APPENDIX 5
Memorandum submitted by the South and
West Wales Fishing Communities (K12)
1. INTRODUCTION
1.1 The South & West Wales Fishing Communities
is a formally constituted Fishermen's Association formed from
the recent merger of the Joint Fishing Communities of South &
West Wales and the South & West Wales Fishermen's Association.
Its membership currently comprises 120 licensed commercial fishermen
and charter angling boat skippers residing in South Wales from
Cardiff to Cardigan and operating from harbours within the South
Wales Sea Fisheries Committee area of jurisdiction. The majority
of vessels operated by members of the Association are 12 metres
and fish inshore waters with static gear for shellfish, particularly
crab species, lobsters, whelks and prawns. Other vessels fish
seasonally for white fish, eg cod, herring, mackerel, skate and
ray, shark species, flatfish and bass, whilst there are also fishermen
who locally hand pick bivalves, especially cockles, oysters and
mussels.
1.2 The South & West Wales Fishing Communities
wholeheartedly welcomes this opportunity to present its views
to the Committee and trusts that the views expressed will assist
the Committee in its formulation of a robust and sensible response
to the Commission which will lead to the protection of the interests
and livelihoods of UK fishermen through a sustainable, ecosystem-based
approach to the management of the EU's fisheries and marine environment.
2. SUMMARY
There now follows the Association's brief response
to the reforms to the Common Fisheries Policy proposed by the
European Commission in May 2002.
The response:
— supports the need for an urgent and
swingeing review of the Common Fisheries Policy which is not meeting
the needs of the industry, stocks or the environment;
— supports the proposed capacity reduction
rather than TAC/quota approach to high seas fishery management
whilst also being concerned that overly rigid application of capacity
reduction could adversely affect the ability of fishermen to diversify
operations;
— highlights the urgent need for the
Common Fisheries Policy to differentiate between the needs of
the inshore and the high seas fishing sectors and to focus more
carefully on the former;
— endorses the ecosystem-based approach
to fisheries management whilst advising of the dangers of too
rigidly imposing the "precautionary principle";
— endorses the proposal to create Regional
Advisory Councils and suggests that there should be Local Advisory
Councils to ensure adequate industry representation and a sense
of ownership by stakeholders;
— endorses the proposal to retain the
access restrictions within the six to 12 mile zone but suggests
that the proposals do not go far enough to afford adequate protection
to stocks, inshore fisheries and the inshore marine environment.
3. OVERALL IMPACT
ON FUNDAMENTAL
PRINCIPALS
3.1 The review of the Common Fisheries Policy
is essential as the current policy, depending as it does on TACs
and quotas, is acting counter to the interests of the fishing
industry, the fish stocks and the marine environment generally.
3.2 Whilst the current proposals go some
way to providing the radical and courageous review of the CFP
that is essential to ensure sustainability of stocks and fishing
communities and to restore public support for the fishing industry,
without a similar radical and courageous approach to its implementation
by the Commission and Member States the current situation will
continue to deteriorate.
3.3 The proposal to concentrate more on
capacity reduction and to employ an ecosystem-based approach to
fisheries management is believed to be more likely to succeed,
but only if the latter policy is applied in a local / regional
way based on ecosystem rather than on political or other false
grounds.
3.4 The declared aims of the proposed new
Policy of openness and transparency, involvement of stakeholders
in policy shaping and the management process and improved accountability
are supported wholeheartedly, but the it is not clear from the
proposals that this will be achieved in any significant way unless
the management process is introduced at a much more local and
"grass roots" level than would seem to be envisaged.
3.5 The Commission is urged to adopt a "Small
is Beautiful" approach to fisheries management. The past
and present concentration of attention on large scale fishing
activity, high seas fisheries and large scale, broad brush measures
is believed to be a major reason for the failure of the CFP. It
is recognised that this stems, to a large extent, from the acceptance
by the European Commission of an "open seas" policy
where all fisheries outside the six mile limit are effectively
open to all Member States. However, such an approach creates major
impediments to the development and operation of fishery and environmental
conservation measures and a sense of ownership and responsibility
amongst stakeholders. It also is a very blunt and unwieldy implement
and prevents the fine tuning and local variation that would be
valuable for effective stock management.
4. IMPACT ON
QUOTA MANAGEMENT
AND CONSERVATION
AND ALTERNATIVES
4.1 The impact on stocks of the current
quota management policy with the high level of discards and by-catch
does not appear to have been adequately addressed by the proposed
revisions. Stringent measures are required and would be supported.
The current failure of the UK Government and the European Commission
to adequately address the unsustainable south coast pair trawler
bass fishery with its excessive exploitation of spawning stock
and its demonstrable high by-catch of cetaceans gives no confidence
that there is any will or intention to change to the extent that
is urgently required.
4.2 The proposal to establish rules for
the protection of non-commercial fish species is very welcome
but they must be effectively designed and enforced.
4.3 The retention of the 6 and 12 miles
limits is welcomed and should be made permanent. However, the
detailed proposals regarding the 6 to 12 mile zone does not go
far enough. The effective management of the coastal zone out to
12 miles is fundamental to the survival of the inshore fishing
sector and to the sustainability of the important coastal marine
environment. Dr. Franz Fischler's suggestion that the intention
of the CFP Review is to give each National State responsibility
for the fishery within its own 12 mile zone is particularly welcome
as is his suggestion that the responsibility will include control
over foreign vessels fishing under historical rights between 6
and 12 miles and that the 12 mile zone will be totally separate
from the shared regions outside 12 miles. It will be essential
that this interpretation is supported with the greatest energy
by the UK Government in partnership with others to ensure that
it is pushed through against anticipated opposition from some
other Member States.
4.4 The Association recommends in the strongest
possible terms that the 0-12 mile zone should be designated for
the exclusive use of National vessels only. Further that fishing
activity within this 0-12 mile zone should be derogated to national
management through the designation of adequate powers of regulation
and enforcement. If this restriction in use is applied and rigidly
enforced, the following benefits will accrue:
— stakeholders will feel a sense of
ownership and responsibility for their fisheries;
— stakeholders will develop a confidence
in the future which will allow them to manage their fisheries
in a sustainable way through the adoption of conservation measures
and practices in the knowledge that their will be no unexpected
impact from outside interests;
— the inshore fishing industry will
be able move from a "hunter/gatherer" mode of operation
to a "farming/husbandry" approach.
3 October 2002
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