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SHARKPROJECT Germany e. V.

SHARKPROJECT Germany e.V.

Lobbying Activity

Response to Correction to the multiannual programmes for fisheries

31 Jan 2024

The proposed removal of Article 4(6) from the Baltic and North Sea Fisheries Multi Annual Plans (MAPs) and Article 4(7) from the Western Waters MAPs came without prior consultation and quite unexpected. Indeed the proposed removal would be a turn around of the EU's commitment to the sustainable management of all fish stocks and the application of a precautionary approach in doing so. Allowing spawning stock biomass to fall below the reference point, Blim, and accepting a less than 95% probability that this is NOT happening will substantially weaken the EU's management framework for those fish stocks, many of which are already at risk of being overfished or experience overfishing at this time, allowing those stocks to collapse. SHARKPROJECT is highly concerned about this proposal and the approach taken here with this last minute information and without an appropriate consultation with all stakeholders prior to this ad hoc public consultation and without a thorough environmental impact assessment having been performed prior to that. We also disagree with the assumption that the removal of the 5% rule will be mitigated by alternate measures as foreseen in other articles of the MAPs and emphasize that the removal of the 5% rule in Article 4(6)/4(7) will substantially increase the risk of a stock collapse as stocks can be depleted beyond the currently existing safeguards. Neither will such a shortsighted approach benefit the already massively threatened ecosystems in our oceans nor will it benefit fisheries' interests in the long term as stocks collapse and deprive those dependent on healthy stocks to fish on of their livelihoods in the mid to long term.
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Response to Evaluation of Council Regulation (EC) No 734/2008 on the protection of vulnerable marine ecosystems

30 Jan 2024

Protecting vulnerable marine ecosystems in the high seas from negative impacts from bottom fishing There is increasing evidence that bottom fishing seriously damages deep corals and other fragile benthic habitats. These habitats take an extremely long time to recover, if at all. Bottom trawling also carries major threats to bycatch and climate change. Commercial bottom trawling and pelagic trawling make up 60% of global discards, the highest compared to other types of fishing. In Europe, it is responsible for 93.2%. Disturbing the seafloor also brings potential impacts on the oceans ability to store carbon. The average CO2 emissions from trawling is also the highest compared to other types of fishing, averaging 4.65kg CO2 per kg landed, but up to 46.71kg of CO2. In fact, this is the 3rd highest contributor of CO2 per kg of protein (after beef and Norwegian-farmed salmon). While not all bottom trawling activities cause the same extent of damage to the sea bed it is important to note that especially VMEs - regardless whether in EU waters or in the High Seas outside the jurisdiction of the EU or any RFMOs are recognised as explicitly vulnerable and therefore should all be protected to the same extent as in EU waters where the implementation of the EU Deep Sea Access Regulation in October 2022 has resulted in the first closures of identified and/or expected VME areas in a depth of 400 and 800 m depth to all bottom fishing operations, while these have already been banned in depths beyond 800 m since 2016. Implementing this ban for all bottom gear in EU waters in 2022 has been a longtime overdue measure which has been due to come into action in 2018 already and has therefore been four years delayed. As a result of this time delay many areas with VMEs and VME elements have experienced continued fishing pressure and damage and new areas have been exposed to such damage since then, with fisheries thereafter claiming that these areas should no longer be considered VMEs as already destroyed by the impacts of the bottom fishing activities. The same track record of destruction should not be allowed to be repeated in the High Seas. Therefore, it is important to maintain Council Regulation 734/2008 as is although enforcement of the existing regulation has probably been insufficient in the past and should be strengthened, also considering the low extent of observer coverage currently existing in the High Seas. As this regulation specifically applies only to a limited area in the South West Atlantic (FAO 41) which is the only High Seas area where there is no established RFMO and fishing there is performed only by one EU member state, the economic impacts of the ban apply to a very limited number of vessels, that have so far not been able to fish in identified VMEs or areas without having undergone an appropriate scientific assessment. The balance for the EUs fishing sectors economic goals and the potentially hugely negative impacts on fish populations, threatened species, and the marine environment needs to take this very limited number of vessels into account, which have so far not been able to bottom fish in these regions. It is also important to note that not only the direct impacts to the seabed in VMEs, but also the impact on marine species associated and depending on such important marine habitats (e.g. reefs, seamounts, deep water corals, hydrothermal vents, sponge beds), caused by bottom fishing gear should be evaluated. Conservation and management measures established to prevent negative impacts from fishing, including if necessary, banning all bottom fishing activities in vulnerable marine habitats and especially bottom trawling should be clearly given priority here as affecting extremely sensitive areas and species. Please see attached file for complete response
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Meeting with Caroline Roose (Member of the European Parliament) and Sharkproject Austria

