
News


Christmas Council Annual Quota Carve Up: Getting the Balance Right
LIFE calls for a more level playing field and a fairer allocation of quota between larger scale and smaller scale fisheries.
19th December 2018
Update: LIFE reacts to the Council’s agreement on bass and eel
LIFE is disappointed to note that Fisheries Ministers have failed to grasp the economic importance and the social and environmental significance of the commercial hook and line fishery for seabass. Instead of rewarding this sector with a significantly increased allocation, rather they have seen fit to increase the allowance for mobile gears, doubling the allowance for demersal trawlers. This sends out the wrong signals and raises questions on the political will of the Council to take serious measures to conserve northern sea bass. It is also a lost opportunity to apply the spirit of Article 17 by rewarding and giving incentives with increased access those fishing vessels deploying selective fishing gear and using fishing techniques with reduced environmental impact.
On the positive side, LIFE notes that the 1% cap on fixed netters has been lifted, and their allowance raised from 1.2 to 1.4 tonnes over the year. This is a lifeline for those fishers who use small-scale fixed nets in mixed fisheries, and for whom by-catches of seabass provide a vital economic contribution to their struggling livelihoods.
But the devil is in the detail, and we look forward to seeing the revised text of the EC proposal on 2019 fishing opportunities.
Based on the information available[1] following the conclusion of Council negotiations, LIFE cautiously welcomes the outcome for European eel stock. For a long-lived species such as eel, it is makes sense to continue the coordinated closures at national level and have them broadly applied – for all eel life stages, in particular the glass eel, and to recreational fisheries.
The work towards the much-needed eel recovery is far from over. We urge the EU Institutions to elaborate a full, credible and realistic package of actions to make sure that European eel has a bright future. It must squeeze life out of illegal eel fisheries of all kinds, in particular “Europe’s own ivory trade” – the glass eel trafficking. An all-encompassing Catch Documentation Scheme for all eel catches may be helpful in achieving this aim. Equally, it needs to address sources of eel’s non-fishery anthropogenic mortality, with special attention to turbine mortality and the impact of black cormorants. As ever, LIFE will spare no effort to offer constructive ideas based on the experience of practitioners.
[1] Public information on the outcomes of the Council meeting https://www.consilium.europa.eu/media/37643/st15654-en18v2.pdf
17th December 2018
Brian O’Riordan
European Union Fisheries Ministers will meet in Brussels today and tomorrow, Monday 17 and Tuesday 18 December for the annual “Christmas Fisheries Council” to agree on fishing opportunities for 2019 for the Atlantic, North Sea and Black Sea. Over the last year, fisheries managers have been upbeat on progress towards MSY targets, but even so the Fisheries Council must strike a delicate balance between protecting fragile and vulnerable stocks and allowing increased access commensurate with stock recovery.
It is a delicate balance between following the precautionary approach to safeguard resources on the one hand and sustaining economic activity and livelihoods on the other: combining environmental sustainability with a fair and equitable allocation that is in the interests of all. For small scale low impact fishers the Christmas Council is generally seen as a Christmas quota carve up, which benefits mainly the larger scale fishing interests. In the main, smaller scale interests have been marginalised by an unfair quota system and alienated from quota species. This has been a major failing of the much heralded 2014 CFP reform, which despite much promise – notably Article 17[1] – has failed to deal with inter-sector inequalities and level the playing field between larger and smaller scale fleets.
This lack of quota and lack fair access to quota is a major barrier for smaller scale fishing operations to survive and thrive and could be the final straw on January 1 2019 if the Landing Obligation is fully implemented, as intended. Without quota for target or choke species, the EU’s zero discards policy could become a zero-fishing policy for small scale fishers, effectively outlawing most fishery operations.
Finding the right balance is particularly critical in the case of bass (Dicentrarchus labrax). Since 2015 EU wide conservation measures have been in place to reduce fishing pressure on this valuable but highly vulnerable stock. Efforts since 2015 have focussed on reducing targeted fishing effort on bass, including through a fisheries closure when stocks are at their most vulnerable during their spawning season (in February and March), and closing the fishery entirely for pelagic trawlers.
Following a benchmarking process earlier this year, ICES advice for bass in divisions 4.b–c, 7.a, and 7.d–h (central and southern North Sea, Irish Sea, English Channel, Bristol Channel, and Celtic Sea) was published in June 2018. This proposed a change in approach from a precautionary approach in 2017 to an MSY based approach for 2018 and 2019. In their 2017 advice on bass in these sea areas ICES had recommended that commercial catches in each of the years 2018 and 2019 should be no more than 478 tonnes. In their 2018 advice for bass, based on an MSY approach ICES upped this, and advised that total removals (for both commercial and recreational sectors) in 2018 should be no more than 880 tonnes; for 2019 no more than 1,789 tonnes. The 2017 cap of 478 tonnes did not take recreational fishing into account; the higher figures provided in 2018 do.
This most recent ICES advice highlights a delicate balance between poor recruitment and low spawning stock biomass on the one hand, and a perceived lowering of fishing effort on the other. Worryingly ICES advise that the spawning–stock biomass (SSB) has been declining since 2005 and is now below Blim. Also worrying is the estimated poor recruitment since 2008; only the 2013 and 2014 year-classes estimates show average recruitment. Along with the average recruitment for 2013 and 2014, the only cause for optimism is that fishing mortality is deemed to have peaked in 2013, to have declined rapidly since then, and is now estimated to be below FMSY.
All this has led to some optimism that the medicine may be working, and that bass stocks are on the road to recovery. To a certain extent this is borne out by the catches and observations of LIFE’s hand line fisher members over the 2018 season. Whilst good catches of bass have been patchy and there has been some mixed success, along the Atlantic coast of France, the South coast of the UK, and the southern North Sea coasts of UK, Belgium and Netherlands, fishers have reported seeing large quantities of bass just below the MCRS. This indicates the possibility of a rosy future, if these bass are able to survive to grow and spawn over the next 2 years.
And this is a big IF. On all sides the fate of bass is beset by many challenges. High on the list of these challenges is the aggregation of mature bass over the winter months, starting in October, and lasting through to March and sometimes up to June. This makes them highly vulnerable to the targeted and untargeted fishing by larger scale and semi-industrial smaller scale netting operations. Likewise, aggregations of juvenile fish below MCRS makes them vulnerable to these gears. If mobile and larger scale fixed net operations take evasive measures to avoid these aggregations, then unintended and potentially destructive impacts on bass stocks can be reduced.
