lack of geographical coherence and noncomprehensive membership. More importantly, they are essentially commercial organisations dedicated to the pursuit of members' interests rather than resource management objectives. Certain sectors, notably the small boat interests, which are effectively excluded from PO membership, remain vigorously opposed to the idea of POs receiving additional responsibilities on this basis. Paradoxically, POs have tended to be entrenched in quota administration issues and, partly for this reason, have underplayed their commercial potential. In practice, it is also difficult to envisage what new management roles might be offered to POs, except perhaps for administering effort quotas in addition to, or in lieu of, catch quotas. Arguably, greater benefits might accrue to the management system if POs were to seek to maximise their existing potential in relation to commercial activities rather than the assimilation of new roles. This might involve a more proactive engagement in marketing initiatives with the assistance of European Community funding mechanisms. For example, they may have scope for investment in processing facilities and in the handling and selling of fish, or have opportunities to implement a more effective system of supply management. It is likely that if the PO leadership took the initiative in market development, this would in turn lead members to adopt a more positive attitude to supply management. A strengthened role for POs could also involve offering financial services to
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members or a greater interest in the 'ring fencing' of members' track records. Here, POs have the option to purchase the track record of a member leaving the industry, which can then be absorbed by the remaining vessels or held in a reserve fund for allocation to new entrants. Finally, to take on a more holistic commercial approach or new management responsibilities, POs might seek to strengthen their institutional structure through: • structural rationalisation and the creation of fewer and larger POs with corporate, as opposed to cooperative, forms of organisation, this would encourage benefits of economies of scale with regard to capital and senior management would be better positioned to take a more independent and strategic perspective; • improving their disciplinary record; possible methods may include independent arbitration panels or a code of practice; • strengthening their representation of the small boat sector; • increased transparency of behaviour through participation within Area Management Committees (see below).
3.2. Sea Fisheries Committees
Given their existing central position in inshore fisheries management, SFCs offer another potential focus within which to vest responsibility. Several possibilities exist for the development of the role of SFCs. They could be retained as organisations responsible for inshore fisheries management (with limited regulatory functions and byelaw making powers) and matters relating to marine conservation. Alternatively, some redefinition of their role may allow them to adopt more specialised functions, rather than attempting to perform both coastal zone management and fisheries management tasks. As with producers' organisations, there is also a considerable case for consolidating the existing devolved management functions of SFCs. A number of developments might serve to soften the negative effects of the limitations within which SFCs operate, including a widening of their powers and the administration of inshore licensing. At present, their regulatory powers are both rigid and slow to resolve problems. Greater flexibility of management response would arise from the adoption of precautionary and emergency byelaws. Statutory local organisations for inshore fisheries management apply only in England and Wales; the extension Of the principle, if not the precise form, of SFCs to Scotland and
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Northern Ireland would help to consolidate the basis for devolved management around the whole of the UK coastline.
3.3. Advisory Panels and Area Management Committees Whereas the restructuring of fishermen's organisations would improve their functional performance or extend their role in terms of policy implementation, there is a further need to provide a more structured, coherent and transparent system of consultation between industry and central government and to strengthen the framework for policy-making. One potential approach to meet this organisational need might involve a two-tier integrated framework, incorporating a series of what can be termed Advisory Panels (APs) and Area Management Committees (AMCs). 2 A system of APs, embracing AMCs, might help the formulation of broad strategies for the development and management of the industry as a whole. Within such a system, fishermen's associations and their national federations would continue to function as key political organisations representing members' interests at local, regional and national levels of negotiation. The political role of the national federations would, however, be elevated through their key positioning within the framework. APs would provide arenas for industry and government to discuss all matters relating to fsheries management, including the development of policies and regulations relating to conservation, marketing and structural management, as well as biological, economic, social or environmental issues. Government could present policy proposals to the appropriate panel(s) for discussion at the earliest possible opportunity, and certainly well in advance of their intended implementation. In turn, it would benefit from the professional advice and proposals from industry concerning resource issues. In terms of spatial extent and geographical location, the system could involve three APs constructed along ICES areas (IV; Via and b; VII) (see Fig. 1). Utilising ICES areas would place less emphasis on territoriality, which might help to avoid regional disputes. It would also provide the opportunity to relate advice to stock management information currently collected on an area basis. It would be particularly useful if AP meetings were timed to coincide with discussion of proposed, and subsequently agreed, Total Allowable Catch/quota allocations, thus reinforcing the notion of resource management as the central focus of their deliberations and enhancing existing consultation arrangements for these issues. In order to facilitate greater cooperation among different interests within the fishing industry and the opportunity for more integrated
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management approaches, it would be appropriate if panel membership was broadly constructed, including representation from central government, harvest and post-harvest sectors and statutory environmental organisations. However, in order to convey maximum legitimacy, the balance of membership should favour the harvesting sector. An essentially political remit would suggest an emphasis on federations and fishermen's associations in the 'seating' arrangements. As a whole, the intention would be to provide a transparent, timely and formal consultation process. Crucially, the system would also offer greater regional sensitivity in the policy generation system. It is also the case that the delineation of APs in terms of ICES areas could openly suggest that they might ultimately evolve or be replicated to include the fisheries management apparatus of other member states linked to the particular
o
500 km
ADVISORY PANELS
I~
V,
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(-
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Vl
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Fig. 1. Advisory Panels and Area Management Committees.
