Memorandum by the Royal Society for the
Protection of Birds (RSPB)
The RSPB is the largest wildlife conservation
organisation in Europe with over one million members. Wildlife
and the environment face many threats. The RSPB focuses its work
on the species and habitats that are in greatest danger. At EU
level, we work with our BirdLife International Partners to influence
policies that have the biggest impact (negative and positive)
on wildlife, particularly the Common Agricultural Policy, the
Common Fisheries Policy, the Cohesion Policy, the Birds and Habitats
Directives, climate change measures and the Sustainable Development
Strategy.
We welcome many aspects of the Commission's
work programme for 2007, most notably the proposal to amend Directive
2003/87/EEC on the greenhouse gas emission allowance trading and
the legislative initiative to reduce CO2 emissions from light
duty vehicles. However, we believe that two further initiatives
should be included in the Commission's work programme for 2007.
1. PERMANENT
BAN ON
IMPORTATION OF
WILD BIRDS
INTO THE
EU
1.1 The EU is the last large-scale importer
of wild birds in the world, importing an estimated 1-2 million
birds each year, 90 per cent of the international registered market.
Yet information on wild populations of these birds is almost entirely
lacking. EU laws supposedly regulate the trade in the most threatened
species but, even for these, there is a genuine paucity of information.
The failings of these rules can be seen in that species that are
regularly traded under EU permit have to be regularly upgraded
to those that consequently require a full import ban due to critical
conservation impacts.
1.2 The trade also raises serious concerns
about animal welfare and potential threats to both animal and
human health. Following the publication of a European Food Safety
Authority (EFSA) report that outlined appalling mortality and
welfare issues associated with this trade, the UK Government has
adopted a policy of seeking a ban on the importation of wild birds
into the EU for conservation, animal welfare and health reasons.
(The Government acknowledges the need for possible exceptions
for strict conservation reasons.) A letter from the Prime Minister
(dated 30 November 2006) assured interested parties that "the
UK intends to press other member states and the European Commission
to extend indefinitely the ban on the commercial importation of
wild birds".
1.3 A spokesperson for the EU Environment
Commissioner has been quoted (European Voice, 16 November 2006)
as acknowledging that the Commissioner would support a total ban
on EU wild bird trade. Yet the Commission has made no formal proposals
for 2007 to ban the trade on the basis of conservation (or welfare).
If a permanent ban does emerge on health grounds, it is quite
possible that this will be overturned in the medium term if health
fears surrounding Avian Flu decline, leaving the trade to re-start.
1.4 The RSPB believes that a lasting EU
ban must be imposed on conservation, welfare and health grounds
if this unnecessary trade is to end.
2. EUROPEAN COMMUNITY
PLAN OF
ACTION ON
SEABIRDS
2.1 BirdLife International estimates that
every year 300,000 birds, including 100,000 albatrosses, are killed
by longline fishing. In 1999, the United Nations Food and Agriculture
Organisation (FAO) developed an International Plan of Action (IPOA)
to tackle seabird by-catch. This voluntary initiative provides
practical guidelines for reducing seabird mortality on longlines.
The FAO is encouraging member countries to assess their own seabird
by-catch problem and to develop and implement a National Plan
of Action, based on the recommendations listed in the IPOA. Several
global fishing nations have produced and implemented National
Plans of Action but progress is slow and several key countries
are still in a state of denial that they have a by-catch problem
or that they need a formal plan.
2.2 In line with its commitments under the
IPOA-SEABIRDS, the European Commission produced a "preliminary
draft" proposal for a Community Plan of Action for reducing
seabird by-catch in time to report to the 24th (2001) session
of the FAO's Committee on Fisheries (COFI). However, there has
never been any elaboration of this draft, despite the fact that
the Commission set a target to propose legislation on this Community
Action Plan before the end of 2003 (see COM(2002)186 final). At
the Malahide meeting on "Biodiversity in the EU" during
the Irish Presidency, the Commission was part of a stakeholder
group which set a new target of establishing a Seabird Plan of
Action by 2006. However, the Commission has not met this target,
shows no political will to take this forward, and the plan does
not feature in their work programme for 2007.
2.3 The RSPB believes that it is essential
that the Commission presents a Community Plan of Action to reduce
incidental mortality of seabirds in longline fisheries in 2007.
This should include consideration of EC distant water fleets (external
fisheries) as well as fisheries within Community waters. BirdLife
International is currently compiling the evidence that a Community
Plan is needed and has offered to assist the Commission in drawing
up their proposals.
December 2006
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