To encourage mobile and fixed gear operators to take such evasive measures, the EC proposal for 2019 fishing opportunities for the Atlantic, North Sea and Black Sea puts a daily cap of “1% of the weight of the total catches of marine organisms on board caught by that vessel” for demersal trawlers, seiners and fixed gillnets. Bass is out of bounds for pelagic trawlers, which under current legislation are “prohibited to retain on board, tranship, relocate or land European seabass”.
In LIFE’s view these are fair and sensible measure, so long as they are backed up by adequate control measures at sea and ashore. However, there is much anecdotal evidence to indicate that such controls are not as watertight as they should be, and that the efficacy of the 1% cap as an incentive to take evasive action is thereby reduced.
LIFE is also concerned that the 1% cap spells the end of the line of our Members from the UK and Netherlands who use small-scale fixed nets in mixed fisheries, and who are effectively banned from selling their relatively small bass catches. Their daily catches amount to no more than 20 to 50kgs per day, which would mean having to discard all the bass they catch. For vessels under 10 metres using small quantities of fixed gears, LIFE would advocate removing the 1% cap completely.
For 2019, bass stocks in the Bay of Biscay south of the 48th parallel, and in the central and southern North Sea, Irish Sea, English Channel, Bristol Channel, and Celtic Sea are still regarded as 2 separate stocks, under two different management regimes. Under the recently agreed multi-annual plan in Western Waters, from 2020 onwards, bass stocks in these two areas will be managed as one.
This merging of the two stocks may make sense from a fisheries management perspective, but there is huge room for improvement below the 48th parallel. The French Platform for Small Scale Fisheries (PPAF) has been highly critical of the lack of effective management and control of larger scale activities, particularly on the spawning aggregations. This has also put the current and future prospects for the bass handliners, commercial activities with the least impact on the resources, very much at risk.
We sincerely hope that such a move will ensure a more rigorous approach to managing and conserving stocks in both areas, and defending the rights and rewarding of those fish in the most sustainable way – based on the three pillars of sustainability; environmental, economic and social.
[1] Article 17 of the “Basic Regulation (Regulation No 1380/2013) obliges Member States to “use transparent and objective criteria including those of an environmental, social and economic nature” when allocating the fishing opportunities available to them. The criteria to be used may include, inter alia, the impact of fishing on the environment, the history of compliance, the contribution to the local economy and historic catch levels. Within the fishing opportunities allocated to them, Member States shall endeavour to provide incentives to fishing vessels deploying selective fishing gear or using fishing techniques with reduced environmental impact, such as reduced energy consumption or habitat damage.
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Expertengruppe Fischereikontrolle
Expertengruppe Fischereikontrolle, Arbeitsgruppe für digitale Komponenten zum Monitoring und zur Fangaufzeichnung in der Kleinfischerei am 4. Und 5.12.2018 in Brüssel.
Bad Schwartau, 15.12. 2018
Wolfgang Albrecht
Sehr geehrte Frau Veits
Zunächst möchte ich Ihnen meinen besonderen Dank dafür aussprechen, dass mir als Mitglied im BSAC die Gelegenheit gegeben wurde an dieser wichtigen Arbeitsgruppe teilzunehmen. Die Einbindung von möglichst vielen Praktikern in einen Entscheidungsprozess zur Novellierung der Kontrollverordnung, womit das Thema elektronische Überwachung und Erfassung von Daten untrennbar verbunden ist, sollte zu einer ausgewogenen und in der Praxis auch anwendbaren Verordnung führen. Allerdings sind mir und vielen anderen Teilnehmern der Veranstaltung einige Schwachpunkte in der Ausgestaltung der neuen Kontrollverordnung aufgefallen, die ich nachstehend gerne aufzeigen möchte, um im Detail Verbesserungen anzuregen.
Allgemeine Zusammenfassung
Die Absicht eine Kontrollverordnung zu erlassen, die ja auch die elektronische Erfassung und Übermittlung von Fangdaten umfasst-und die europaweit gelten soll, ist nur erreichbar unter Hinnahme erheblicher Kompromisse die an den unterschiedlichen
– klimatischen Verhältnissen
– hydrologischen und biologischen Bedingungen
– Fangmethoden und den damit verbundnen Schiffsgrößen
anzupassen sind, was naturgemäß die Umsetzung erschwert und damit die Wirkung vermindert. Dies ist sicherlich nicht in Ihrem Sinne und auch für die betroffenen Fischereibetriebe kein Vorteil.
Im Folgenden möchten ich zu einem geeigneten, durchführbaren und verhältnismäßigen Lösungsansatz meinen Beitrag aus der Sicht der Praxis nach mehr als 40 Jahren aktiver Fischerei auf eigenem Schiff, leisten.
Unterschiedliche Bedingungen
Klimatisch
Ostee Mittelmeer
Hydrologisch
Fangmethoden und die damit verbundenen Schiffsgrößen und hier besonders die Fischerei mit passiven Fanggeräten.
Risikoabschätzung
Bei der Beurteilung der nötigen Kontrollintensität ist die Fangintensität der entsprechenden Fahrzeuge wie in der geltenden KV, in Betracht zu ziehen.
Das zur Begründung des Handlungsbedarfes herangezogene zahlenmäßige Übergewicht der kleinen Fahrzeuge ist als Argument nur auf den ersten Blick geeignet.
Bei einer realistischen Betrachtung spielt nämlich nicht die Anzahl der Fahrzeuge die entscheidende Rolle, sondern deren Fangintensität.
Bei der bei diesem Fahrzeug angewandten
Fangtechnik sind z.B. leicht 500 Kisten Dorsch
gleich 12,5 To. pro Tag möglich!
Hinzu kommen die Rückwürfe durch eine zu
geringe Selektivität, die sich immer noch um die
20% Marke bewegen, sowie eine erhebliche
Belastung der Meeresumwelt.
Mit der gleichen Menge kann ein Betrieb
mit einem Fahrzeug dieser Größe
mindestens 2 Jahre auskömmlich
wirtschaften!
Oder: 200 Fahrzeuge dieser Größe
fangen an einem Seetag nicht mehr als
das oben abgebildete große Fahrzeug
der Schleppnetzfischerei.
