APPENDIX 10
Memorandum submitted by The Wildlife Trusts
(K18)
The Wildlife Trusts welcomes the opportunity
to submit evidence to this inquiry. The Wildlife Trusts advocates
fisheries management which maintains the balance between fishing
effort and living marine resources, thus ensuring the long-term
sustainability of fish stocks and a more stable marine environment.
As members of six of the locally based Sea Fishery Committees,
The Wildlife Trusts plays a key role in delivering science-based
advocacy to the fishing industry and its managers in England,
Wales, Scotland and Northern Ireland.
The Wildlife Trusts are a unique partnership
of 47 local Wildlife Trusts covering the whole of the UK and the
Isle of Man. The partnership campaigns for the protection of wildlife
and invests in the future by helping people of all ages to gain
a greater appreciation and understanding of nature. Collectively
The Wildlife Trusts have approximately 382,000 members and manage
almost 2,500 nature reserves, covering more than 76,000 hectares
of land, ranging from inner city urban sites to the UK's finest
wildlife areas.
We have considered the Commission's proposals
for the first set of reforms and would like to make the following
observations.
1. There is no doubt that long-term mismanagement
of the European Union's fish resources has put the environment,
fish stocks and fishing communities in an unsustainable manner.
The original CFP Green Paper portrayed the CFP as a policy that
has failed to provide adequate management of EU fisheries and
identifies candidly several major failures of the existing system.
The Wildlife Trusts welcomed the acknowledgement by the Commission
of the main drivers for the current crisis, namely over capacity,
inadequately targeted subsidies and inequitable fisheries agreements.
We also endorsed fully the shift in focus in the Green Paper towards
the promotion of sustainable ecosystem-based fisheries management.
The Wildlife Trusts believed that the original Green Paper provided
a good basis for discussion and offered some tangible solutions
towards recovery of dwindling resources, a declining industry,
and a degraded ecosystem. However, we feel the Commissions proposals
fall far from what is needed to achieve a strategic policy which
provides SMART targets and indicators on which to base the long-term
sustainable management of EU fisheries.
2. The Wildlife Trusts are very concerned
that the new draft Framework regulation has failed to give any
emphasis to delivering the requirements of the Habitats and Birds
Directives. In order to meet the requirements of the Habitats
and Birds Directives, strategic management plans would need to
be developed to ensure that fishing activities occurring within
inshore and offshore Special Areas of Conservation (SACs) and
Special Protection Areas (SPAs) meet with the conservation objectives
of the site. Plans for inshore sites have already been developed
in some Member States; for example the LIFE funded marine SAC
initiative in the UK. Under Article 12 of the Habitats Directive,
a mechanism should also be identified for ensuring that fishing
activities do not have negative impacts on populations of cetaceans
and turtles.
3. We are very disappointed that the road
map did not consider the ecosystem approach as one of the key
principles and objectives of the CFP. We believe in order to retain
a healthy ecosystem with abundant fish stocks, it is necessary
to move away from the conventional focus on single target species,
and to adopt an ecosystem-based approach to management. Such an
ecosystem-based approach is central to the system of management
endorsed by the Council Integration Strategy, the EC Communication
on the Integration Strategy and the EC Biodiversity Action Plan
for Fisheries, and is embodied in the objectives of the CBD, the
UN Fish Stocks Agreement and the FAO Code of Conduct. The Wildlife
Trusts believe it is essential that an ecosystem-based approach
should therefore be adopted at all levels of decision making under
the CFP, including decisions concerning fleet restructuring, subsidisation,
marketing and processing, and external relations.
The ecosystem approach to fisheries management
takes a step beyond single or even multi-species approaches but
considers the management of all the processes essential for maintaining
a natural and healthy ecosystem. It involves safeguarding not
only food chains but also habitats and wider environmental interactions.
In 1997, at a North Sea Ministerial Meeting on fisheries and the
environment, the need for an ecosystem approach was recognised
by environment and fisheries ministers alike. This recognition
was reaffirmed when environment ministers adopted the new OSPAR
Annex V on the protection of biodiversity and ecosystems in 1998.
Yet, again, this has not been applied. The ecosystem approach
will not only aid recovery plans for commercial fish stocks but
will also benefit all species which spend all or part of their
life in our coastal and marine environments. The ecosystem approach
to the management of fisheries is essential for the successful
integration of fishery and nature conservation objectives.
4. The Wildlife Trusts are disappointed
that neither the precautionary principle nor adaptive management
styles have been considered by the Road Map as priorities. We
believe these principles must be accepted otherwise it will not
be possible to develop a new CFP, which is capable of providing
sustainable development in environmental, economic and social
terms. In the absence of scientific information on the impacts
of fisheries on biodiversity, conservation measures should be
adopted in line with the precautionary principle, particularly
in cases where fishing activities are likely to result in serious
or irreversible damage. Adaptive systems of management with proper
and transparent auditing systems are central to the success of
fisheries management systems in other parts of the world, such
as that underpinning the Convention for the Conservation of Antarctic
Marine Living Resources (CCAMLR).
