Memorandum by Greenpeace UK
1. INTRODUCTION
1.1 Greenpeace
Greenpeace UK is the autonomous regional office
of Greenpeace, one of the world's leading environmental campaigning
organizations. Greenpeace has regional offices in 40 countries,
2.8 million supporters worldwide and around 150,000 in the UK.
It is independent of governments and businesses, being funded
entirely by individual subscriptions.
The World's oceans have reached a state of crisis.
They are woefully unprotected, hugely overexploited, polluted,
and face the uncertain impacts of global climate change. Supported
by the weight of credible scientific findings, Greenpeace believes
that a crucial part of achieving environmentally balanced and
sustainable oceans is a representative network of large-scale
Marine Reserves covering 40% of our oceans, with environmentally
responsible fishing practiced in the other 60%
1.2 The evidence of overexploitation of
global fisheries is startling:
(i) Large predatory fish species such as
cod, tuna, sharks and swordfish have declined by 90% in the past
50 years. 65% of all fisheries exploited since 1950 have collapsed.
(Myers RA, Worm B (2003). Rapid worldwide depletion of predatory
fish communities. Nature 423: 280-3)
(ii) The European Commission's latest advice
states that 80% of European fish stocks are outside known safe
biological limits
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2007:0295:FIN:EN:PDF
(iii) The UN FAO estimated that in 2003,
76% of the world's assessed fisheries stocks were either fully
exploited, over exploited or depleted.
http://www.fao.org/docrep/007/y5600e/y5600e00.htm
1.3 Moreover, there is widespread and consistent
criticism of the failure of Fisheries management and nowhere is
this more acute than in European waters. In addition to the Court
of Auditors Report, the recent report to the European Commission
by Sissenwine and Symes is a damning critique of the failure of
the CFP:
http://www.greenpeace.org/raw/content/denmark/press/rapporter-og-dokumenter/reflections-on-the-common-fish.pdf
1.4 Greenpeace believes that the solutions
that are needed to address the crisis facing our oceans are well-known,
supported by credible scientific evidence and enjoy popular support.
Only by setting aside large areas off limits to all destructive
activity, including fishing, as Marine Reserves, can we hope to
rebuild the resilience our oceans and our ocean species need,
so that we may exploit them sustainably outside these areas. We
would welcome the opportunity to present evidence to this inquiry.
2. CONSERVATION/MANAGEMENT
Chapter II of Regulation 2371/2002 on the conservation
and sustainable exploitation of fisheries resources under the
CFP introduced new methods of ensuring conservation and sustainability,
including recovery plans, management plans, and emergency measures.
To what extent have these been effective?
2.1.1 The implementation and application
of conservation measures under the CFP are extremely disappointing.
Firstly, a significant number of stocks that are outside safe
biological limits have no recovery plans, and management plans
also remain underutilised. Secondly, many of the plans that have
been adopted are both weak in content and restrictive in the conservation
measures they outline. For instance, little use is being made
of closed areas, fishing bans and specific gear restrictions.
2.1.2 Most, if not all, plans fail to apply
the precautionary principle. In the case of the cod recovery plan,
for example, ICES has recently concluded that since it does not
allow for a complete closure of the cod fishery, it is not consistent
with the precautionary approach (ICES Advisory Committee on Fisheries
Management, North Sea cod 2007).
2.1.3 In particular, the rules aimed at
maintaining relative stability in the annual fishing opportunity
by limiting TAC changes to no more than 15% (up or down) between
any two years, restrain the management of depleted stocks in unsustainable
patterns of overfishing. Given that many stocks are in such a
severe state of depletion that much more drastic cuts in fishing
quotas would be necessary, the 15% rule seems just another misguided
management ploy that favours the short-term interests of the fishing
industry and politicians over the long-term benefits of stock
recovery and sustainable management.
2.1.4 Moreover, many management and recovery
plans have only very recently been adopted and therefore have
not been in place for long enough to show results. No stock has
yet recovered as a result of an EU recovery plan. There is also
considerable pressure both politically and from the fishing industry
to increase levels of fishing at the earliest possible opportunities,
meaning that any apparent recoveries in stocks are seemingly viewed
as short-term bonuses with little long-term consideration.
2.1.5 It makes no coherent sense for marine
conservation to be the (sole) preserve of the CFP, when clearly
protection should be given under Environmental auspices.
