The Bluefin tuna industry received a windfall in Marrakech, with proposed TAC increases over the period 2018 to 2020, culminating in the highest TAC ever set. There is a hike on the 2018 TAC of 4,500 tonnes, up to 28,200 tonnes from 23,655 in 2017, with a projected increase to 36,000 tonnes for 2020. This is despite uncertainties over the extent of the recovery of the resource, uncertainty which meant ICCAT was unable to move from a recovery plan to a management plan.
Despite this windfall, the Spanish industry was disappointed by the outcome. It accused the EU of not knowing how to negotiate, given the acceptance by the EU of a small reduction in its TAC allocation key. Others accused ICCAT of placing short term profit ahead of longer term conservation, and the TAC hikes a disgrace.
With such relatively large increases in TACs over the next 3 years, it is well within the powers of Member States to step up and allocate a quota to the small-scale fishery sectors, which have been on the sharp end of conservation measures since 2006.
Interestingly ICCAT highlighted that the needs of artisanal fisheries in coastal developing contracting party countries (CPCs) could receive part of the unallocated reserves from ICCAT in 2019 and 2020. This could pave the way for a dedicated artisanal fishery Bluefin tuna quota at ICCAT level, given political will to do so.
In this sea of plenty, LIFE urges the EU and Member States to do the right thing, and allocate a fair share tuna quota to small scale hook and line fishers, as we have been urging for years.
Bluefin tuna in the dock: French small scale fishers take collective action to challenge unfair, non-transparent allocation system.
In line with ICCAT, Europe is celebrating the successful application of Bluefin tuna recovery measures in its waters and the rebuilding of stocks by increasing quotas allocated to the industrial and sports fishing sectors. Once again Europe’s small-scale fishers have been over looked and their interests discriminated against.
To draw attention to this omission, and to open up a dialogue with the authorities, the Union of Small-scale fishers from Occitanie (former SPMLR)took the initiative to mount a legal challenge to the French Ministerial decree through which tuna quota is allocated. In this endeavour, they are joined by 4 other associations, representing small scale fishing interests from the French Mediterranean and Atlantic coasts, and at European level. Between them, these associations represent over 1,500 French small-scale fishers, and around 7,000 fishers from 12 European Member States. These organisations include:
The French Platform of Small-scale Artisanal Fisheries (PPPAF);
The Low Impact Fishers of Europe (LIFE)
The Varoise Departmental Committee for Marine Fisheries and Aquaculture (CDPMEM Var);
The Regional Committee for Marine Fisheries and Aquaculture for Alps and Côte d’Azur Province (CRMEM PACA).
The diversity and strength in numbers represented by these bodies highlights both the frustrations and the high hopes of the professional fishers concerned, on both the Atlantic and Mediterranean seaboards of France. The engagement of LIFE in the campaign underscores the importance of the European dimension, where despite a significant overhaul of the regulations in the 2014 Common Fisheries Policy (CFP) reform, Member States are still able to go about their business as usual, ignoring the interests of the small-scale fleet segment.
In a general sense, the grievances that have led to the action are the same as those voiced by small scale fishers for years. They demand that the way fishing quotas are shared out must change to ensure a fairer allocation and a wider spread of benefits amongst small scale fishers who have been excluded up to now. In particular that the provisions of Article 17 of the CFP be fully applied, and not merely using catch history as the main method for quota allocation.
Article 17 obliges Member States to use transparent and objective criteria including those of an environmental, social and economic nature when allocating fishing opportunities, and encourages them to provide incentives to fishing vessels deploying selective fishing gear or using fishing techniques with reduced environmental impact.
This demand is not restricted to France, nor to Bluefin tuna. Across Europe, traditionally polyvalent, seasonally diverse small-scale fishery activities are increasingly being forced to adopt more homogeneous fishing methods, and to fall back on non-quota species, being deprived as they are of access to quota species.