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ICES area or 'regional sea'. 3 This would offer an important step towards a more regionally sensitive policy process throughout the EC as a whole. To provide greater co-ordination among management organisations at the regional level within the UK, a case might be made for the creation of a sub-set of AMCs. The AMCs would encourage liaison among local organisations, including POs and SFCs, and, in turn, facilitate more coherent and transparent management approaches and initiatives. Through overlapping membership, they could also be used to generate local information and expertise to enhance the advisory functions of the APs. Within both AMCs and APs, membership would generally comprise primarily those with a significant management interest in the respective ICES areas and sub-areas. In both cases, interests representing the 'region' would be present. AMCs, however, would be smaller in size than the APs and their membership focused on management organisations in the harvest sector, with the chair taken by a senior representative of one or other (or, in some cases, both) of the federations. AMCs could be based on ICES sub-areas (possibly IVa; IVb; IVc; VI; VIIa; VIId; VIIe&h; and VIIf&g), again to place less emphasis on territoriality and to link AMCs to identifiable fish stocks (at least in statistical data terms). They could also benefit from attendance by the regional fisheries inspectorate and government scientists, together with representatives from local government and downstream sectors as observers or through co-option. It would be invaluable for positive linkages to be generated between APs and AMCs, on the one hand, and between different APs and different AMCs, on the other. Interaction between the organisations might be encouraged through careful timetabling of meetings to ensure a phased cycle of discussion, so that issues raised at one AP or A M C meeting, which are of relevance to other neighbouring groups, could be passed on for further discussion either at the same level or raised from AMC to AP level.
4. ISSUES OF IMPLEMENTATION The alternative management systems elaborated above represent possible avenues through which a number of institutional needs may be addressed. Whereas specific details may require refinement and elaboration, their underlying objectives are sound. The proposals are certainly not overly radical; the existing hegemony remains intact, through recognition of established boundaries of responsibility and the positioning of the leading fishermen's organisations. Overall control over fisheries management remains with the central state and there are no significant challenges to
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existing forms of property rights. Whereas ultimately, radical reform may be what is required, the realities of institutional change and the legitimacy of organisational development necessitate an incremental and practicable approach. At the same time, if there is acknowledgement of the institutional and political context, within which the model designs would operate, the systems do represent significant challenges. Implementation of the alternatives would pose a number of problems. Perhaps the greatest is found in a general reluctance on behalf of state and industry for any significant shift in the loci of responsibility within the policy system. Both lack trust in each other. The state admits that it is reluctant or unable to fully assimilate FOs within the policy process, given widespread division and politicisation among FOs and doubts relating to the representativeness of their membership and their capacity for internal discipline. This attitude is also symptomatic of the wider political culture within which approaches to governing and user participation are framed. When compared to other European states, such as Denmark or Norway, the UK appears more centralist and government led. Existing forms of user participation and delegation are clearly centrally determined, controlled and structured. Proposals that work against this established style of governance clearly face difficulties, particularly when one considers the lack of economic and political power shown by the fishing industry within the UK. Whereas it is doubtful whether government would concede effective responsibility to FOs, it is also uncertain whether the industry is in a position to induce change itself. This is not solely a question of capabilities, divisions, levels of professionalism or even simply a resistance to change p e r se. For large sections within the industry, there is unease with suggestions of institutional change. There are a number of reasons for this situation. Institutional change is simply not a high priority for many FOs or government. There are clearly more pressing problems, such as fleet overcapacity and structural adjustment, regulation issues and fisheries resource levels. For many FOs and fishermen, conceptualising new institutional forms is too distant from their day-to-day fight for survival. Numerous FOs remain understandably preoccupied with quota, resource or membership levels. Aspirations of FOs and fishermen remain modest and reflect organisational capabilities and resources. Leading FOs, already positioned favourably within the industry set-up or decision-making framework, are anxious to protect the s t a t u s q u o and prevent any erosion of their position. Fishermen's federations, with established informal channels to government, would certainly be concerned at a widening of the scope for representation within any new formal consultative arena. Already, some are concerned that too many competing voices are