Auch die Unterscheidung: „ Unter 12 m“ ist nicht wirklich geeignet, wenn der Zusatz: „ mit passiven Fanggeräten“, fehlt. Denn auch Fahrzeuge im Bereich von 10 bis 12 m Länge über alles, die aktive Fanggeräte einsetzen (können) sind hinsichtlich ihrer Fangintensität anders zu beurteilen, als solche, die nur passive Fanggeräte einsetzen. Dies gilt umso mehr für die Fahrzeuggruppe unter 8m Länge, die in ihrer Fangintensität aufgrund baulicher und technischer Möglichkeiten nochmals weit hinter die der größeren Fahrzeuge zurückfallen. ( siehe oben)
Kombiniert nur passive Fanggeräte
Ausrüstung mit elektronischen Geräten zur Überwachung der Fangtätigkeit.
Technische Voraussetzungen, Platzbedarf.
Fahrzeuge von 8 bis 10 Metern Länge sind hierfür mehrheitlich geeignet, da sie meistens über ein
Steuerhaus und eine elektrische Anlage mit Batterie und Lichtmaschine verfügen.
Aus vorstehenden Gründen ist daher eine gesonderte Betrachtung schon aus technischer
Sicht für die Fahrzeuggruppe unter acht Metern vorzunehmen.
Elektronische Übermittlung von Fangdaten von See aus.
Infrage kommt aus technischen Gründen, wie vorstehend geschildert daher nur eine Übermittlung per Mobiltelefon. ( z.B. MOFI )
Die gewonnenen Erfahrungen im Jahr 1017 bei der Anwendung zur Überwachung der 20 m Tiefenlinie bei einer Ausnahme von der Dorschschonzeit haben deutlich gezeigt, dass sich selbst bei der Übermittlung von den entsprechenden Plots schon erhebliche Bedienprobleme ergeben haben, obwohl sich die Bedienung hierfür lediglich auf zwei Knöpfe begrenzt, also sehr einfach gestaltet war.
Die viel umfangreichere Übermittlung von Fangdaten von See aus ist aus diesem Grunde nicht durchführbar.
Das Mobiltelefon ist, wenn es bei einem Fahrzeug ohne Ruderhaus den Betrieb auf See überleben soll, unter der wasserdichten Kleidung zu tragen. Schon das Hervorholen unter dieser stellt den Bediener vor eine große Herausforderung.
Die Bewegungen des Schiffes durch Seegang und überkommendes Spritzwasser kommen erschwerend hinzu.
(Abb. Samsung Galaxy A 5)
Die Eingabe von Fangdaten mit den gebräuchlichen Handschuhen in der kalten Jahreszeit, ist wie man auf dem Bild sehen kann nicht möglich und mit den kalten Händen, wenn man die Handschuhe auszieht, auch nicht.
Ich bitte daher dringend von einer Übermittlungsvorschrift von Fangdaten für die Fahrzeuggruppe unter 8 Metern von See aus Abstand zu nehmen.
Elektronische Wiegeeinrichtungen (3.4.)
Auch hier steckt der Teufel im Detail, weil zumindest hier an der Ostsee nicht an jedem kleinen Hafen eine Fischannahmestelle mit einer Wiegeeinrichtung vorhanden ist.
Hinzu kommt die Strandfischerei, die auch noch eine gewisse Verbreitung hat.
Zur Abhilfe und für einen händelbaren Ablauf schlage ich daher vor, den Wiegevorgang, wie bisher üblich, durch den Fischer mit einer geeichten Waage am Anlandeort durchführen zu lassen um die Fangmengen festzustellen.
Verkäufe an die Endverbraucher
In der Begründung des Entwurfes der neuen KV findet sich unter der Nummer 39 folgender Satz:
„Beim Verkauf an den Endverbraucher ist die Rückverfolgbarkeit nicht anwendbar. Diese Vermarktungsart ist deshalb soweit wie möglich zurückzudrängen“.
Hierzu sei mir folgender Kommentar erlaubt:
Nachverfolgbarkeit:
1. Diese Begründung ist sachlich und fachlich nicht nachvollziehbar. Kauft ein Kunde im Geschäft X seinen Fisch, kann er wenn alle Vorschriften befolgt wurden und die Angaben richtig sind herausfinden, wo sein Fisch herkommt.
2. Kauft der gleiche Kunde seinen Fisch beim Fischer Y direkt am Kutter, weiß er von Anfang an wo sein Fisch herkommt. (Schiffsname, Fischereinummer)Da die Staatsmacht wohl kaum die Bratpfannen der Bürger kontrollieren will und kann läuft das Argument der fehlenden Rückverfolgbarkeit bei der Selbstvermarktung ins Leere.
Grundsätze für die Kontrolle der Vermarktung ( Art 56-66 )
Dieser Aspekt war in der Expertengruppe zwar nur indirekt ein Thema kann aus meiner Sicht der Vollständigkeit halber aber nicht unerwähnt bleiben.
Bei sinkenden Fangquoten ist die ortsgebundene Kleinfischerei mit passiven Fanggeräten, wenn sie überleben will, auf die Selbstvermarktung ihrer Fänge zu auskömmlichen Preisen angewiesen. Immer nach dem Motto: „Nicht Masse sondern Klasse“!
Die Kontrolle dieser Fänge hat sich durch die bisher angewandten Vorschriften, wie Monatsmeldung und Wiegeprotokoll bewährt und kann aus meiner Sicht im Rahmen der Risikoabschätzung aufgrund des Anteiles von durchschnittlich gerade einmal 3% an den europaweit getätigten Anlandungen beibehalten werden. Hierfür spricht auch der Verhältnismäßigkeitsgrundsatz und eine Kosten/Nutzenanalyse.
Ich hoffe, dass mein Beitrag zur Beleuchtung der unterschiedlichen Problemfelder der Kleinfischerei, vor allem der Fahrzeuge unter acht Metern Länge im Zusammenhang mit der Novellierung der KV beitragen kann und stehe für Detailfragen jederzeit gerne zur Verfügung.
♦ ♦ ♦
Wolfgang Albrecht, Mitglied im BSAC/EXCOM, Vorstandsmitglied L.I.F.E und erster Vorsitzender des Fischereischutzverbandes Schleswig-Holstein

LIFE position on Eel for 2019
LIFE reacts to the Commission’s proposal on Eel ahead of Monday’s Council
Warsaw, 13th of December 2018
Marcin Ruciński
Based on the publicly available information[1], LIFE understands that for 2019, the Commission has proposed to extend the existing mechanism of „movable” 3-month eel closure to be applied by Member States over a 5-month period to all eel life stages and all waters in which eel is found.
