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Fiskesekretariatet

FishSec

The Fisheries Secretariat (FishSec) is a non-profit organisation working towards sustainable fisheries in Europe and worldwide.

Lobbying Activity

Meeting with Virginijus Sinkevičius (Commissioner) and

19 Jul 2022 · To exchange views, upon NGO request, on the upcoming Action plan to conserve fisheries resources and protect marine ecosystems, on Commission implementing act on vulnerable marine ecosystems and on European eel status

Meeting with Virginijus Sinkevičius (Commissioner) and

29 Oct 2021 · To discuss with the NGOs the perspectives for the 2022 annual fishing opportunities ahead of international consultations and the December AGRIFISH Council.

Meeting with Virginijus Sinkevičius (Commissioner) and

13 Jul 2021 · To exchange views with the ‘’blue’’ NGOs on the upcoming Action Plan on sustainable fisheries and protection of marine resources, annual exercise of fixing total allowable catches and ongoing WTO negotiations on fisheries subsidies.

Response to Action plan to conserve fisheries resources and protect marine ecosystems

13 May 2021

FishSec position on Roadmap for the Action plan to conserve fisheries resources and protect marine ecosystems -FishSec endorses the production of an Action Plan which will exploit synergies between marine environmental policy and CFP legislation and strengthen the implementation of current EU acquis. -We welcome a joint approach between DG MARE and DG Environment aiming for ecosystem based management. The lack of integration between fisheries and environmental policy has contributed a lot to the problems the Action Plan aims to address. -A connected network of well-managed and fully implemented MPA’s – where fishing is strictly regulated or banned – is needed to meet environmental objectives. FishSec urges that the Action Plan fully reflects the aim of the EU Biodiversity Strategy that at least 30% of the ocean shall be protected by 2030. -We support the recommendations by the European Court of Auditors (ECA) to regulatory and administrative changes that facilitate faster application of conservation measures under the CFP and MSFD; and to extend protection to more species (in particular those classified as critically endangered) and habitats in the light of current scientific knowledge, e.g the critically endangered European eel. -We support the adoption of legally binding restoration targets for fish populations and habitats and encourage drastic and long-term measures to achieve them. We aim to address all listed priorities in the Road map directly or indirectly and look forward to an opportunity to elaborate our proposed actions, which are particularly relevant for Baltic cod. Action 1: When available, the use of more selective gears must be made mandatory to get access to the fishery. (CFP Art. 7.2.C and E) We have observed that selective gears are often not used even when they have been proved effective. Action 2: Area closures for trawlers (CFP Art. 7.2.C) Passive gears are generally much more selective, do less damage to the seabed and consume less energy when deployed. To spatially reserve a minimum of 75 % of all sea areas fished today for fishing with passive gear, would help achieve both environmental and sustainable fisheries objectives, in line with CFP Art. 17. Action 3: MPAs fully closed to all fishing, as default (CFP Art. 8) MPAs fully closed to all fisheries are also easier to control and enforce. Action 4: Lower the fishing capacity ceiling for Baltic Sea fisheries to reflect the collapse of Eastern Baltic cod, and focus on reducing the bottom trawlers Adjustment and management of fishing capacity is part of the CFP, Art. 22. Fleet overcapacity is a key driver of overfishing, high grading and illegal discards. ECA concluded: “The EU fishing capacity ceilings and the Entry Exit Scheme were not designed to respond to the specific circumstances of the EU regional seas and did not consider the environmental impact of different types of fishing techniques”. Action 5: Use EU funds to retrain fishermen without fishing opportunities When fishing capacity is brought in line with the fishing opportunities (CFP Art 22.) many fishermen will have to be re-educated. Action 6: Remote Electronic Monitoring, REM (including cameras) Mandatory REM as part of the ongoing revision of the Control Regulation would be the most effective measure to monitor and control implementation of the CFP. Action 7: Set lower TACs and fishing effort Any ecosystem-based approach (CFP, Article 2.3) to management requires a much higher degree of precaution than today, especially if scientific data is poor or missing. Action 8: Ban targeted fishing of critically endangered species We support the recommendation by the ECA. Action 9: Use more EU funds to improve scientific advice for an ecosystem-based approach to fisheries management Together with the MS, the Commission must consider how to increase the contribution and uptake of future EMFAF funding to support marine conservation objectives, including scientific advice.
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Meeting with Virginijus Sinkevičius (Commissioner) and

12 Feb 2021 · To discuss different blue/marine related issues, in particular bycatch emergency measures, EU-UK negotiations and implementation of the Biodiversity Strategy.