8 Jun 2023 · Requins océan Indien et commerce ailerons

Meeting with Caroline Roose (Member of the European Parliament) and Sciaena - Ocean # Conservation # Awareness and The Shark Trust

18 Nov 2022 · Mesures de conservation requins makos

Response to Communication on the functioning of the Common Fisheries Policy

17 Sept 2022

We have already provided excessive feedback during the public consultation earlier this year but would like to reiterate the core issues of our submission. The CFP as such is a good framework for sustainable fisheries and ecosystem based management and in providing this for all member states as an harmonized approach, "speaking with one voice" it could drive real improvements in EU waters and leverage the EU's position to drive improvements in RFMOs. Therefore, we strongly support the CFP. HOWEVER, the current performance of the CFP "on the water" clearly demonstrates the shortcomings and main problems: - Inadequate implementation - Lack of effective controls - Widespread non compliance in the absence of rigid enforcement And the main reason for those shortcomings is that the EU Commission so far has listened primarily to the arguments from the fishing industry, which are driven solely by economic interests to maintain its current market position or the status quo. Fisheries reject to any improvements towards an ecosystem based fishery management and a wholistic sustainability that might reduce short-term profits even if these measures will improve longterm profitability and ensure future income from healthy marine systems. Therefore, TACs set by the Council of Fisheries Ministers for 2021 were higher than the maximum sustainable catch these stocks could support at their depleted state with most stocks being below the CFP target size able to produce maximum sustainable yields. In the Mediterranean >80% of stocks in European waters continued to be overfished in 2021. As fisheries remain unwilling to reduce their catch or accept higher costs for bycatch mitigation measures and EU Mare continues to support this position of the industrial fishing fleets bycatch of threatened species will not be reduced nor will the destruction of vulnerable ecosystems end and we will continue to waste marine life by non selective fishing practices like bottom trawling or by continuation of economic benefits from the (by)catch of threatened species. Fisheries, DG Mare and the EU Council of Fisheries ministers have to accept increased costs / reduced profits for the industry to stopp the loss of biodiversity and strengthen ocean resilience to combat climate change. Compensation for fisheries losses instead of investments to increase overfishing capacity should be a priority. The Commission should commit to accepting scientific advice even if the advice is "inconvenient" and not appreciated by the fishing sector or the processing sector when their profitability is impacted. Despite clear scientific advice from SCRS at ICCAT DG Mare has continued to reject urgently needed conservation measures for endangered Shortfin mako in the Atlantic. Only after massive public pressure and clear evidence of non compliance of EU fisheries with reporting requirements did DG Mare accept at least a temporary retention ban for the North Atlantic at last year's ICCAT meeting. Yet no measure has been proposed to limit mortality of Shortfin mako in the South Atlantic allowing unregulated and widely unreported bycatch of this species to continue there although scientists have warned since 2017 that this stock experiences overfishing and will soon be on a similar trajectory as in the North. The EU continues to advocate business interests of vocal fisheries and member states over common conservation needs in contradiction to the intent of the CFP. Especially when the status of a stock is uncertain as data are insufficient a precautionary approach of "in dubio pro reo" must be followed. This lack of a precautious approach in guiding the decisions for the CFP results in continued overfishing of already overfished target species and bycatch species without HCRs or realistic rebuilding plans being adopted and scientific advise being ignored. We call to the Commission to make the CFP deliver to its intent, the longterm sustainable management of ocean resources.
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