The legal challenge addresses the following shortcomings of the tuna quota allocation system in France:
Its disregard for Articles 16 and 17 of the CFP Basic Regulation (EU 1380/2013), which oblige Member States a) to inform the Commission of the methods used for allocating fishing opportunities; b) to use transparent and objective criteria to allocate quota; and c) to provide incentives to fishing vessels that use fishing techniques with a reduced environmental impact;
Its contravention of EU competition law by using catch history almost exclusively as the allocation criteria for quota;
Its quasi-exclusive use of catch history as the criteria for allocating quota;
The ill-considered way it calculates and allocates “socio-economic” quota; and
The non-respect for the principle of equality in setting by-catch quotas for Bluefin tuna that exclude small scale fishers, whilst trawlers and some longliners benefit.
This action does not signify a split amongst the professionals, with “small” pitted against the “large”. The problem of sharing out the quotas is a recurring one with a long history. The purpose of this action is rather to break the deadlock; it should not interfere with negotiations between professionals in the sector. That is not the intention of those bringing the action. On the contrary, questioning the law should provide a lever, to make those in the profession take heed, and to make the authorities aware of the disproportionality and inequality of the current situation.
Last November, Commissioner Vella informed LIFE that “it is for the Member States to decide on how BFT fishing opportunities are allocated” within the limits set. He assured LIFE that the Commission would continue to address this allocation issue regularly with Member States to ensure that the provisions are correctly applied (https://lifeplatform.eu/correspondence-vella-tuna-quota/). LIFE welcomes the Commissioner’s response, and hopes that this new action will highlight where Member States are falling short in putting their commitments into practice, and open the way for the Commission to oversee the correct application of the CFP provisions.
Finally, both ICCAT and the scientific community agree unanimously on the improving health status of Bluefin tuna stocks, which are well on the road to a full recovery. This is confirmed by the regular sightings made by small scale fishers, who watch tuna swimming past without being allowed to catch them. Rarity is no longer an acceptable excuse for denying access to small scale fishers.
Discriminating against the interests of the small-scale fleet segment, whose potential catch rates are relatively low, and whose hook and line techniques are highly selective and discard free through such a differentiated treatment is not acceptable.
It is in the interests of all professional fishers and the sustainability of their professions that a fair re-balancing of quota allocation is made.
11 Years Awaiting in Vain for a Fair Quota Allocation
Once again Spain has turned its back on historic injustices by denying rights to small scale fishers in the Mediterranean to access Bluefin tuna.
Brussels, 14 February 2017
On 7 February, the Spanish Ministry of Agriculture, Fisheries and Environment, announced that the government had published its “Plans for the Fishery, Capacity, and Control of Bluefin tuna” and had fixed the allocation criteria for the reserve pool of quota for 2017.
This document does not correct in any way past mistakes and will continue benefiting the status quo: increasing the fishing possibilities of the very industrial fleets and overlooking – for another year – the Spanish small scale fisheries sector.
LIFE laments that the Spanish Government did not seize this golden opportunity to correct the historic errors and begin to promote a necessary and just balance that guarantees the survival and prosperity of the small-scale fleets, which provide so many social, economic and environmental benefits to coastal communities.
Rights Based Management and Small Scale Fisheries in the EU
A LIFE Position Paper on ITQs
Individual Transferrable Quotas (ITQs) have caused no end of controversy in the small-scale and coastal fisheries (SSCF) sector worldwide. The most recent reform of the CFP stirred up such controversy but rejected the imposition of obligatory Transferable Fishing Concessions (TFCs) – ITQs by another name. However, TFCs remain an integral part of the reformed CFP and Sweden is now set to establish an ITQ system for demersal fisheries in Baltic and North Seas in January 2017. This may well encourage others to follow suit.
There is no doubt that clearly defined rights in fisheries, both individual and collective, which are fairly, objectively and transparently established, and revocable by the State, are beneficial to all. However, where rights regimes have been imposed, with access rights allocated to a privileged segment of the fleet, and then effectively privatized through ITQs, this has led to concentration of rights in the hands of a few, increased inequality in the fisheries sector, and negatively impacted small scale fisheries.
In this paper, LIFE reviews Rights Based Management (RBM), and calls for rights to be allocated in ways that are fair, which privilege those who fish in the most responsible manner, and with adequate safeguards in place to protect vulnerable small scale fisheries and their communities.
