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Nederlandse Elasmobranchen Vereniging

NEV

De Nederlandse Elasmobranchen Vereniging is in 2010 opgericht met als doel de kennis over haaien en roggen in te verbeteren om zo de populaties beter te kunnen beheren en waar nodig te beschermen.

Lobbying Activity

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.

Response to Amendment to the delegated act on the functioning of the Advisory Councils under the Common Fisheries Policy

10 Sept 2021

We welcome the Commission’s draft Delegated Act (DA) and efforts on the improvement of the functioning of the Advisory Councils (ACs), but we would like to bring to your attention some fundamental improvements that are still needed to ensure the functioning and the legitimacy of the ACs. Having worked in several advisory concils in the past seven years both in vice chair and working group chair roles we have experienced that transparent, balanced, and informed recommendations and suggestions by ACs are critical to comply with Art. 43(1) of the Common Fisheries Policy (CFP).The current way the ACs are organised can prevent these from being formed. In both 2019 and 2020 many NGO’s wrote about this to the commission (see annexes) indicated the changes that would be needed to make the ACs a fair and balanced forum. We support the requirements on working methods under art. 5, as well as article 7a, which would require an independent performance review to be conducted at least once every 5 years for each AC. These evaluations, and the requirement for an action plan to address any identified shortcomings, will contribute to improving ACs’ functioning, provided that they are followed up with immediate actions when ACs are not performing well, and there are direct consequences when shortcomings are not properly addressed. We, therefore, consider that this DA should provide for the possibility of sanctions and of suspending ACs funding in case of failure to address deficienceis identified by the independent performance review and implement adequately improvements. We welcome the efforts to clarify the classification of members in one of the two categories of stakeholders. However, while recognizing the importance to keep the door open to any interest groups affected by the CFP (per article 45(1)(b) CFP), we are concerned about the specific inclusion in the “other interest group” of any ‘organisation that represents or has direct or indirect economic interests linked to the use of the marine environment or maritime space other than commercial fishing, aquaculture or the processing, marketing, distribution and retail of seafood.' (Annex, art. 2(b)). We believe that these organisations representing or having direct or indirect economic interests should rather be included in the sector organization group, as their interests, although not directly linked to fisheries or aquaculture, remain economic. This should be the main criterion for differentiating between sector organisations and other interest groups, and the Commission should define general criteria for the categorisation of economic and non-economic interest in expert groups, as stated by the European Ombudsman in its decision OI/6/2014/NF. In addition, it is regrettable that the DA fails to address the persisting lack of compliance with the required balanced composition of ACs as per Article 43(1) CFP. In particular, we regret that it does not introduce a more balanced composition between sector organisations and other interest groups, ensuring a strictly 50/50 representation when voting. The lack of balance has been one of the main drivers for inequality and conflict within the ACs and has been repeatedly given as one of the ain reasons NGos are less willing to participate in ACs. Increasing the Executive Committee membership to a maximum of 30 members. As proposed in Article 4.1, therefore goes against the need for balance even further. Furthermore, when consensus is not possible to reach, the DA must ensure minority positions and dissenting opinions are duly recorded by the ACs. Article 5.c now appears to give the opportunity to the majority to object to a minority position being added to advice as the text implies voting will be allowed on the dissenting position. Finally, we believe that the DA should clarify that the ACs are “Commission expert groups” as defined by the Commission’s decision C(2016)3301 and that they should, as such, align with the horizontal rules stat
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Response to Action plan to conserve fisheries resources and protect marine ecosystems

13 May 2021

Recommendations on elasmobranch (shark and ray) management and conservation for the European Commission’s Action plan to conserve fisheries resources and protect marine ecosystems Contribution on behalf of: iSea (Greece), APECE (Portugal), SharkTrust (EU & UK), SUBMON (Spain), Sharklab-Malta, Marine & Environmental Research (MER) Lab (Cyprus) and Dutch Elasmobranch Society (Netherlands) We welcome the opportunity to contribute to the public consultation on the Action plan to conserve fisheries resources and protect marine ecosystems that will be part of the EU Green Deal strategy. We specifically welcome the 1st and 2nd objective of the strategy that focus on the need to decrease the bycatch of endangered and threatened species, as well as the need to ensure fisheries management measures in MPAs have a positive impact on the conservation of threatened species. As organisations focussed on the management of elasmobranchs we stress the urgent need to implement the objectives the EU and its Member States signed up to in the 2009 Community Plan of Action for the Conservation and Management of Sharks (CPOA-sharks). We call on the Commission to ensure the new Action plan has the strength to deliver much needed actions listed in the CPOA-sharks are followed through. Elasmobranchs are among the most vulnerable marine species. A recent study published in Nature showed that the global population of pelagic sharks has decreased by over 70% in the past 3 decades , this decline is almost exclusively driven by unsustainable fisheries. In Europe at least 40% of shark and ray species are threatened with extinction . With little effort to decrease fishing mortality. To curb this negative trend, more effort is needed to better protect these species and to effectively manage the fisheries that impact upon them. The EU acknowledged more needed to be done to protect elasmobranchs when it adopted the CPOA-Sharks in 2009. This Action Plan sets out management targets for that, if adhered to, would ensure European elasmobranch populations could flourish. The action plan was reviewed by STECF in 2019 and the conclusions of the independent scientific panel were that hardly any of the objectives had been met, and more effort was needed to effectively manage and protect elasmobranchs in Europe. To date many species still have no management measures or catch restrictions associated with them, only the most endangered species have a catch prohibition under the Technical measures regulation / TAC & Quota regulation but this is not linked to any conservation, protection or rebuilding measures. To ensure the sustainable management of sharks and rays in Europe the new Action plan to conserve fisheries resources and protect marine ecosystems should at least include the following: 1) Stock assessments for all elasmobranch species caught as target or bycatch in EU fisheries, with associated funding to bridge knowledge gaps 2) An obligation to have a conservation and management plan for all species on the prohibited species list with the aim to rebuild populations to healthy levels 3) EU to champion shark conservation in Regional Fisheries Management Organisations, advocating for fins attached policies in all RFMO’s, and strictly following scientific advice on catch limits. 4) Binding targets for member states on the ambition for protection of essential habitats for shark and ray species in their Nature2000 / MSFD sites The European Green Deal was introduced as a transformative agenda, a clean break with past policies that focused too much on economic gains and left little room for nature and the environment. The integration of previous species and habitat action plans into an ambitious overarching action plan fits into this strategy, and should lead to an accelerated and high ambition agenda. Sharks and rays of Europe deserve nothing less. For further information, please contact: Irene Kingma Dutch Elasmobranch Society kingma@elamsmobranch.nl
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Meeting with Charlina Vitcheva (Director-General Maritime Affairs and Fisheries) and WWF European Policy Programme and

16 Sept 2020 · Workings of the Advisory Councils