We strongly regret that the Commission has not publicly informed, let alone consulted the concerned fishers and other interested parties about this important measure. There was enough time to do so between the GFCM decision in late October, publication of ICES advice (7 November) and now. There were also earlier processes[2] in which the proposed measure could have been properly communicated and discussed with stakeholders.
On the basis of publicly available information about details of the proposed measure, LIFE can live with the Commission approach, even if it poses difficulties for many fishers. The measure has clear shortcomings for large eel traps which take a long time to set and are dependent on weather conditions. However, it offers some basic equitability in efforts undertaken at national level, making their assessment and comparison much easier.
The Commission has taken the bold step to extend the measure to all eel life stages and waters where this fundamentally important species occurs. For many fishers, this measure will be new, introduced at short notice, as a surprise which is very hard to cope with in areas where CFP’s conservation measures have not been applied to date. We thus urge the Commission and national authorities to make EMFF-supported compensations readily available in such cases.
The universal applicability of the closure for 3 months a year will not solve the problem of the trafficking of glass eels from Europe to the Far East. We urge the Commission to assist member states in their efforts to clamp down on this criminal activity.
We cannot emphasize enough how important it is for the Commission to continue the work on a credible and broad package of measures beyond the Council of Ministers next week. They must go way beyond fisheries management measures to have real positive effect on the stock. LIFE has been calling for this already last year[3], to no avail as yet. Our ideas for an all-encompassing eel Catch Documentation Scheme, involving EFCA in the eel-related inspection work, dealing with hydropower turbine eel mortality and the impact of cormorants, all remain on the table.
Any further restrictions imposed on legitimate, traditional, small-scale marine fisheries for eel will not help to recover the species – they are responsible for only 3% of total human-induced eel mortality[4]. On the contrary, further effort restrictions would reduce the willingness to undertake privately funded restocking actions, quality of data available to scientists and put unnecessary extra pressure on the fishers remaining in these traditional fisheries of small quantities and high value.
[1] http://blueplanetsociety.org/2018/12/possible-eu-eel-fishing-closure/
[2] http://www.bsac.dk/getattachment/4b9f4b1c-c6b2-41c7-9483-51000615bdb1/Steve-Karnicki-and-Tof.pdf.aspx?lang=en-GB
[3] https://lifeplatform.eu/saving-european-eel-small-scale-fishermen/
[4] http://orbit.dtu.dk/files/158589197/Publishers_version.pdf , Table 1
Pictured: Turbine-induced eel mortality during autumn downstream migration, photo by Frode Kroglund.
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An unacceptable Mediterranean miscalculation!
Brussels, 10th of December 2018
The Director-General of the European Commission – DG Mare, Mr João Aguiar Machado, writes to the Chairman of the Mediterranean Advisory Council, Mr Giampolo Buonfiglio, objecting as unacceptable his use of the MEDAC to influence the decision-making process of the proposal for a Multi-Annual Plan for the fisheries exploiting demersal stocks in the Western Mediterranean Sea by “seeking the European Parliament’s support on a text that has been neither discussed nor approved among all MEDAC members on a proposal from 3 Italian organisations” thus breaching consensus, transparency and impartiality rules.
Access the letter by clicking here
Update published on 12/12: Mr Buonfiglio replies to Mr Machado stating that “The MEDAC Secretariat has never written to the EP asking for support on statements from certain members” being “well aware that this would be against the AC rules and as such would be completely unacceptable.”
Access the reply by clicking here
Important news on LIFE’s operations
LIFE in transition
Towards a stronger voice in Brussels and an increasing presence in the regions.
As the majority fleet by far, small-scale fisheries merit their own place at the heart of Europe.
Brussels, 29th November 2018
Meeting in Brussels on 15 November, the Low Impact Fishers of Europe’s (LIFE) Board of Directors approved a plan for the LIFE’s further development and growth. This aims to further consolidate LIFE’s role as the dedicated voice for small-scale, low impact fishers across Europe and at a European level. The process will pave the way for increased effort on behalf of this vital yet neglected sector that needs and deserves to be at the heart of Europe’s fisheries policy development.
LIFE was launched in 2012 on the eve of a newly reformed CFP to provide a voice for Europe’s previously overlooked but significant [80% of EU vessels by number] fleet of small-scale vessels and those whose livelihoods depend on low impact fishing activities. Over the last 3 years, since opening an office in Brussels in 2015, and under the direction of its board of small-scale fishers, LIFE has more than fulfilled that role by successfully establishing itself as the recognized body exclusively representing the interests of small-scale low impact fishers. This European level representation has been complemented by LIFE’s extensive engagement in the Advisory Councils at regional level across many of Europe’s sea basins from the Baltic to the Mediterranean, supported by its regional coordinators managing specific projects in partnership with our member organisations.
LIFE is now entering a new phase, building on what we have learnt and achieved during our start up period and guiding us to focus on the provision of greater support to our members. This will enable LIFE to engage at local and regional levels through specific projects on the water face as well as by increased lobbying efforts both nationally and in Brussels.
As part of this restructuring process, LIFE’s Executive Director Jerry Percy will step down and take up the part-time role of Senior Adviser. The role of Deputy Director will be subsumed into the newly created post of Executive Secretary, to be taken up by Brian O’Riordan, LIFE’s current Deputy, to steer LIFE through the next phase of its evolution.
LIFE can be proud of the fact that it now has its own identity and momentum. Thanks to this, there is no longer the need for the role that Jerry Percy has provided since the creation of LIFE. His retention is both welcome and valuable to ensure that LIFE does not lose his long and varied experience across all areas of small-scale low impact fisheries, from the water-face to the negotiating table, and the fact that he was one of the original co-creators of LIFE.
The most recent changes involved moving LIFE’s registration from the UK to Belgium. Not only is such a move essential due to the implications of Brexit for UK registered organizations, but it also makes sense for LIFE to become more centrally established at the heart of Europe. However, LIFE will remain committed to the concerns of the UK small vessel fleet, and according to the outcome of Brexit, LIFE’s UK members will continue to receive our support under an associate membership arrangement.
