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Asociatia Nationala a Producatorilor din Pescarie "ROMFISH"

ANPP ROMFISH

1.

Lobbying Activity

Response to EU 2030 Biodiversity Strategy

2 Jan 2020

Nr. RFS 1/02.01.2020 Ref: Ares(2019)7908307 To: ENV.D2 – Biodiversity One of the objectives stated by Common Fisheries Policy is the sustainable development of aquaculture as a way to reduce fish and fisheries products and to reduce commercial fishing pressure to stocks. From the sustainability point of view it is worth mentioning that food industry is responsible for about 29% of the total GHG emissions in EU. Aquaculture has a lowest carbon footprint than most of the other food production sectors. Within aquaculture there are different carbon footprints depending on the farming system, species and intensity. But the importance of different forms of aquaculture such as pond fish farming, shelfish farming or algae production to the biodiversity preservation and restoration is often neglected. To take just the example of pond fish farming which is still widespread in Central and Eastern Europe and has a bi-millennial tradition being highly integrated within the social, environmental and cultural landscape. Low intensive pond fish farming are based upon nutrient recycling using a polyculture of species of different trophic levels and niches. As a result, basically in Central and Eastern European countries, this type of fish farming provided the basis for Natura 2000 sites, mainly due to the great number of bird species which were found just because of the fish ponds managed by the farmers. These fish ponds are not providing only fish for human consumption, but also are providing for the whole society a wide range of ecosystem services which must be recognised, valorised and partially compensated in order to make the fish farmer continue his activities and manage properly the wetland. Today more and more pond fish farmers are ready to drain out the ponds and move towards agriculture (plant or animal husbandry) due to direct payments provided and the simplification of their activity. Pond fish farming is a source to a full range of ecosystem services associated to wetlands: PROVIDER (fish production, fiber production, irrigation and fertilizer source for aquaculture), REGULATION (local climate regulation, water regulation), CULTURAL (raising environmental awareness, important part of the cultural heritage, landscape as a source of inspiration, education and leisure, tourism, birdwatching) and SUPPORT (nutrients sequestration/extraction of N, P, C, wetland preservation, biodiversity preservation through resting, nesting and feeding areas). If looking to nutrient extraction, shellfish culture and algae production are two other forms of aquaculture which should be recognised and supported as having an important role in biodiversity conservation measures. If measures introduced in the CAP through agri-environmental schemes to reduce the environmental impact of agriculture have brought some positive outcomes, then the legislators must consider the larger scale outcomes from aquaculture managing different types of wetlands. Nutrient extraction from surface waters by using non-fed species contributes significantly to the environmental goals. One must not forget that water is not only a resource, but is the living environment for a whole range of fish species and other aquatic organisms and the wetland associated species (plants, birds, mammals, invertebrates a.s.o.) and for this reason fish farmers are the first noting the water quality changes. According to a plethora of research papers it is demonstrated that the wetlands are one of the most productive ecosystems on earth and for this reason farmers contributing to their management should be supported accordingly and this types of aquaculture must be promoted.
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Response to Amendment of products and substances allowed in organic production

4 Aug 2019

Dear Madam/Sir, It would be appropriate to allow in organic production of common carp the use of filter-feeders or macrophyte feeders such as silver carp, big-head carp and grass carp which could be obtained only by assisted reproduction using natural products such as common carp pituitary gland. These three species are very important for the better use of the wasted nutrients in a common carp pond and as long as they are consuming only natural products such as phytoplankton, zooplankton or aquatic plants from an organic pond they could be part of this system.
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