2.1.6 Overall, we would respectfully adopt
the following expert conclusions:
"[T]he track record of fisheries management
in Europe has been disastrous." Prof Callum Roberts, The
Unnatural History of the Sea: The Past and Future of Humanity
and Fishing, Octopus Publishing Group, London, 2007, p. 346-7
"Over the past 25 years (1982-2007), EU
institutions have presided over an unparalleled period of decline
for Europe's fishing industries. In denial of the basic principle
of Sustainable Development, they have apparently allowed the satisfaction
of demands by the present generation to compromise the ability
of future generations to meet their needs from the living resources
of Europe's seas. : David Symes `Institutional Issues' in Michael
Sissenwine and David Symes, Reflections on the Common Fisheries
Policy, Report to the General Directorate for Fisheries and
Maritime Affairs of the European Commission, July 2007 at http://www.fishsec.org/downloads/1193925814_63294.pdf
"...EU national-level and European Commission
fisheries advisory groups are often dominated by interests from
the fishing industry through powerful lobbying and this has often
led to scientific advice being ignored or compromised..."
Turning the Tide—Addressing the impact of Fisheries on
the Marine Environment, Twenty-fifth Report of the United
Kingdom Royal Commission on Environmental Pollution, December
2004 at http://www.rcep.org.uk/fishreport.htm
"In summary, the overall performance of
the CFP has been poor. In terms of conservation of fish stocks,
it is doing worse than the US and the rest of the world."
Michael Sissenwine, "Challenges, Peformance and the Future"
in Michael Sissenwine and David Symes, Reflections on the Common
Fisheries Policy, Report to the General Directorate for Fisheries
and Maritime Affairs of the European Commission, July 2007 at
http://www.fishsec.org/downloads/1193925814_63294.pdf
A wide range of management tools are available
to fisheries managers. What are your views on the following tools:
Total Allowable Catches
2.2.1 Setting a TAC for an individual stock
is meant to help keep catch levels at or below sustainable levels.
However, as the European Commission itself reports (COM(2007)295),
the Council of Fisheries Ministers has consistently set EU TACs
50% above the scientifically recommended catch levels. This renders
them useless as a tool for sustainable fisheries management, is
entirely unprecautionary, and instead makes them part of the problem
rather than a solution to overfishing. To the contrary, the US
has passed fisheries legislation that stipulates that TAC must
be set at, or below scientifically recommended levels.
2.2.2 TACs also lose their value when i)
they are set for individual species, which are then caught in
a mixed fishery, and/or ii) fishermen get away with high-grading
their catch by throwing small or undersized fish overboard, so
as to replace them by larger, more valuable, fish.
2.2.3 Clearly TACs must be set at, or below,
scientifically recommended levels, and not simply at levels that
are the result of political bargaining. If there are socio-economic
repercussions associated with setting a recommended low level
of TAC, they should be addressed accordingly, but bending or ignoring
the science to cause as little socio-economic disruption as possible
ultimately helps no one.
Effort limitation, including "days at sea",
marine conservation areas and real-time closures
2.3.1 Days at sea limitations only work
if there is i) consideration taken of the effect that the advancement
of technological improvements have in increasing catching ability
(eg through sonar fish finders), and ii) steps taken that less
time doesn't mean increased effort in a shorter period, but actually
results in a reduction in fishing effort.
2.3.2 Closed areas are a huge part of the
solution, crucially the provision of a network of large-scale
Marine Reserves that crucially prohibit fishing and allow stocks
to recover, thrive, and offer resilience. The current attitude
by the fishing industry is that protected areas should be as small
and unrestricted as possible—and that long term protected
areas are only acceptable in areas they don't want to fish in.
The science says that for any real gain an area must be closed
to all fishing—resulting in bigger animals, bigger stocks,
and greater biodiversity; the essential bedrock of a long-term
future for a sustainable fishing industry.
Technical Conservation Measures
2.4.1 Technical Conservation Measures must
accompany measures aimed at effort and capacity reduction, better
enforcement, and measures aimed to protect particularly sensitive
habitats and species (such as the creation of fully-protected
Marine Reserves), including fish. Fisheries must move towards
selective, non-destructive and sustainable methods of catching
fish. The most destructive methods, such as beam trawling, should
be stopped as soon as possible, and more progressive and selective
measures should be encouraged and promoted.