Meeting with Charlina Vitcheva (Director-General Maritime Affairs and Fisheries) and WWF European Policy Programme and

16 Sept 2020 · Workings of the Advisory Councils

Meeting with Agne Razmislaviciute-Palioniene (Cabinet of Commissioner Virginijus Sinkevičius)

21 Jan 2020 · Fisheries in the Baltic Sea

Meeting with Agne Razmislaviciute-Palioniene (Cabinet of Commissioner Virginijus Sinkevičius) and BalticSea2020

21 Jan 2020 · the overall situation in the Baltic Sea and their views on how to overcome the crisis.

Response to Evaluation of the Eel Regulation

10 May 2018

We strongly support the upcoming evaluation and welcome this opportunity to provide feedback on the effectiveness and implementation of the EU Eel Regulation. The population of European eel has declined dramatically since the 1970s*. Recruitment of juvenile eels remains extremely low despite the joint EU management framework, which has now been in place for 10 years. The state of European eel remains critical and further action is urgently needed. Earlier evaluations indicate that the current EU management framework is insufficient and show that implementation of the regulation and of the national eel management plans has been delayed, piecemeal and focused on efforts with little discernible impact on the recovery of the European eel population. Notably, it has been very difficult to measure progress against the main target – at least 40% escapement of silver eels. While a strong focus of resources has been placed on restocking of eel, there is no evidence that this effectively contributes to future recruitment. Most countries maintain a directed fishery, and illegal catches and trafficking of glass eels remain a major problem. Habitat loss and deteriorating water quality also affect eel. The latest assessment of the implementation of the Water Framework Directive shows poor status for around 60% of surface water bodies and a massive presence of migration barriers**. Since the Eel Regulation came into force, some major changes in related EU policies have taken place. Notably, the reform of the Common Fisheries Policy resulted in the new commitment to restoring the biomass of all harvested fish stocks above levels capable of producing Maximum Sustainable Yield (MSY). MSY is also used as a key criterion to assess Good Environmental Status under the Marine Strategy Framework Directive. We are therefore particularly pleased to see the evaluation’s focus on coherence with other EU legislation, as well as with international instruments. We ask the European Commission to ensure that this evaluation of the effectiveness and coherence of the measures taken to aid the recovery of European eel assesses all aspects of eel management and potential options for the future, including: •The objective of 40% escapement of silver eels and whether it is in coherence with the precautionary principle and the MSY objective •The effectiveness of fisheries closures/restrictions for all life stages •The targets and indicators set in the national eel management plans, as well as the national monitoring to measure progress •Reporting and data collection obligations •Restocking practices and the associated overall effectiveness in terms of conservation •Progress on measures to address other major anthropogenic impacts on eel, primarily habitat restoration and removal of migration barriers •The use of public funds (EMFF) and whether it has aided eel recovery •The substantial illegal trade of European eel outside of and inside the EU and its effect on eel conservation •Control and enforcement issues related to the entire chain, from glass eel fisheries to consumption of eel products, including more coordinated action between the Member States’ enforcement agencies •The implementation of EU commitments within the framework of CMS and CITES Bearing all of the above in mind, we look forward to a thorough evaluation of all aspects of the European eel management framework, and to future opportunities to engage with this process. It is our hope that through implementation of urgent measures and better management and protection in the future, we can enable long-term recovery and sustainable exploitation of European eel, but we note that we are a very long way from there today. Submitted by: ClientEarth, European Anglers Alliance, FishSec, Good Fish Foundation, Our Fish, Pew Charitable Trusts, Seas At Risk and WWF *www.ices.dk/sites/pub/Publication%20Reports/Advice/2017/2017/ele.2737.nea.pdf **www.eea.europa.eu/themes/water/status-and-monitoring/
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Meeting with Karmenu Vella (Commissioner) and

23 Jan 2018 · common fisheries policy, multi-annual plans and fisheries control regulation

Response to proposal for a Regulation amending the Baltic multiannual fisheries management plan

11 Jan 2018

In response to the consultation on a Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2016/1139 as regards fishing mortality ranges and safeguard levels for certain herring stocks in the Baltic Sea. Brussels, 18.12.2017 COM(2017) 774 final. 2017/0348 (COD) We note that the CFP does not allow fishing above MSY (MAXIMUM Sustainable Yield) from 2020. We are therefore opposed to the concept of f-upper values in management plans because these by their nature are most often higher values than the F-msy point value and are not coherent with “restoring and maintaining populations of fish stocks above biomass levels capable of producing MSY”, as stated in the CFP. We note that Article 10 (e) of the basic regulation, "Content of multi annual plans” states “conservation reference points consistent with the objectives set out in Article 2”. In this proposal the F-upper figure of 0.21 is proposed and in this case that is the same as the newly proposed F-msy figure. However the previous F-msy figure was 0.15. That figures of 0.15 has now been proposed to be used as the F-lower value. We are concerned that there remains high uncertainty about the stock and the potential for the stock biomass falling below the safeguard levels. Therefore we should not be locking ourselves into this new untested f-upper figure. Fmsy figures can change annually but this new F-upper figure may be fixed for a number of years. This does not demonstrate the required precaution in our view. Best Regards Lindsay Keenan Fisheries Policy Officer The Fisheries Secretariat (FishSec) Prästgatan 9, 111 29 Stockholm, Sweden www.fishsec.org Mobile: +46 (0) 707 100 510
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