What has become abundantly clear to LIFE during its initial development phase is the absolutely vital need for a specific and dedicated voice for the small scale fleet across Europe. This need has been acknowledged and supported by both past and current DG MARE Commissioners and their staff.
We are confident that LIFE’s further development and growth will provide an even firmer foundation for its future work and securing the rightful place for small-scale, low impact fisheries at the centre of fisheries policy making.
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For more information, please contact:
Claudia Orlandini, LIFE Communications Officer, communications@lifeplatform.eu.


LIFE writes to ICCAT’s Chair
An invaluable opportunity for a more sustainable and fair BfT fishery
From the 12th to the 19th of November 2018 in Dubrovnik (Croatia) the 21st Special Meeting of the International Commission for the Conservation of Atlantic Tunas will take place. The Meeting is the right time to draw the attention on the case of European small-scale fishers, the majority of the EU fleet, that since 2006 have been stripped from their rights to fish Bluefin Tuna.
It is in this framework that LIFE writes to Mr. Raul Delgado, Chair of ICCAT, welcoming the EU’s Draft Recommendation to ICCAT on establishing a Multi-annual Management Plan for Bluefin Tuna in the Eastern Atlantic and the Mediterranean and making recommendations to ensure that small-scale fishers are allocated the fair proportion of the annual increase of quota which they deserve.
Access the official letter to ICCAT’s Chair here
The above-metioned letter has been sent to the following officials and decision-makers, plus widely disseminated to sector representatives, NGOs and stakeholders.
ICCAT:
Mr. Camille Jean Pierre Manel, Executive Secretary ICCAT; Dr. Miguel Neves dos Santos, Assistant Executive Secretary; Mr. Raul Delgado, ICCAT Commission Chair; Stefaan Depypere, First Vice Chair ICCAT
European Commission:
Mr Andres Jessen; Mr Franco Biagi; MR Francisco-Javier Vazquez-Alvarez
European Parliament
MEP Linnea Engstrom; MEP Gabriel Mato; MEP Norica Nicolai; MEP Ricardo Serrao Santos;
Spanish Ministry
Mr Rafael Centenera

Great expectations in the Med & Black Sea
Deep Rooted Problems, Great Expectations: can the Ministerial declaration and regional plan of action signed recently in Malta turn the tide of fortune for small-scale fisheries in the Mediterranean and Black Sea?
Brussels, 5th of November 2018
Brian O’Riordan
On 26 September in Malta, 18 Mediterranean and Black Sea coastal states committed themselves to developing “objectives, principles and concrete actions” to be applied across the region through a regional plan of action (RPOA) and thus “to ensure the long-term environmental, economic and social sustainability of small-scale fisheries”[1]. Such a political commitment was made possible thanks to the joint efforts of the General Fisheries Commission for the Mediterranean and Black Sea (GFCM) and the European Commission.
Some history
The RPOA is the culmination over 5 years of steady joint work by these two bodies, initiated in 2013 at the First Regional Symposium on Sustainable Small-Scale Fisheries in the Mediterranean and Black Sea, held in Malta, and organized by the GFCM in collaboration with the FAO and other partners. In fact, small-scale fisheries have been on the GFCM agenda since 1980, rooted in a Resolution calling on its members for “the definition of a national strategy indicating in particular the place of artisanal fisheries in management schemes”.
Small-scale fisheries and the Mediterranean and Black Sea have for long been on the agenda of the GFCM, but it is only relatively recently that the EU seems to have woken up to their importance.
Until the launch of the reformed CFP in 2014, small-scale fisheries were considered a national issue and outside the purview of EU policy. Step by step, the socio-economic and strategic importance of small-scale fisheries as an integral component of European policy to sustain fisheries and fishing communities is gaining recognition. Europe’s forgotten fleet is being rediscovered, albeit late in the day!
EU Small Scale Fleet at a Glance (Vessels under 12 metres in length, not using towed fishing gear)
Number of vessels (49,029): 70% of the fleet Tonnage: 8% of the tonnage, Fishing days: 59% of the fishing days Fuel used: 6% of the fuel used Fishers employed (78,304): 50% of at sea employment Landed volume: 6% by weight Landed value: 12% of the value Revenue: 13% of the revenue, Labour costs: 19% of the labour costs Source: Scientific, Technical and Economic Committee on Fisheries (STECF). The 2018 Annual Economic Report on the U Fishing Fleet (STECF 18/07).[2] |
If small-scale fisheries are Europe’s rediscovered fleet, then the Mediterranean and Black Sea are its most neglected sea basins. Although the Common Fisheries Policy (CFP) was established in 1983, until 2006 the Mediterranean and Black Sea fell outside its purview. That is now changing through a process of steps. Launched in Catania in 2016, the MedFish4Ever process was designed to build political consensus among all Mediterranean stakeholders towards obtaining a commitment from all EU and non-EU countries to take concrete actions to address the dire fisheries situation in the region[3]. Within the framework of the CFP, a series of multi-annual plans are being developed to cover stocks in different regions, starting with demersal stocks in the Western Mediterranean and pelagic fisheries in the Adriatic[4].
What are small-scale fisheries in the Mediterranean?
Under the RPOA, small-scale fisheries in the Mediterranean and Black Sea are to be characterized “as soon as possible” according to a set of indicative criteria “reflecting their socio-economic relevance and specificities”.
Given the highly diverse nature of small-scale fisheries in the region and the lack of a simple cut off point between different fleet segments (small-scale, semi-industrial, large-scale, industrial, inshore, offshore, coastal, deep sea etc.) the GFCM proposes to apply a “matrix approach” being developed by the FAO. Such a matrix may include characteristics spanning across governance (policy, legislation, access and tenure), economic (taxation, subsidies, special preference) and management (regulation, gears, zoning).