2.4.2 However, there have been numerous
examples where the conservation objectives of technical measures
have not been achieved (for example acoustic "pingers"
on static nets to deter porpoises, mesh sizes etc.). In such instances
it is imperative that the original conservation objective is addressed—and
if no "technological fix" is forthcoming, action should
be taken in other ways to halt the detrimental impact of these
fisheries, up to and including stopping the fishery.
To what extent have current management tools increased
the levels of discards and bycatch?
2.5.1 Greenpeace has seen first hand the discarding
of perfectly marketable but `non target' fish as part of the North
Sea whitefish fleet, the wholesale destruction ravaged by bottom-trawling
vessels in the North East Atlantic, and the bycatch of threatened
species in the Mediterranean. Similarly the UK's coasts are still
littered with the corpses of dolphins and porpoises that die in
fishing nets in our waters.
2.5.2 Recent debates on the problem of discarding
appear to have spectacularly missed the point in terms of addressing
the main cause of high discarding and bycatch rates: ie destructive
and indiscriminate fishing practices. The solution to discarding
and high by-catch rates is thus neither in the lowering of conservation
standards, nor in the raising of fishing quotas.
2.5.3 Greenpeace agrees that certain policies—in
particular provisions that prohibit the landing of undersized
and over-quota fish but fail to prevent their capture—have
aggravated the problem of fish being wasted as a result of discarding.
What is your view on how these problems can be
best tackled?
2.6.1 Greenpeace supports a discard ban,
so long as it is used to complement other management and conservation
measures, in particular those that lead to more selective and
sustainable fishing practices. A discard ban would move the focus
of management measures from landings to catches and from fish
production to fish mortality. In conformity with the precautionary
approach, by regarding "no discards" as the norm, any
discarding then requires adequate justification (eg high survival
potential). Experience shows that discard bans may be effective
where control of shore-based infrastructure is efficient, and
where other complementary measures, such as introduction of selective
gears and real-time closures, reduce discards to a minimum.
2.6.2 The following considerations should
be noted:
— Any policy on bycatch and discards
must be complementary to, and not replace, other necessary management
measures, such as capacity and effort reduction, technical conservation
measures and area closures, including the establishment of a network
of fully protected large-scale marine reserves that allow species,
stocks, and ecosystems to recover and thrive. Overall, present
stock levels dictate that we need to fish less.
— The key issue is to avoid unwanted
catches in the first place, by prohibiting the most destructive
and indiscriminate forms of fishing and by requiring, for example,
the best available technology for all other gears, as well as
by introducing real-time closures etc.
— An EU policy needs to effectively
tackle all the different types of bycatch (mature [over-quota]
specimen, juveniles, endangered and protected species) and the
two reasons for discarding (high-grading and getting rid of [general]
unwanted catch).
— Greenpeace agrees with the Commission's
proposed approach to tackle the issue on a fishery by fishery
basis, and considers that a range of measures tailored to specific
types of fisheries will be required, but only after the establishment
of a general EU-wide framework within which certain standards
are set—including rules on storage, documentation and landing.
A fishery-by-fishery approach must prioritise the worst offenders,
ie the fisheries with the highest bycatch and discards rates,
for example beam trawls, Nephrops trawls and whitefish
trawls.
— More selective fishing gears and
practices should be promoted, including by providing appropriate
incentives (tax-breaks, financial assistance, preferential licensing
conditions etc), and non-selective gears prohibited or their use
discouraged by introducing licensing and impact assessment requirements
and/or financial disincentives.
— The general framework to reduce bycatch
and eliminate discards should apply to all vessels, although small-scale
vessels may need special consideration, as some will be too small
to carry onboard observers and/or be fitted with VMS.
— Much of the Commission's proposal
relies on industry initiative to, for example, improve the selectivity
of gears, but it should be noted that the sector is not generally
organised in a way suitable to collectively deal with such issues,
and consideration should be given to support development of structures
and processes that can facilitate, for example, the exchange of
best practice, sector-based real-time-reporting on spawning aggregations
and high by-catch rates etc.
Do you consider that fisheries management policies
may need to adapt to climate change?
2.7.1 Yes.
If so, how might this be achieved?
2.7.2 Building in resilience means adaptable
measures, a precautionary approach, and moving towards an ecosystem-based
management. A representative network of large-scale marine reserves
is essential in allowing all marine species (including commercially
important fish stocks) space to survive and thrive, as well as
room to move as and when temperatures and food distribution change.
2.7.3 While every effort is made to reduce
greenhouse gas emissions, it is vital that we build up the resilience
of ocean ecosystems and improve our understanding of the impacts
of climate change on marine ecosystems.