5. The Wildlife Trusts believe that the
precautionary approach must be seen as one of the most important
underlying principles of the future CFP. The need for the precautionary
principle was recognised in the 1980s when Environment Ministers
were considering future management and environmental protection
for one of the most productive but intensively used seas of the
world—the North Sea. Over the past two decades the principle
and its application have been widely discussed and adopted in
a variety of international agreements, declarations and conventions.
The reason we need to apply this approach is that we will never
have a full understanding of the marine environment, which is
a dynamic and complicated ecosystem.
6. The Wildlife Trusts believe that the
underlying principle for future policies for the management of
fisheries should include the conservation of marine biodiversity
as a major objective. An approach that is based on maintaining
the health of the ecosystems, upon which both wildlife and fishermen
depend, is one that is most likely to deliver a sustainable future
for both.
7. We are pleased to see that the roadmap
advocates greater openness and transparency, and the participation,
through greater and broader stakeholder involvement. Local participation
in the management of sea fisheries will also allow more scope
for the contribution of local fishermen to the decision making
process. The current situation tends to lead to fishermen feeling
excluded from the major decisions that affect them. As well as
cutting off a useful source of local knowledge, such alienation
may lead to increased levels of non-compliance. As the Roadmap
suggests it will take more than changes in the regulatory framework
to deliver a sustainable future for inshore fisheries. Financial
support for pilot projects investigating new management techniques
and to cushion the effects of transition between regimes will
be required. Developments in the business infrastructure supporting
the industry may also be beneficial; developments that will undoubtedly
need funding.
8. A number of European funding programmes
are available to support structural development within the fishing
industry. Objective 1 and Objective 2 funding, under the European
Regional Development Fund (ERDF) and the European Social Fund
(ESF) is aimed at general economic development, which may include
fisheries, and is available for specific areas within the UK.
This is complemented by the Financial Instrument for Fisheries
Guidance (FIFG) which is aimed specifically at providing investment
in the fishing and aquaculture industries and is available throughout
the UK outside Objective 1 areas. However, experience to date
suggests that the delivery of sustainable inshore fisheries may
be seriously threatened by a lack of co-ordination between different
programmes. The situation in the South West of England Objective
2 area provides an example. A Single Programming Document (SPD)
sets out priorities for structural funding in the region and one
of the measures is aimed at "Regenerating Fishing Communities".
These are contrary to the measures outlined in the Roadmap. Which
states that there will be "restriction on the aid for modernisation,
renewal and export of fishing vessels". The commission also
states in the Roadmap that the "possibility of granting public
aid for the new capacity be removed". The Wildlife trusts
believe that this should come into affect immediately and that
steps are taken to ensure that the recommendations in the roadmap
are translated on the ground with immediate effect.
9. The incidental capture of animals in
fishing gear (bycatch) is considered to be one of the greatest
threats facing small cetacean population's world-wide. Every January
during the winter storms 100's of carcasses of common dolphins
and porpoises are washed ashore in the Southwest. This is not
a new phenomenon but has been a regular occurrence for the last
five years. The Wildlife Trusts working with the Plymouth aquarium
have collated information on this issue and with other NGO's have
created considerable publicity on this horrific and unnecessary
problem. We have also lobbied the government and the EU commission
and provided them with our results and made certain demands in
order to reduce this problem. Yet despite all this publicity and
evidence of an unsustainable fishery the bycatch of small cetaceans
continues.
10. Members of the European Union are already
committed under Council Directive 92/43/EEC (the Habitats Directive)
to establish a system to monitor the incidental capture and killing
of all cetaceans and, in light of the information gathered, to
take further research or conservation measures as required to
ensure that incidental capture and killing does not have a significant
negative impact on the species concerned.
11. Last summer Member States which includes
the UK that are Parties to the Agreement on the Conservation of
Small Cetaceans of the Baltic and North Seas (ASCOBANS) have acknowledged
the threat that bycatch poses to small cetacean populations and
have committed themselves to ensuring that where unacceptable
bycatch is identified, measures are taken to reduce this level
of bycatch. Parties have agreed for the present to define unacceptable
interactions as being, in the short term, "a total anthropogenic
removal above 1.7 per cent" of the population.[1]
12. The only direct way to obtain reliable
estimates of total marine mammal bycatch in a fishery is via an
independent observer scheme covering a representative sample of
the fishery. The UK has failed to implement such a scheme and
are therefore unaware of the precise nature of the problem associated
with the pelagic trawl fishery in the Southwest. Despite unacceptable
bycatch levels being identified in UK waters, there has been no
demonstrable reduction in bycatch to date. In general, Member
States are failing to fulfil their obligations on incidental capture
set out in the Habitats Directive and Parties to ASCOBANS have
failed to meet the specific commitments made under this Agreement
with respect to bycatch.
