reLAKSation 133.

Po’ed!: Ole Petter Krabberød, until recently, Managing Director of Norway Royal Salmon, told IntraFish that Producer Organisations have so many positive attributes as a regulating mechanism, he is curious  to know what arguments could be put forward against them. Fortunately, we, at Callander McDowell, are happy to satisfy Mr Krabberød’s curiousity.

Mr Krabberød is looking for an impartial debate about PO’s in Norway. He believes that Producer Organisations could cement relations with Brussels, as well as neutralise the Scots and Irish. He cannot understand why many Norwegian salmon farmers are so reticent to take on the responsibility of self regulation, but are happy to allow the Norwegian Government to take control of production. Perhaps, they, unlike Mr Krabberød, can see that Producer Organisations are not the answer and any attempt to introduce them to Norway would be just another example of appeasement.

The problem with Producer Organisations is that their whole concept as a regulating mechanism for salmon farming is inherently flawed. They will not solve the recurring problems of market disruption because they are production oriented, which is why they are called Producer Organisations. The only solution for continued market disruption are those that address the issues of the marketplace. Producer Organisations were originally envisaged as a way of regulating the fishing industry. As fish stocks declined, the European Commission needed to find some way of dividing a finite resource between every fisherman. Producer Organisations are an ideal way to do this. Under the Common Fisheries Policy, the national fisheries ministers sat down once a year and set quotas for every type of fish. Each quota was divided between the various Producer Organisations who then allocated a fixed catch to each of their members. If we try to illustrate this as a cake, then the EU fix the size of the cake and then how it is divided up. By comparison, if we try to use the same example for farming PO’s, then the real problem is that no one seems to know what size the cake should even be!

The idea of trying to apply what are effectively measures to control fishing to the farming industry was first conceived by Professor Chris Ritson of the Department of Agriculture at the University of Newcastle upon Tyne. In 1990, he had been employed as a consultant to then Scottish Salmon Growers Association to offer possible solutions to the collapse of salmon prices. His view was that the industry was over-producing and that production should be regulated. He believed that as Producer Organisations were an existing method of regulation used by the EU, they could be adapted to the farming situation.

Unfortunately, fishing and farming may have fish in common, but they have little else. What worked for fishing might not necessarily work for farming. The fishing industry controls are used to protect stocks from over-fishing and they operate by limiting how many fish can be taken. By comparison, the capacity to produce fish by farming is potentially limitless so PO’s can only work by placing limitations on the size of the market.

Professor Ritson’s proposal was that a committee of eminent industry experts would be established to discuss and set an annual figure for the size of the salmon market. This market size would be then equated to an annual production figure which would then be divided between the various national Producer Organisations. This plan may seem ideal in principle but it is extremely simplistic and unlikely to work, notwithstanding the legal issues. Firstly, whilst fisheries experts calculate fishing quotas based on known recruitment patterns and depletion rates, there is no magic formula for calculating market demand. Even today, many fishermen argue that the experts have got their calculations wrong so could salmon farmers expect any better? The answer is probably not. It is clear that there is a already a major difference of opinion as to the size of the market with repeated claims of over-production despite continued production growth. Obviously some farmers are confident that the market will grow whilst others are not. This uncertainty is also reflected in the recent admission by Lars Liabo of Kontali that some of his forecasts were wrong. If Mr Liabo cannot get it right, what hope is there for a Producer Organisations committee?   

One of the difficulties that the industry has in determining the size of the market is that everyone has a very different idea as to what the market actually is. Certainly, suggestions of over-production are more linked to price expectation than to actual over-production. The higher the volume produced, the lower the price and vice versa. Those sections of the industry that complain about over-production actually mean that the price is below their own expectation and this is the reason why they want production to be restricted either through reduced smolt input or by more stringent border controls. The problem is that higher prices also mean a reduced market demand but it does not mean that demand has fallen, it simply means that some consumers are not willing to buy salmon if the price is too high. In addition, the salmon market is not just about fresh fish anymore. The market for salmon has become extremely sophisticated with the development of many added value products ranging from smoked salmon to complex ready to eat meal solutions. One of the reasons that salmon is increasingly used in such products has been its low cost. Should the price rise, salmon would no longer be considered to be a viable raw material for such products. This could be extremely damaging to a processing sector that has come to rely on this versatile and low cost raw material. The range of products now manufactured means that it is extremely difficult to assess how much impact they have on the size of the market. If prices remain low, the size of the market increases significantly and as some farming companies find that they can retain some profitability at these lower price levels, any future committee cannot ignore this aspect of the market.

Even if this proposed committee of experts can decide on a market size acceptable to the whole industry, there are still other issues which must be overcome if Producer Organisations are to function realistically.

The first problem is how Producer Organisations would be policed. Producer Organisations work successfully (although some may disagree) in the fishing sector because every individual PO has been established within a member country. This means that every PO is subject to the rules and regulations operated by the European Commission. Norway is not a member of the EU and therefore cannot be subjected to these rules and regulations. According to IntraFish, the EU’s Directorate General for Competition has already expressed concern that Norway has been previous involved in covert negotiations with Ireland and Scotland so it is unlikely that unless Norway joins the EU, any discussion about PO’s is pointless. Even if Norway, were a member of the EU, then there are still unanswered questions about imports from Chile and the Faeroes.

These insurmountable hurdles have led some advocates of Producer Organisations to propose that this system of control could be established as a voluntary arrangement. They have even gone as far as setting up their own voluntary so-called Producer Organisations. There is now a Scottish PO, a European PO and there was once a Shetland PO. Mr Krabberød has already admitted that he had an 18 month stint on the Board of the Scottish Salmon Producers Organisation, whilst he was head of Stolt’s activities in Scotland. It is unclear as to what the Board of this PO actually did since clearly they were not involved in the regulation of their member’s production, which is there only purpose for their existence. However, these voluntary PO’s could have been using the time since they were established to conduct dry runs as a demonstration to their potential effectiveness to the rest of the wider industry. The salmon industry might be more convinced as to the rationale for PO’s if they could be shown that this system of regulation would work. This has been a lost opportunity. Instead, at least one of these ‘PO’s’ has been the vehicle for further complaints to Brussels. This is not really their purpose, but it does allow some of the independent farmers to gain credibility in Brussels as a recognised representative organisation in order to pursue their own case.

Mr Krabberød believes that a Norwegian PO would place Norway in a more favourable light with the European Commission, especially if it were to employ the EU’s own model for regulation. It would also reduce criticism from the Scots as it is the type of cooperation that they have demanded for over 10 years. However, they have also had 10 years to demonstrate that such a system would work and one of the reasons why they have not is simply because it won’t.  The industry needs to stop this fixation with production controls and instead focus on the necessary market development needed to secure the future of salmon farming.

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