2.7.4 The experts warn that we have depleted
marine biodiversity, and with that have eroded the ocean's ability
to cope with and mitigate the consequences of global warming.
They recommend that we reduce our exploitation levels of marine
fish and other maritime activities in order to improve the resilience
of our seas and oceans and ultimately safeguard their role in
stabilising the climate. Simply aiming at the sustainable use
of sea-life is no longer a sufficient management strategy; marine
protection has become an insurance policy for an unpredictable
future, which will be on average hotter, with more intense extreme
events and more hostile.
2.7.5 Marine Reserves, areas set aside from
all extractive and destructive activities, offer the highest level
of protection for marine life, superior to areas with a limited
number of restrictions. Through protecting the diversity of marine
life, Marine Reserves boost the oceans' capacity to rally its
own defences against a changing climate. In addition, ocean sanctuaries
act as valuable reference areas that can guide complementary management
measures and recovery targets in areas beyond the reserves' boundaries,
so underpinning the ecosystem approach.
2.7.6 In 2001, the United Nations Intergovernmental
Panel on Climate Change (IPCC) warned that climate change in turn
will "affect the physical, biological, and biochemical characteristics
of the oceans and coasts", and warned of "significant
feedback on the climate system" of such changes. In light
of these findings, the Secretariat of the Convention on Biological
Diversity (CBD) has advised that "genetically-diverse populations
and species-rich ecosystems have a greater potential to adapt
to climate change".
2.7.7 Subsequently, the European Commission's
own Research Centre (JRC) advised that "protected areas contribute
to the good health of the ecosystem which then could become relatively
more resilient to environmental changes in comparison with those
affected by additional anthropogenic pressure", and called
for the creation of new conservation areas in Europe's Seas, including
fully protected no-take zones.
3. CONTROL AND
ENFORCEMENT
Chapter V of Regulation 2371/2002 lays down the
responsibilities of the Member States and the Commission as regards
the control and enforcement of the rules of the CFP. The recent
Court of Auditors Report on the control, inspection and sanctions
systems relating to the rules on conservation of Community fisheries
resources was very sceptical of the systems currently in place.
What is your view of the efficacy of the systems in place?
3.1.1 The UN Convention on the Law of the
Sea and the UN Fish Stocks Agreement are clear in so far as the
right of a state to fish is not an absolute right, but is conditional
upon that state meeting its obligation to protect the marine environment
and fish stocks. One of the fundamental failings of the Common
Fisheries Policy is that it separates the exercising of the rights
to fish (rights are allocated exclusively at EU level, largely
through the TACs and quotas system) from the responsibilities
of conserving the marine environment and enforcing fisheries management
rules, which are almost exclusively the responsibility of the
Member States.
3.1.2 Greenpeace has documented first hand
the multiple and varied ways in which illegal, unreported and
unregulated (IUU) fishing are conducted by the nationals of EU
Member States, vessels flagged to EU Member States, vessels fishing
in EU waters and/or operating and landing fish and fish products
in EU ports. In addition, the products of IUU fishing enter the
EU market by road and by air.
3.1.3 Greenpeace agrees fully with the Court
of Auditors Report and is alarmed at the scale of mismanagement
that it has brought to light. Greenpeace would like to underscore
the conclusion that an apparent lack of will amongst the Member
States is to blame for weak EU fisheries management rules and
an even weaker implementation of in particular those rules that
are designed to provide the mechanisms for control and enforcement
at national level (including the use of reporting and accounting
system, statistical analyses, licensing schemes etc).
3.1.4 Not only is there an urgent need to
rectify weaknesses in the rules and application of fisheries legislation,
it appears ludicrous that this level of non-compliance is being
allowed to continue without serious consequences in terms of infringement
procedures, fines, cuts in the allocation of public subsidies
and restrictions on the way operators and Member States continue
to benefit from other EU policies and services. The concept of
"cross-compliance" (which in the EU's agricultural policy
stipulates that farmers must comply with all legislation affecting
their businesses, if they are to receive direct financial aid
from the EU) should be applied to fisheries. It should also be
considered a principle that should be adhered to by the Member
States themselves. For instance, it simply is incomprehensible
that Member States can continue to benefit from subsidies and
the allocation of fishing rights, if they are so evidently in
breach of the most basic EU conservation and fisheries management
rules.
