Annex B
Letter to Sea Fisheries Conservation Division,
Department for Environment, Food and Rural Affairs, from the Chief
Executive, Association of Sea Fisheries Committees of England
and Wales (dated 29 August 2002)
EUROPEAN PROPOSALS
FOR REFORM
OF THE
COMMON FISHERIES
POLICY
I refer to your letter of the first instant
acknowledging my comments in a letter to you dated the 15 July
last following informal consideration of the Commission's Consultation
Documents. As indicated in my letter, the Association's Technical
Panel has now had an opportunity of considering the whole of the
documentation including the Roadmap and my report on the Consultation
Meeting hosted by Stephen Wentworth at York on the 24 July last,
which was also attended by representatives of some of my member
Sea Fisheries Committees. As you will no doubt be aware, other
Sea Fisheries Committees representatives attended the Consultation
Meetings held in London and Exeter.
I am aware that several of my member Sea Fisheries
Committees have written in some detail, not only in response to
your Consultation Document, but also commenting on the "Roadmap"
Document. In the circumstances, I do not intend to repeat many
of those observations, the gist of which in most cases would have
the support of the Association, and bearing in mind our initial
support of the proposals as indicated in my letter to you of the
15 July last.
The Association's Technical Panel were, however,
concerned at the ability of the Commission to maintain "relative
stability" in the long term, if not in the short term, bearing
in mind the expectations of those who would be entitled to access
to fisheries post 1 January, 2003. Whether or not the existing
"ration" of quotas can be maintained is, in our view,
doubtful. They would, however, support the stated aims concerning
the conservation of resources and management of fisheries and
the proposed new multi-annual framework, together with a strengthening
of technical measures but would oppose industrial fishing. The
political implications should be removed and a precautionary approach
taken.
The Panel is naturally more concerned with proposals
concerning inshore fisheries management which directly impact
on coastal stocks falling within the statutory responsibility
of the regulation and management of those fisheries by my Member
Committees. They welcome the continuation of the six and 12 mile
limit arrangements and are delighted at the proposed member state
control. They are, however, concerned at the possible knock-on
effect if free access is allowed into coastal waters, albeit outside
the 12 mile limit. It is quite feasible that marauding EU trawlers
would not only target high value non-quota species such as bass
and crustacea, but also may be allowed to keep a by-catch of quota
species. The Panel considers that access to any waters should
only be allowed on a proven track record and that so far as the
inshore fisheries are concerned, ie 0-12, any existing historical
practices should be re-examined.
The Commission has never spent very much time
in dealing with shellfish management and the CFP discussions and
arguments over the years have seldom concentrated on shellfisheries.
As the UK Government is aware, shellfish is of huge importance
to the fishing industry here and provides a third of the landings.
The lack of knowledge and the ignorance of the effect of decisions
by the Commission needs to be immediately addressed. The amendment
to regulation 850/98 concerning crab claws (the initial provision
of 5 per cent itself should never have been allowed) whereby all
boats other than potters would be allowed to land up to 75 kilos
of crab claws per trip was outrageous. This one provision in itself
needs rectification.
So far as Regional Advisory Councils are concerned,
the Panel is sceptical as to whether or not such bodies with no
teeth will provide an improvement or an encumbrance. What is particularly
important is that member states should have absolute control of
inshore waters out to 12 miles and the proposed consultation provisions
of Articles 9 and 8 should be re-visited. Does "consultation"
mean consent?
Proposals to strengthen the monitoring and enforcement
regime are welcomed but additional funding and resources must
be made available as I am sure that SFC's would want to be part
of the Joint Fisheries Inspection structure.
Finally, on the 10 June in London, Dr Franz
Fischler, the E.U. Commissioner, in response to my question concerning
the 1 January 2003 and the fact that time was running out, assured
the meeting that they had power to act if agreement had not been
reached in time. I do hope that circumstances do not conspire
to prove him wrong. We shall be happy to discuss with the U.K.
representatives any detail concerning the Reform which the Department
feels would be helpful. My members are genuinely anxious to assist
in a constructive manner as there appear to be many questions
which could legitimately be raised on parts of the Roadmap and
various Articles, if only for clarification.
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