A Matrix Approach to Characterizing Fisheries[5]
The matrix provides users with a tool to describe a fishing unit across multiple dimensions or characteristics of scale. The flexible nature of the matrix means that the fishing unit being assessed can either be an entire fishery/fleet, a part of it, or an individual vessel/ fisher. This flexibility allows the matrix to be applied to diverse types of fishing activity around the world. Applying the matrix generates an aggregate score for the given unit under assessment, with relevance for discussions of scale. A given fishing unit may have characteristics typically associated with both smaller-scale and larger-scale fisheries, so many will receive lower scores in some categories and higher scores in others. Scoring allows for an objective characterization of the fishing unit, indicating whether it tends towards small-scale or large-scale. Once scores from all the categories are aggregated, an overall picture emerges that facilitates differentiation between larger- and smaller-scale fisheries. By analysing different scores for different fishing units, it is possible to determine if there is a clear cut off between distinctly small-scale fisheries and distinctly large-scale fisheries. In theory, if the matrix is working well, it should highlight those fisheries which may be on the edge of small-scale and large-scale (e.g. a small vessel with a high-powered engine and large-scale level of fishing effort), assigning them their own category. Furthermore, by incorporating multiple dimensions, the matrix approach seeks to avoid misleading or inappropriate characterizations of fisheries as small-scale or large-scale, which can sometimes occur when a single criterion, such as vessel length, is emphasized.
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The Ministerial Statement highlights the strength in numbers of small-scale fisheries in the region (80% of the fleet by number, 44% of the capacity, 62% of employment aboard fishing vessels and 24% of the landed value), their socio-economic value, relatively low environmental impact and importance for food security. The statement also draws attention to endemic problems besetting the sector: the lack of a voice and lack of access to decision making processes; lack of access to resources, to markets, to credit and to support; and the limited capacities of the sector in terms of human capital.
These problems make the sector particularly vulnerable to the impact of other marine activities, such as marine pollution, habitat degradation, biodiversity and resource depletion, and to the encroachment of other activities in the areas it has traditionally occupied. In this regard, the RPOA highlights the need to both ensure that small scale fisheries are taken account of in marine spatial planning at national and regional level, and that the sector is specifically represented throughout the entire process.
A historic step
Although the RPOA is non-binding, it is a historic step, and places small-scale fisheries centre stage in the bid to reverse the declining fortunes of the Mediterranean and Black Sea.
The RPOA is the first instrument to be adopted by any Regional Fisheries Management Organization (RFMO) that goes beyond the management of fisheries to address such issues as social inclusion, decent work, social protection, the role of women, the participation of small-scale actors in management and decision-making processes, and the incorporation of traditional ecological knowledge. The RPOA builds on the foundations laid down by the FAO Voluntary Guidelines for Securing Sustainable Small-Scale Fisheries in the Context of Food Security and Poverty Eradication (SSF Guidelines), and draws on and compliments other international instruments including the 1995 FAO Code of Conduct for Responsible Fisheries; 2007 ILO Work in Fishing Convention; and 2015 UN General Assembly 2030 Agenda for Sustainable Development that adopted the Sustainable Development Goals (SDGs).
It is a significant step because thanks to the Ministerial statement and RPOA, small-scale fisheries have moved from the periphery to centre stage in the regions’ fishery policies and are now incorporated as part of the solution to the problems besetting the Mediterranean and Black Sea. Also, as highlighted by the European Union’s Commissioner for Maritime Affairs and Fisheries, “small scale fisheries (SSF) are the backbone of the fleet, the workers, and the community. They are also the first to feel the pain of collapsing resources. It is therefore important to build the future with them”.
Most Ministers highlighted the traditional nature of SSF, and their cultural importance. Few spoke about their importance to food security. Some highlighted the low incomes and poor capacity of the SSF sector to provide decent work. Some mentioned the problems of invasive species and the vulnerability of the fisheries sector. A few mentioned the need for improved data collection. One, Turkey, mentioned “legacy” – the importance of the heritage that we will bequeath to the next generation.
Palestine, not a contracting party, although Israel is, made the most passionate speech. The gradual encroachment of Israel as an occupying state into Palestinian waters has reduced its fishing area from 20 nautical miles in 1994 down to 3 NM today. In 2017 there were over 200 unlawful shootings on Palestine fishermen with one fisherman killed and an overall policy of suppression of the sector and the coastal community. The Minister invited everyone to visit his country, to witness “one of the most vulnerable SSFs” and in the “interests of justice”. He reminded that the Sustainable Development Goals (SDGs) were designed to leave no-one behind. He pleaded for the Palestinian SSFs not to be left behind.
Spain’s was one of the most supportive speeches of SSF, emphasising its special characteristics, freshness of the product, low environmental footprint, and the important role of women.
Deep rooted problems require a joined-up approach
Of course, the problems besetting the Mediterranean and Black Sea go way beyond fisheries. The semi enclosed nature and large catchment areas of these sea basins make them highly vulnerable to human impact. The Mediterranean is a hot spot of biodiversity with a great variety of marine and coastal habitats including wetlands, lagoons, dunes, reefs, seamounts, canyons, sandy and rocky coasts, which are all important fisheries grounds.
The ever-increasing human population, with the coastal population doubling during some tourist seasons, along with expanding economic development has resulted in increased environmental degradation. These vulnerable marine environments face a worrying combination of pollution from land sources and ships, including plastics and litter, from aquaculture production, with impacts on biodiversity and coastal degradation, along with climate change related impacts. These are considerable challenges that such an RPOA alone can’t address on its own. Furthermore, a large proportion of the marine areas are in international waters and fall outside national jurisdictions, making fisheries and the human impact on fisheries even more difficult to manage and control. Therefore, this RPOA needs to be fully integrated into the wider maritime policy spheres, especially the development of the blue economy.
It is significant that Malta was chosen as the venue for this historic signing. Over 90% of the Maltese fleet is comprised of small-scale coastal fishing vessels (under 12 metres using non-towed gears), numbering some 950 vessels. Traditional Maltese fishing boats are made of wood, and use a wide variety of gears – nets, traps, hook and line, along with ancillary equipment like fish aggregating devices (FADs) made from palm fronds, and lampara vessels to attract shoals of fish at night.
However, as with small-scale fisheries across the Mediterranean and Black Sea region, this once vibrant fishery sector is facing a number of big challenges. These challenges were discussed at an informal gathering of Maltese, Cypriot and Italian (Pantelleria island) small-scale fishers hosted by the Malta College of Arts, Science and Technology (MCAST) ahead of the Ministerial summit, and attended by the Maltese Minister for Justice, Culture and Local Government.
These challenges include:
- IUU fishing and organized fishing crime, a transnational activity with well-organized and equipped criminal gangs. This was highlighted by the Europol led Operation Tarantino, which led to arrest of 79 people involved with IUU fishing tuna, fraudulent trade and marketing of illegal tuna across France, Italy, Malta and Spain[6]
- Cheap labour of migrant workers in fishery operations.