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approaching central government and thus undermining the 'national' representation of the federations, Formal assimilation within the policy process may be seen to tie the hands of the industry, which has traditionally performed a role of resistance. Furthermore, there is concern with becoming more responsible for a management system, which already faces crisis, and for a range of socially unpopular decisions in the short and long term. Others are sceptical that there would be a real change in attitude towards user participation and that some of the structures elaborated above may simply be no more than talking shops, with little real impact on the policy system. Any implementation of the alternative models would require a feasibility study and further definition of detailed structure and design. Here, the wide range of choices and dilemmas surrounding the architecture of devolved management systems in general, such as the scale and breadth of representation, would come to the forefront. Elaboration and negotiation of such detail would itself be a significant challenge, especially in reaching agreement over the formula for representation on APs and AMCs. Indeed, whereas AP membership may, on paper, appear to be representative of interests across the board, this would clearly be a matter for much debate and would lead, in practice, to difficulties with respect to obtaining legitimacy for the advice generated. Would it suffice for the AP to make recommendations on the basis of (narrow) majority agreement? How could the decision-making process be configured to engender confidence in the outcomes? It is possible that the existence of Area Management Committees might smooth the decision-making processes at the AP level but, in their role as co-ordinators at regional level, they could be confronted by serious representational and consensus limiting factors. Implementation would also raise a number of practical concerns that may prove barriers to successful user participation. Arrangements for consultation may, for example, place an unacceptable burden on the established decision-making procedures in both Whitehall and Brussels. Although the additional financial burdens are unlikely to be significant, the question of who pays could prove contentious. Both government and industry would be beneficiaries of the system; the government would gain from professional advice engendered by APs and AMCs, and from potentially reduced enforcement costs through more legitimate and informed management approaches. Finances would be required to cover the initiation and maintenance of APs and AMCs or to support additional PO or SFC functions, including the skills enhancement of personnel within the constituent organisations. FOs clearly face a challenge in consolidating their own financial base in order to maximise their potential and remit.
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Some alteration to primary legislation may be necessary, which, given the pressures on parliamentary time, would be likely to prove a reason for indefinite delay. Such would also be the case for any strengthening of the powers for SFCs or the extension of inshore management structures to Scotland. A strategic restructuring and strengthening of the current institutional configuration within the UK would lend significant benefits to the management system through meeting a number of specific needs. Clearly, however, there would be substantial obstacles and institutional challenges to such a course of action, not least the difficulty of initiating change in an industry dogged by crisis and steeped in apathy. Immediate difficulties would be faced in reaching agreement over the detailed structure and functioning of the system. Of perhaps greater importance would be issues of capability, aspirations and traditions that exist throughout the political and institutional environment. Both state and industry are reluctant to place institutional reform high on their respective agendas. Furthermore, enthusiasm for a more active participation of FOs within the policy system, widespread at grassroots level among fishermen, is only occasionally present within the industry's managerial class.
ACKNOWLEDGEMENTS Some of the issues referred to in this paper were developed as part of the EU-funded project on Devolved and Regional Management Systems for Fisheries (AIR-CT93-1392, D G X I V SSMA) based at the University of Hull.
REFERENCES l. Symes, D., Crean, K., Phillipson, J. and Mohan, M. Alternative Management Systems for The UK Fishing Industry, EU funded Research project (AIR2CT93-1392:DGXIV SSMA) Devolved and Regional Management Systems for Fisheries, Working Paper 5, School of Geography and Earth Resources, University of Hull, 1995. 2. Symes, D. and Phillipson J., The imperative of institutional reform: alternative models and the UK fishing industry. In Proceedings of the Vllth Annual Conference of the European Association of Fisheries Economists, Portsmouth, UK, 10-12 April 1995. CEMARE: University of Portsmouth, 1996, pp. 229-244. 3. Symes, D., Towards 2002: subsidiarity and the regionalisation of the Common Fisheries Policy. Paper presented at the Colloquium on the Politics of Fishing, Newcastle, 1996.