Allocation of Artisanal Bluefin Tuna Quota: Commissioner Vella commits to addressing this regularly with MS to ensure that CFP provisions for a fair allocation of quota are correctly applied.
In an exchange of letters between LIFE and Commissioner Vella concerning the allocation of a dedicated, non-transferable Bluefin tuna quota for small scale hook and line fishers just prior to and post the ICCAT Annual meeting in Vilamoura, Portugal from November 14 to 21, Commissioner Vella explained that ICCAT decides on Bluefin quota allocations amongst the Contracting Parties (CPCs), not on the allocation of these quotas between the various sectors within a given CPC. Responsibility therefore lies with EU Member States to implement the provisions of the recent Bluefin tuna regulation 2016/ 1627 as regards a fair distribution of quota, and giving consideration to traditional and artisanal fisheries.
However, Commissioner Vella assured LIFE that “the Commission will continue to address this (quota issue) regularly with Member States to ensure that these provisions are correctly applied”.
Time to correct historic wrongs, and return rightful access to small scale fishers.
Brussels, 16 november 2016
Brian O’Riordan, Marta Cavallé
The Low Impact Fishers of Europe (LIFE) Platform calls on ICCAT contracting parties to establish a dedicated, non-transferable, ring fenced Bluefin tuna quota for small scale low impact fishers
Es hora de corregir las injusticias históricas y devolver el derecho de acceso a los pescadores de pequeña escala
Bruselas, 16 noviembre 2016
Brian O’Riordan, Marta Cavallé
La Plataforma de Pescadores de Bajo Impacto de Europa (LIFE) pide a las partes contratantes de ICCAT que establezcan una cuota de atún rojo, dedicada, intransferible, para pescadores de pequeña escala y bajo impacto.
Le moment est arrivé de corriger les erreurs du passé et redonner l’accès à la petite pêche.
Bruxelles, 16 novembre 2016
Brian O’Riordan, Marta Cavallé
La Plateforme LIFE demande aux parties contractantes de l’ICCAT d’établir un quota de thon rouge spécifique, non-transférable et réservé à la petite pêche.
Mediterranean and Canary Island Fishers demand fishing quota justice
Tarragona, 8 October 2016
The Association in Defence of Mediterranean Artisanal Fisheries (ADPAM), the Regional Federation of Canary Island Fishing Cofradias, the Gaia Oceans Association, the Tarragona Fishing Cofradia and the Low Impact Fishers of Europe (LIFE) met in Tarragona to ask that Bluefin tuna quoas are assigned by ICCAT specifically to the coastal small scale low impact fleets of the Mediterranean and Eastern Atlantic.
Pescadores del Mediterráneo y Canarias piden justicia para las cuotas pesqueras
La Asociación para la defensa de la pesca artesanal del Mediterráneo (ADPAM), la Federación regional de cofradías de Canarias, la Asociación Océanos de Gaia, la Cofradía de Tarragona y Low Impact Fishers of Europe (LIFE) re reunieron en Tarragona este fin de semana para pedir una cuota total específica asignada por ICCAT a flotas costeras de pequeña escala y bajo impacto Mediterráneas y Atlántico.
Please find below LIFE’s contribution on the way forward to tackle the main challenges faced by the sector in the year to come, including on how the levels of fishing effort and quotas are set according to the new Common Fisheries Policy and in relation to scientific advice about sustainable fishing.
During past months the members and staff of the Low Impact Fishers of Europehave been working hard to improve the environmental, economic and social framework within which the European small-scale fleet operates.
LIFEurges European and national institutions not to turn a blind eye on the complex situation affecting coastal communities throughout Europe, and is confident that the dedication and efforts of its members to improve the situation will be rewarded in the long run.
Background
Historically, small scale fisheries, specifically vessels under 12 metres using non-towed gears, have been overlooked by the CFP, with the notable exception of the 12-mile zone derogation. This has meant that previous CFP’s have focussed on larger scale, mobile gear fisheries, that are more industrial in nature and intensive in their impact on the fish stocks and wider environment.
The specific characteristics of smaller scale low impact fishing operations, providing as they do solutions to current problems of overfishing and ecosystem impact, have tended to be overlooked at both national and EU level in fisheries policies and the implementation thereof.