13. There should be a much wider deployment
of independent on-board observers to monitor bycatch of non-target
species such as small cetaceans. This would also help inform the
development of the EU's National Plan of Action to reduce seabird
bycatch in longline fisheries. In New Zealand, observers are part
funded by the fishing industry through a Conservation Services
Levy Programme. This model could be adopted in the UK, either
working alongside the Sea Fish Industry Authority (SFIA) levy,
or as an additional function of the SFIA levy.
14. A generic approach to addressing the
variety of bycatch problems, that meets Member States' conservation
obligations and objectives, should be adopted by Member States
and formalised within the Common Fisheries Policy of the EU. We
are extremely disappointed that such provisions have not been
formally adopted during the current CFP review. The Wildlife Trusts
are calling for a new CFP to contain clear and measurable commitments
to reduce significantly bycatch in the EU fishing fleet within
the next five years and to reform subsidies to ensure they support
sustainable fishing.
15. The Wildlife Trusts believe that the
Roadmap is particularly weak in terms of developing policy for
the sustainable management of aquaculture. By far the most pronounced
aquaculture-derived environmental impacts within Community waters
result from finfish culture. Through a combination of the scale
of production, techniques utilised in the husbandry, and the often
enclosed nature of the environment in which fish farming is undertaken,
it results in impacts including:
16. The green paper acknowledged the increasing
industrialisation of aquaculture throughout the community. Unfortunately
the need for a co-ordinated strategy for guiding the development
of this expanding industry at a Member State and Community level
is not highlighted within the roadmap or regulations. The inclusion
of aquaculture into the CFP would provide an important opportunity
for the principles of sustainability, integration of environmental
concerns and the adoption of an ecosystem approach to be extended
to Community aquaculture policy, planning and financial assistance.
The Wildlife Trusts see such a strategic view as essential.
17. Clear strategic guidance should be given
on the development of aquaculture both within the EC and Member
States. This should be transparent and subject to environmental
appraisal, covering the full life-cycle of aquaculture production.
Strategic environmental assessments should be applied to all aquaculture
development plans to ensure that cumulative impacts of developments
are properly considered. In particular, new regulatory measures
need to be adopted to minimise the impacts of aquaculture on wild
fish populations through ecological and genetic effects and disease
and parasite transfer.
18. The Green Paper recognised the role
FIFG has played in providing capital grants to aquaculture companies.
It is vital that aquaculture policy learns from the problems of
encouraging intensive, high-impact terrestrial farming through
the CAP and uses the CFP reform to put measures in place to encourage
a more sustainable responsible approach to marine fish and shellfish
farming in the community. Existing policies, particularly relating
to funding, should be reviewed to ensure that no EC support is
being given to aquaculture developments that are likely to impact
negatively on the environment. Conversely, active support should
be given to the development of environmentally benign aquaculture
practices and to initiatives such as eco-labelling in order to
assist these.
CONCLUDING REMARKS
19. There can be a healthy future for the
European fishery, provided that the plans for their management
do not neglect the ecosystems and habitats on which they depend.
There need be no conflict between our vision for a healthy marine
environment and the development of an inshore fishery, which provides
for the needs of fishermen and the communities in which they live.
All it takes is for us all to share a common vision for the future,
to have the imagination to see the changes that are needed and
to work together to bring them about. The Wildlife Trusts believe
the Roadmap and Regulation fall from implementing this vision.
20. But there is little point in fisheries
management taking account of ecosystems and habitats if other
human activities continue to place them under pressure. The mistake
in the past has been to consider each human activity in the marine
environment in isolation.
21. True sustainability will only be achieved
through a single strategic approach to the management of all human
activity in the marine environment, an approach that includes
the conservation of marine biodiversity as a major objective.
We would like to see the Commission stating how they see the CFP
review and reform integrating with the EU Marine Directive that
is to be published in July of this year.
Finally, The Wildlife Trusts have recently produced
a report on the future of inshore fisheries (Annex 1 [not printed]).
The recommendations in the report our based on our experiences
over the last five years as members of the Sea Fisheries Committee's.
Although the CFP does not cover the inshore are it is important
the Committee recognises that inshore waters are of particular
value to marine biodiversity, encompassing a wide range of seabed
habitats and marine communities. The same areas are also important
to the fishing industry, especially small vessels limited to grounds
close to their homeports. It follows that establishing sustainable
management regimes in inshore waters is of the highest priority,
with fisheries managed in a way, which enables both wildlife and
fishermen to thrive.
14 September 2002
1 Northridge SP and Hammond P S. 1999. Estimation
of porpoise mortality in UK gill and tangle net fisheries in the
North Sea and west of Scotland. Paper SC/51/SM42 submitted to
International Whaling Commission Scientific Committee. Back
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