- Encroachment into SSF of larger scale interests, such as feed fisheries for aquaculture and tuna fattening;
- Unregulated sports fishing across the Mediterranean.
- Climate change and invasive species ;
- Pollution, notably from plastic waste (marine debris and mirco-fibres and micro-particles);
- The promotion of “Blue Economy” activities (tourism, aquaculture, energy generation, bioprospecting, seabed mining, oil and gas extraction etc.) that impose themselves in areas traditionally occupied by small-scale fisheries[7].
A particular problem across the Mediterranean highlighted by all the fishers is the rapid colonisation by invasive species from the Red Sea, along with the displacement of traditional species. Two of the main culprits are the rabbit or toad fish (Lagocephalus sceleratus), and the lionfish (Pterois miles). The toad fish can grow up to 1 metre in length and weigh as much as 7 kgs, with sharp teeth that cause extensive damage to fishing nets. Additionally, it has no commercial value as it is highly poisonous. The lionfish is a voracious predator with highly venomous spines that can inflict severe pain and even death. Both fish are also hazardous to the environment; the toad fish is a bottom feeder and can cause extensive damage to seabed habitats, and the lion fish is highly predatory. The lion fish makes good eating but is difficult to handle and is not well known to consumers. In other parts of the Mediterranean the Blue Crab (Callinectes sapidus), native to the Eastern seaboard of the Americas and a voracious predator on shellfish, has become a cause for concern in the South of France and East coast of Spain.
Last but not least, across the Mediterranean the unregulated fishing activities of leisure boating, both through displacing fishers from their harbours and through their fishing activities impacting on stocks, be it for sport or their own consumption through their sheer numbers.
Co-management: not a panacea but a management tool in the box
For the Low Impact Fishers of Europe (LIFE) one of the principle benefits that the RPOA could deliver on is improved governance through co-management. An entire section is devoted the “participation of small-scale fishers in decision making processes”. Linked to this is the call of the RPOA “for fisheries management plans with specific rules designed to ensure preferential access for sustainable and low-impact fisheries along the coastal band.” Such preferential access will only bring benefits if coupled to a system of genuine co-management where both responsibility and decision-making power are devolved to co-management committees, and where small-scale fishers are empowered to form and run their own autonomous organizations.
For LIFE, the top down model of command and control fisheries management as applied in the Mediterranean has become dysfunctional. Small-scale fishers have been alienated from management decision-taking processes, and, combined with a lack of capacity and political will at national level to enforce regulations, this has encouraged overfishing, habitat destruction and Illegal, Unregulated and Unreported (IUU) fishery activities.
In such a context, new forms of governance are required that build trust and cooperation between national authorities and fishery stakeholders, promote co-responsibility, and which unite them in the common purpose of sustainable fisheries and in the fight against IUU fishing and organized fishing crime. This requires a paradigm shift away from a top down command and control approach to a bottom up approach based on co-management.
Around the Mediterranean there are examples where relatively small, localised, and often informal co-management projects have successfully brought state and non-state actors together and facilitated a dialogue and collaboration between them, establishing a basis for co-responsibility and improved acceptance of legally binding regulations, which in turn is contributing to addressing IUU practices and social conflict.
Of course, co-management is not a panacea, but could provide an important management tool honed for managing small-scale fisheries, to be used alongside others (including closed areas reserved for small-scale fisheries, effort control, etc.). In this regard, co-management has the potential to empower fishers and build their capacities to become responsible and competent actors in fisheries management.
There seems to be a critical mass of efforts in co-management that are now coming together: the recent incorporation of co-management into fisheries law in Catalunya through a decree, putting co-management alongside MSY, MCS, technical measures etc. is an inspiring example. There are also many relatively small local initiatives associated with MPAs that are beginning to reach a critical mass and joining up through networks and scaling up initiatives.
The Ministerial commitment to supporting small scale fisheries through the RPOA is both timely and necessary. We hope the positive political will fostered over the last 5 years will ensure that the necessary resources are invested in putting the RPOA into practice, and to transform the ink on paper into action at the grass roots.
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[1] Regional plan of action for small-scale fisheries in the Mediterranean and the Black Sea: a common commitment for the future http://www.fao.org/gfcm/news/detail/en/c/1154586/
[2] Scientific, Technical and Economic Committee on Fisheries (STECF). The 2018 Annual Economic Report on the U Fishing Fleet (STECF 18/07). https://stecf.jrc.ec.europa.eu/documents/43805/2262384/STECF+18-07+-+AER.pdf
[3] DG Mare webpage on the Mediterranean https://ec.europa.eu/fisheries/cfp/mediterranean_en
[4] DG Mare webpage on the rules in force in the Mediterranean https://ec.europa.eu/fisheries/cfp/mediterranean/rules_en
[5] Workshop proceedings on Improving our knowledge on small-scale fisheries: data needs and methodologies, June 2017 http://www.fao.org/3/a-i8134e.pdf
[6] Europol Press Release: How the illegal bluefin tuna market made over EUR 12 million a year selling fish in Spain https://www.europol.europa.eu/newsroom/news/how-illegal-bluefin-tuna-market-made-over-eur-12-million-year-selling-fish-in-spain
[7] LIFE calls for inclusive Blue Growth at the Our Ocean Conference https://lifeplatform.eu/life-calls-inclusive-blue-growth/

BFT: from recovery to fair management
Bluefin Tuna: the move from recovery to management
must directly benefit coastal artisanal fleets.
It is high time that coastal artisanal fisheries were included in the strategy to manage fishing effort, conserve stocks and distribute the benefits from the recovering Bluefin tuna resources in an equitable manner.
Brussels, 25th October 2018
Brian O’Riordan
LIFE welcomes the European Commission’s recognition that coastal artisanal fishing fleets should benefit from the reallocation of Bluefin tuna quota in a fair manner across all European fleets, and the proposal to reintegrate this marginalised sector into the Bluefin tuna fishery.
DG Mare unveiled plans to move from a recovery to a management plan for Eastern Bluefin tuna last Wednesday 17 October 2018, in Brussels, at a meeting with industry and NGO representatives to prepare for the annual meeting of the ICCAT – the International Commission for the Conservation of Atlantic Tuna. This year the 21st Special Meeting of the ICCAT will be held in Dubrovnik, Croatia, from 10-19 November (for details see https://www.iccat.int/com2018/).