3.1.5 Greenpeace believes that the Commission
should encourage a mandate for EUROPOL to investigate organised
transboundary crime relating to IUU fishing, including but not
limited to the laundering of money earned in IUU fishing. http://ec.europa.eu/fisheries/cfp/governance/consultations/contributions150107/greenpeace.pdf
3.1.6 The issue of the link between organised
crime and fishing has been highlighted by Ben Bradshaw, the then
UK Fisheries Minister,
"Illegal, unreported and unregulated fishing
is a huge problem. It destroys fish stocks and marine biodiversity,
it depresses the market in legally caught fish, and drives legitimate
fishermen out of business.
"It's driven by sophisticated criminal gangs
who don't care what or who they damage in the pursuit of easy
cash. It's a crime that should concern the world, because it plunders
a world resource.
"We all have a responsibility and a duty
to make sure there is adequate governance and enforcement in place
to stop illegal fishing and to block illegal produce entering
the food chain. New laws will target not only fishermen but processors
and importers who trade in illegal fish." http://www.dfid.gov.uk/News/files/illegal-fishing-tracking-system.asp
To what extent has the Community Fisheries Control
Agency already assisted in improving matters?
3.2.1 Given the fact that the CFCA has only
just started to operate, it is too early to judge its contribution.
However, given its weak mandate, we have fairly low expectations
as regards its effectiveness in tackling the problem of IUU fishing
and improving the state of compliance with fisheries rules in
the EU.
The European Commission has regularly highlighted
how serious infringements of the CFP are penalised differently
across the Community. This was a matter that was also raised by
the Court of Auditors and sanctions were included in the recent
Commission Proposal in IUU fishing. What is your view on the issue?
3.3.1 Greenpeace agrees that the EU should
adopt a common approach to sanctions and penalties, including
the introduction of criminal sanctions in severe cases of non-compliance.
In fact, Article 25 (4) of Basic Regulation 2371/2002 already
requires the Council to come forward with a "catalogue of
measures to be applied by Member States relating to serious infringements".
This has not yet been developed.
3.3.2 As well as the problems that inconsistent
application and enforcement bring, this also has an effect on
the perception of European Fisheries management. The pervasive
view of the CFP is that it benefits other countries' fishing industries
and not ours, which may well be reflected in every EU fishing
industry. Lack of clarity, simplicity, and transparency do not
help. Nor does the apparent lack of common sense and action on
things like discards and bycatch - which industry, politicians,
public, NGOs all find unacceptable and scandalous.
4. STRUCTURAL
POLICY
Chapter III of Regulation 2371/2002 obliged
Member States to put in place measures to adjust the capacity
of their fleets in order to achieve a stable and enduring balance
between such fishing capacity and their fishing opportunities.
To what extent has this been successful?
4.1.1 The policy has been entirely unsuccessful.
The EU is still maintaining a fleet that is roughly twice as large
as it should be.
4.1.2 That said, it is clear that effort
reduction measures have had greater impacts on some fishing communities
than on others. Some communities feel that they have suffered
unfairly to the benefit of others. This in part is the result
of crises management, which requires drastic cuts in fishing effort
on those stocks that suffer a severe state of depletion. A more
strategic approach to cutting the EU's fleet size should discourage
unsustainable means of fishing and encourage selective, sustainable
and labour intensive fisheries.
4.1.3 The overall reduction in effort has
not been adequate, and is a result of political timidity against
a vociferous and well-supported industry lobby.
What are your views on the possible impact on
EU fisheries structural policy of WTO-level discussions as regards
subsidies in the fishing sector?
4.2.1 We would refer you to the 2007 Greenpeace
report `Trading Away Our Oceans'; http://oceans.greenpeace.org/raw/content/en/documents-reports/tradingaway.pdf
5. GOVERNANCE
As a result of Regulation 2371/2002, regional
Advisory Councils (RACs) were established to advise the Commission
on matters of fisheries management in respect of certain sea areas
or fishing zones.
How do you consider EU fisheries should ideally
be governed?
5.1.1 The Court of Auditor's Report and
the Sissenwine and Symes study call into question the very framework
and principles on which the CFP is built. A much more substantial
reform of fisheries management in the EU is urgently needed:
5.1.2 Faced with unprecedented crises in
fisheries management, the Community must switch from a focus on
managing the commercialisation of fish to a policy that protects
fish as a principal component of marine biodiversity. Greenpeace
is of the opinion that the conservation of fish stocks should
be managed on the basis of Article 175 of the EC Treaty, that
is as part the EU's environment policy.
