February 2023

Thursday 9 February 2023

Dear Friends,

Seize the Opportunity to Implement Article 17 of the Common Fisheries Policy: A necessary step towards Sustainable Fishing and Thriving Coastal Communities

The Low Impact Fishers of Europe (LIFE) Platform is a Europe-wide platform of 32 member associations from 15 Member States, representing around 10.000 small-scale fishers committed to fishing in a low impact manner.

Evidence shows that our way of fishing – using the right gear, in the right place at the right time – is the key to achieving the sustainability goals of the Common Fisheries Policy. As a matter of urgency, we call on legislators to adopt a differentiated approach to the management of small and large scale fisheries, as set out in LIFE’s “Call to Action”.

Article 17 of the Basic Regulation (EU Regulation 1380/2013) requires that Member States allocate fishing opportunities using “objective and transparent criteria, including those of an environmental, social and economic nature”, and calls on Member States “to endeavour to provide incentives to fishing vessels deploying selective fishing gear or using fishing techniques with reduced environmental impact.”

Up to now, catch history has been the main criterion used to allocate fishing opportunities. Such a status quo approach fails to harness the potential of Article 17, effectively rewarding those who fish more, rather than rewarding those who fish in a more sustainable manner.

Fishing opportunities and the way in which they are allocated could provide a powerful tool for shifting effort away from intensive high impact fishing to low intensity low impact fishing, through the use of Article 17. However, the potential of Article 17 to bring about such change has hardly been explored. Information provided by Member States on the methods used to allocate fishing opportunities is partial^[1]. In addition, no definition of social criteria is provided in any EU regulation, so interpretation of social criteria is still open to debate. Article 17 needs to be made fit for purpose, and the Commission needs to take the lead in this regard.

The implementation of the 2013 Common Fisheries Policy (CFP), on which the Commission is about to report, has missed a huge opportunity to steer European fisheries towards carbon neutral, economically viable, socially just and environmentally sustainable fisheries. To this end the Low Impact Fishers of Europe (LIFE) Platform call on:

• Member State governments – to work with all fleet segments, to develop and publish transparent and objective criteria of an environmental, social and economic nature and to deliver a fair transition to low-impact, low-carbon fishing and fairer and more secure access to resources for small scale fishers;
• European Commission – to support and encourage Member States to implement Article 17 by providing guidelines and a detailed implementation plan, with a requirement for Member States to report on progress on an annual basis;
• Members of the European Parliament – to support the legislative development of Article 17, and its full and appropriate implementation at Member State level.

In collaboration with the NGO “OurFish”, the Low Impact Fishers of Europe (LIFE), has produced a report and made recommendations on how Article 17 could be applied in a step by step manner, using different criteria to reward good practice, to encourage greater economic efficiency, and to safeguard smaller-scale lower impact fishing. Other relevant reports include by the Vertigolab on the Methodological Considerations  of an Allocation of Fishing Quotas  Based on Social and Environmental Criteria, the European Parliament Resolution on Article 17, and the European Parliament Resolution on the small-scale fisheries situation in the EU and future perspectives.

Smaller-scale, lower impact fishing activities can, and should, provide part of the solution to addressing Europe’s overfished seas, halt the loss of marine biodiversity, reduce unwanted catches of small fish and reverse the declining fortunes of fishing communities and the small-scale enterprises which provide their livelihoods. For decades, the CFP has discriminated against this fleet segment in the way fishing opportunities have been allocated. But, beyond the need for fair access to resources, LIFE is convinced that full implementation of Article 17 will bring about a transition towards low-impact, low-carbon fishing that also contributes to meeting global climate and biodiversity goals, in line with European Green Deal ambitions and UN Sustainable Development Goal Target 14b.

With this letter we would like to kindly ask for a meeting with you to further discuss this issue in the coming period. Looking forward to hearing from you.

Yours truly,

Marta Cavallé

Executive Secretary

^[1] STECF Report (20-14) on the Social  Dimension of the CFP. 2020 https://stecf.jrc.ec.europa.eu/documents/43805/2672864/STECF+20-14+-+Social+dimension+CFP.pdf/a68c6c42-6b64-41fc-b5a0-b724c71aa78e?version=1.1&download=true

This month, the European Parliament held a hearing on the status of the Multiannual Plan (MAP) for the Baltic Sea. Stakeholders from the region were invited to share their point of view and concerns, including LIFE who was represented by a presentation on small-scale fishermen in the Baltic Sea by Katarzyna Stepanowska. She gave details of the decline of Eastern Baltic cod in the region, which has been ongoing for decades.

At the hearing, it became clear that stakeholders consider the MAP, adopted in 2016 to manage cod, herring and sprat sustainably, to be a failure. Jarek Zieliński, chair of the BSAC (Baltic Sea Advisory Council), said BSAC members supported a reform of the management plan. Cathrine Pedersen Schirmer of the Danish Society for Nature Conservation argued that all three legislative objectives of the MAGP had not been implemented.

Moreover, MAP has failed to adequately protect small-scale fishermen, who make up over 90% of the fleet in terms of number of vessels and provide 65% of jobs at sea, but receive only 7% of the catch.  To make matters worse, 90 % of the fish biomass extracted from the Baltic Sea is destined for industrial processing, mainly as fishmeal and fish oil for animal feed.

Vesa Tschernij from the Simrishamn Municipality Marine Centre, Sweden, pointed out the stark contrast between food fishing and reduction fishing, noting that eleven times more fish are needed to generate the same income from reduction fishing.

Against this background, LIFE calls for a revision of the Baltic Sea MAP to include a cod recovery plan and measures for the management of plaice and flounder, which have become important but were not included in the original version of MAP.