The NFFO comments on where we are after the EU and UK have agreed arrangements for the 21 month…
A major consultative meeting was held in Brussels on 8th September as a prelude to the autumn decisions on TACs and quotas for next year.
Chaired by the Director General, Lori Evans, the meeting reviewed the main themes in this year’s ICES advice, discussed the main economic trends in the fisheries and took initial reactions from an industry panel which included the NFFO. All the main European fisheries organisations and a large number of NGOs were present.
The Director General affirmed that the TACs and quota decisions this year must be seen within the context, and as far as possible, should be consistent with the anticipated direction of CFP reform. The Commission conceded that the general stocks picture was one of “slow improvement”, especially in the Atlantic and nearby fisheries. The trends for the Mediterranean were not as positive. The fixed points in the Commission’s approach were:
- Greater reliance on long term management plans
- Phasing out overfishing where the stock parameters are known
- Adopting a more cautious approach where the conservation status of the stock is unknown
The NFFO, in reacting to the Commission’s Policy Statement on Fishing Opportunities for 2012 and the presentations, made a number of points:
- Destinations: The Director General is correct when she says that there is a broad consensus on the destination for European Fisheries: well managed, high yield, fisheries. But that must be qualified by the words “where possible”, especially in relation to mixed fisheries, as science suggests that it is unlikely to be able to achieve MSY for all stocks simultaneously, not least because of predation patterns. There are also profound disagreements on the route to be taken to get to the destination, especially in the context of an unreformed CFP
- Definition of “overfishing”: The Commission has been justly criticised in the past for being alarmist in its public statements about the state of the stocks. We welcome therefore the greater precision in the definition of “overfishing” now used, in which the term is used in a technical sense in the proximity of each stock to maximum sustainable yield. This is very different from conveying the impression that stocks are heading towards collapse or extinction.
- Trends: As an example of the general trends evident in many of our fisheries, in the North Sea, ICES advice this year suggests that of 23 stocks, 2 display negative trends, the conservation status of 4 are unknown and the rest are either stable or heading in the right direction. Of the two that display negative trends one is saithe, which has been fished at or near MSY for around five years. This sends a signal that either the assessment is incorrect, or it is possible to do everything right in management terms and still face problems because of exogenous factors
- Data Deficient Stocks: The RACs have been involved in a close dialogue with ICES over data deficient stocks over the last year. The Commission’s proposal to apply a blanket 25% reduction on all TACS of data deficient stocks is wholly disproportionate and amounts to something perilously close to collective punishment. There are many different reasons why ICES may not be able to provide an analytical assessment for any given stock, not all of them the fault of the fishing industry or the member states. The problem can lie with the assessment model, financial resource issues, or with the absence of historical data. It is essential that the Commission, having made its point that member states should address their data deficiency issues, now abandons its blanket and punitive proposals and adopts a reasoned case- by-case approach. Arbitrary cuts in TACs in mixed fisheries can have only one outcome: an increase in regulatory discards.
- Discards: Removing discards generated as an unintended by-product of CFP regulations will be a precondition for phasing out discards within the CFP more generally. Taking the Director General at her word, that the TACs and quotas regulation must align itself with direction of CFP reform, it will be important that the Commission in framing its formal proposal addresses the issue of discards generated through the level of TACs set. This applies especially to fisheries for which a cosmetic zero TAC is set, or where a blanket 25% reduction is applied. We agree that it is important to do what can be done to reduce discards now in terms of the policy decisions that will be made this autumn. This largely lies in the hands of the Commission.
- Long Term Management Plans: We strongly support the movement towards the management of stocks on the basis of coherent, well thought-through, long term management plans. At the same time, we shouldn’t shy away from amending plans that are clearly not fit for purpose. STECF and ICES have issued a damning report on the performance of the EU Cod Management Plan, criticising the fact that it is based on two false assumptions. The Commission is now faced with a dilemma: it can carry on into 2012 with a fundamentally flawed plan (with its pre-programmed reductions in effort and TACs), or it can propose interim arrangements for 2012, pending a more profound revision within the context of co-decision making with the Parliament. We make the point that it would be unsupportable to continue blithely with a plan, the central planks of which generate discards, have a very oblique(if any) relationship to a reduction in fishing mortality and cause widespread economic dislocation. STECF’s endorsement of the approach to discard reduction and cod avoidance enshrined in Article 13 of the plan points the way forward.
- Fisheries Science: We took the opportunity to draw attention to the scale of cooperation and collaboration between the fishing industry and fisheries scientists, in order to refute the notion that there is a fundamental conflict between the scientists and fishermen. Collaboration is taking place across the board, through fisheries science partnerships, the development of long term management plans, within the RACs and on the issue of data deficiencies.
- What works? The Federation invited the Commission to examine what works and what doesn’t work in terms of specific fisheries management measures. Amongst the measures that the evidence suggests don’t work are blindly cutting TACs within the context of multi-species mixed fisheries. Effort control is another busted flush. Against the background of what is expected to be a highly critical report by the European Court of Auditors on overcapacity, it is worth considering the relationship between publically funded decommissioning schemes and those fisheries in which positive stock developments are now evident. The Celtic Sea fisheries, North Sea Plaice and even North Sea cod are good places to ask the question as to how much the current positive trends are attributable to publically funded decommissioning schemes in the member states.
Strong, well argued, points were made by a number of other participants in relation to their fisheries. These included:
- the need to align TACs and quota decisions with initiatives to reduce discards, strengthen the economic viability of the fleets and secure the involvement and support of the industry in the development of long term management plans
- The urgent need for better ways to manage multi-species fisheries. In this context the Commission drew attention to new work on this issue within ICES, and the NFFO alerted the meeting to a major conference, planned by the RACs on mixed fisheries, to be held next January.
- The need for a more sophisticated and differentiated approach to understanding economic developments within the industry, including an appreciation of the different price elasticity in different stocks
Oceana, an environmental NGO, noted the positive stock trends but pointed to a number of examples where stocks were not responding to management measures. It also considered that the 25% blanket reduction on TACs for data deficient stock “was a good option” but no explanation was provided to back this opinion.
In summing up, the Commission:
- Noted the constructive spirit in which the meeting had been held
- Hoped that this spirit of engagement would continue through the rest of the autumn discussions on TACs and into the important dialogue on CFP reform
- Noted that the data deficiency issue was a major problem that required serious political attention by the member states. A greater degree of commitment was required from the member states and the Commission would use all levers at its disposal to remove data bottle-necks.
- It was necessary to rethink the Data Collection Regulation as part of a more profound review of how science would be provided within a reformed CFP
- The very positive work emerging from the RACs on data deficiency was commended and the RACs were urged to expand this initiative but to ensure that it was coherent with the provisions of the data collection regulation
- A priority was the development of new science that would allow for better management of mixed fisheries; this work is under way in ICES and a multi-species model for the Baltic has already been completed
- Striking the right balance between out-take in the current year and building stocks to MSY would be critical
- It would be important to evaluate the implementation of long term management plans and those that are revealed not to be working would have to be revised. These revisions should be within the context of an evolution towards an ecosystem approach.
- Fisheries science partnerships and collaboration should be facilitated by the member states
- The Commission would continue to apply the precautionary approach but would be listening to points made about the right response to data deficiencies
- The need to ensure that TAC decisions are consistent with the direction of the reform would be maintained
- There was an absolute need for industry buy-in for the broad direction of change within the reform
- Doing nothing is not an option
The Commission’s Proposal on TACs and Quotas for 2012 is expected to be published on 25th September.