5.1.3 Moreover, given the importance of
fully protected marine reserves for the renewal and recovery of
ocean resources, and considering that Member States are over eight
years behind in implementing relating commitments under the Habitats
and Birds Directives, the EU ought to ensure that payment of money
from the EU structural and fisheries funds are made conditional
upon complying fully with the aforementioned Directives (in the
spirit of cross-compliance and the precautionary principle). Likewise,
Member States and ultimately the fishing operators at national
level should be required to verify that they are complying with
fisheries and conservation rules before they are granted fishing
rights.
5.1.4 In addition to ensuring an accelerated
implementation of the above Directives and strict enforcement
of the CFP, the European Commission must provide for a system
that can ensure the prohibition of fishing where it is in conflict
with the conservation needs of a protected area. Greenpeace maintains
that the currently proposed procedure, by which a Member State
that has identified the need to regulate fisheries activities
in order to achieve compliance with Community provisions under
the Habitats and Birds Directives, must first apply for measures
with the European Commission and then with the Council of Fisheries
Ministers, and in addition consult fisheries bodies, such as ICES
and the Regional (Fisheries) Advisory Councils (RACs), contradicts
existing law and is out of line with the EU's commitment to (progressively)
implement the ecosystem approach to fisheries management. It further
is an obstacle to integrated decision making, as it promotes a
scenario in which the Council of Fisheries Ministers may veto
a management decision that has been taken on grounds of conservation
needs. Even if it agrees with the measures, it will have been
an overly-bureaucratic process, wasting time, effort and resources,
and been to the unnecessary detriment of the area designated for
protection.
5.1.5 The current system hinders Member
States in effectively discharging their duties under the Community's
environmental policy. Greenpeace is of the opinion that the European
Commission has failed to consider a number of more constructive
mechanisms for the protection of Natura 2000 sites from fishing,
including:
(i) Amend, if necessary, the Basic Regulation
(Reg. 2371/2002) to place all measures that are aimed at the conservation
of fish stocks firmly in the field of environmental policy, with
Article 175 as the legal basis. In accordance with the Treaty,
measures to ensure a common and stable market, availability of
supplies, etc. would remain under the Common Fisheries Policy,
but measures dealing with fish before they are taken out of the
sea would fall under Article 175 of the EC Treaty. Greenpeace
acknowledges that this would present a change of magnitude and
go beyond the task of ensuring compatibility of conservation and
fisheries policies in Natura 2000 sites.
(ii) Amend the Basic Regulation (Reg. 2371/2002)
to introduce a complete or partial derogation of powers to the
Member States to regulate all or certain aspects of fishing in
all Special Protection Areas (SPAs) (Birds Directive), Sites of
Community Interest (SCIs) and Special Areas of Conservation (SACs)
(Habitats Directive), in recognition of the fact that these sites
are of special conservation interest and therefore require as
a matter of priority a conservation regime that provides immediate
protection. The Common Fisheries Policy already includes a precedent
for the derogation of powers to the Member States in the case
of the "inshore derogation" (Article 9 and 17 of Regulation
2371/2002). This can act as an example for drafting relevant provisions;
or
(iii) Regulate fisheries in Natura 2000
sites by means of Commission Regulations, in recognition of the
fact that the need to restrict fisheries in certain Natura 2000
sites (on the basis of a request from a Member State) results
from provisions under the Community's environmental aquis and
is necessary to ensure consistency and compatibility between Community
laws. It should therefore be considered as a `mundane' implementing
measure that falls under the Commission's implementing powers
under Article 26 of the Basic Regulation, amended if necessary.
How appropriate and feasible do you consider a
regional management model to be?
5.2.1 Greenpeace is of the opinion that
the Court of Auditor's report and the Sissenwine and Symes study
have shown in stark terms that a lack of political will and a
breakdown of the administrative structures that are meant to ensure
compliance with existing rules are at the heart of the mis-management
of EU fisheries. These issues are hardly rectified by the establishment
of RACs.
5.2.2 RACs are unaccountable to the issues
of broader stakeholders, being very biased towards the interest
of the fishing industry. In effect they strengthen the stranglehold
that the fishing industry lobby has on the marine sector, to the
detriment of conservation issues. We need to move instead towards
a different system, with a different set of constituents, and
manage our seas at an ecosystem level.
February 2008
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