The plan is to be constructed around 3 broad objectives of management and conservation, socio-economic inclusion, and inspection and control. DG Mare officials highlighted that in strengthening the recovery of Bluefin tuna, controls need to be improved, especially the sale and laundering of illegal catches.
Overshadowing the ICCAT preparations was the announcement of criminal proceedings by Europol against 79 individuals involved in the illegal catching and trade of Bluefin tuna all along the value chain from catching through transhipment and fattening to marketing, across Italy, Malta, France and Spain. With an estimated illegal trafficking of 2,500 tonnes per year, equivalent to 50% of the quota allocated to the EU for 2018, and worth 12 million Euro per year, this organized crime illustrates how the “most regulated fishery in the world” suffers from a lack of effective control. For more details see: https://www.europol.europa.eu/newsroom/news/how-illegal-bluefin-tuna-market-made-over-eur-12-million-year-selling-fish-in-spain
Despite such significant and unquantified decades long criminal activity across the Bluefin tuna industry, the Eastern Bluefin tuna has staged a remarkable comeback in the last 10 years. This provides solid grounds for moving from a recovery plan to a management plan. However, DG Mare noted that there was still a considerable risk of overfishing due to black markets and a lack of transparency in the transhipment of fish between catching and intermediary vessels and tuna fattening units.
LIFE is happy to note that DG Mare is ready to grasp the opportunity provided by the recovery of Bluefin tuna stocks and the increase in the TAC allocated to Europe from ICCAT to end the unfair discrimination against small-scale low impact fishing activities, to alleviate the economic difficulties experienced by many small-scale fishers, and to take the pressure off other fish stocks in the Mediterranean.
The strategic importance of Bluefin tuna to alleviate the general state of overexploitation in the Mediterranean, in line with the 2017 MedFish4ever Declaration and the 2018 Regional Plan of Action for Small-scale Fisheries in the Mediterranean and Black Sea signed by 18 Mediterranean and Black Sea coastal states, can’t be underestimated. Central to these new instruments are the “equitable access to living marine resources based on sustainable fisheries and their socioeconomic role” and the granting of “preferential access for sustainable and low impact small scale fisheries along the coastal band”.
The Mediterranean small-scale fishing fleet (vessels under 12 metres using non-towed gear) is by far the largest fleet segment, with just under 70% of the active fleet in 2015 according to the 2017 STECF AEP report. Although producing only 25% of the overall catch in the Mediterranean, the fleet accounts for 65% of the fishing days, and 42% of employment. Until 2006, the Mediterranean and other small-scale fleets were permitted to catch Bluefin tuna, which provided a significant seasonal source of income for them, and an important opportunity to reduce their efforts on other stocks.
Since 2006, under the ICCAT Bluefin Tuna recovery plan (the BfT plan), small scale fishers have been effectively stopped from catching Bluefin tuna, with the consequent loss of an important source of income. This has meant that they have had to fall back on other, lower value species, with a consequent decline in their incomes and an increase in pressure on other stocks. Despite Article 17 of the CFP, and Article 8 of Bluefin tuna multiannual plan regulation which call for a fair distribution of national quotas across fleet segments and for incentives to be provided for selective and low impact fishing, this unfair situation is repeated across EU Member States. The EU’s Bluefin tuna multiannual recovery plan for bluefin tuna (Regulation (EU) 2016/1627) also stresses the importance of promoting coastal fishing activities, including in traditional and artisanal fisheries.
The small-scale fishers are ready to play their part in implementing the necessary management and control measures needed to assure that their activities contribute to achieving social, economic and environmental sustainability. For more details see: https://vimeo.com/240133802
LIFE calls for a fair proportion of the annual increase of quota to be allocated, directly from ICCAT and ring-fenced, to small scale and low-impact fisheries that comply fully with the current Monitoring, Control and Surveillance (MCS) framework.
For this to happen, it is first necessary to define artisanal coastal fisheries. LIFE insists that such a definition must first and foremost be based on the use of low impact gears, specifically hook and line techniques using hand lines and/or pole and line; “hand line and pole and line” gears have the lowest impact on the environment and least by-catch compared to other gears that target Bluefin tuna.
LIFE is in favour of a multi-parametric definition so long as this includes an obligatory criterion which restricts the definition to these gears. If the activity complies with this, then it must then comply with three out of four of the following characteristics: a) overall length of the vessel is less than 12 metres; b) the vessel is fishing exclusively inside the territorial waters, or out to 25 nautical miles, of the flag Contracting Party Country (CPC); c) the fishing trips are of a duration of less than 24 hours, and d) the maximum crew number is established at four persons.
LIFE also welcomes the elimination of the 5-tonne cap on the small scale fleets as this will provide a more inclusive basis for these to benefit from the increased tuna quotas distributed to Member States. However, this does not fully protect small-scale fishers from the negative impacts of tradeable quotas and their marginalization resulting from market-based quota allocation mechanisms. Hence, a specific clause to prohibit transferability should be included to ensure that new quota transferred to Member States for coastal artisanal fishing is non-transferable to other fleet segments including purse seiners and large-scale long-liners.
LIFE is also concerned that allowing a variation of 20% in the adjustment of fishing capacity for purse-seiners is too high and strongly recommends maintaining fishing capacity in line with the TAC. The proposed extension of the purse seine season must also be taken into account in this regard. Projections from the 2017 assessment indicated that quota reductions will be required in the future if a F0.1 strategy is continued, and it wouldn’t be prudent to increase fishing capacity, only to have to reduce it again in the coming years.
LIFE does not agree with the proposed measure to extend the purse seine season. This should not be permitted since many vessels catch their quotas in less than a week, and such an extension opens the possibility to significantly increase the fishing effort from this segment.
LIFE advises that the minimum size provisions shouldn’t change from the previous recommendations and should not be weakened by any minimum size derogation, to prevent targeting of smaller juveniles.
Finally LIFE would like to stress that there should be no increase of allowed bycatch from 5% from Rec 14-04 up to 20%, such an increase is tantamount to allowing a targeted catch of Bluefin tuna.
LIFE looks forward to working with the European and national institutions to level the playing field of opportunities between large and small-scale operators, and to ensure an equitable flow of benefits across the fleet segments, whilst maintaining healthy Bluefin tuna stocks.
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