In LIFE’s experience, Producer Organizations set up to distribute and manage quota have tended to alienate small
scale fishers, whilst catering to the needs of larger scale fishing operations. The use of historic catch records as the basis for allocating quota has restricted access of small scale fishers to quota species. In many sea areas, smaller scale fishing operations are increasingly reliant on non-quota species. This impacts on their profitability, as well as their ability to diversify and with the application of the landing obligation coming into force, in its currently understood form, will result in the forced closure of many small scale fishery enterprises due to their lack of quota for “choke” species. Unless these issues are addressed – restricted access to quota species and the consequent ‘choke species’ issue – the historic demise of small scale fisheries and the coastal communities they support is likely to continue.
Scientific Advice and Maximum Sustainable Yield (MSY)
LIFE supports the adherence to scientific advice in setting quotas, and the setting of fishing levels in line with achieving MSY targets (Fmsy). However, we feel that greater attention should be given to including the wealth of local knowledge of small scale fishers in decision-taking, in combination with scientific knowledge so as to put scientific advice within a socio economic context. By doing so, this will ensure that we don’t “throw the baby out with the bathwater”, maintaining the current upward trend in stock levels but at the same time providing sufficient fishing opportunities to maintain and even improve the viability of Europe’s extensive small scale fleet.
Further, given the historic alienation of small scale fishing activities from the quota allocation processes, LIFEadvocates the use of positive discrimination and affirmative action to level the playing field with larger scale fishing interests as regards access for small scale fishers to quota and fishing areas.
In this regard, LIFE is disappointed that many of the provisions of Article 17 have been overlooked, particularly as regards the genuine use of criteria of an environmental, social and economic nature when allocating fishing quota, and the use of quota allocations to provide incentives to fishing vessels deploying selective fishing gear or using fishing techniques with reduced environmental impact.
Within the context of the Technical Measures Conservation Regulation proposal (COM (2016) 134), and the emerging Multiannual Plans (MAPs), LIFEwould like to see greater use being made of areas reserved exclusively for the use of small scale low impact fishing operations, trawl free zones, and the temporal closure of spawning and other areas where fish may concentrate during certain seasons and life cycle stages.
Baltic Sea
LIFEhas submitted its view on the Baltic Sea fish stocks’ TACs and accompanying measures following the ICES advice for 2017 to the BSAC and DG MARE services for the Baltic Sea. This is included as an annex below.
LIFE is extremely worried at the latest ICES advice for Western Baltic cod. A TAC of 917 tons would effectively mean a bankruptcy of many small-scale businesses, the backbone of coastal communities in most affected Member States. A multitude of reasons has led to this situation, including science shortfalls, long-term overfishing, the rise of recreational fishing, and ecosystem aspects. But it is crucially important to think outside the box and look for innovative longer-term solutions rather than haggling over the percentages of TAC reductions, which is bound to be very serious. LIFE calls for a recognition that just as we take utmost care for our most vulnerable fish stocks, we are obliged to take the utmost care for the most vulnerable fishers – the low impact small-scale fishers with no alternative whatsoever to fishing Western cod.
The situation calls for an array of measures to protect both the stock and the fishers directly dependent on it. These should include:
Enhanced spawning protection through total trawling closure in Subdivisions 22 and 23 in February and March (2 months);
A reallocation of quotas from trawl fleet to small-scale low impact fishers in the spirit of Article 17 of the Basic Regulation, at least until the stock clearly recovers;
Measures to minimize by-catch of undersize and small cod, as well as tightened discards control;
Stronger regulation of recreational fishing and raising their awareness on the Western cod situation;
Taking targeted measures to reduce impact from increased seal population; and
Smart use of EMFF funds to offset the tough effects of these measures.
North Sea, North East Atlantic, Iberian Atlantic and Bay of Biscay
For LIFEMembers operating in these sea areas, one of the main issues of concern is access to quota species and the potential impact of the landings obligation in this regard.
A further concern relates to the situation of the bass stocks, and the ICES advice for zero catch levels (commercial and recreational fisheries) in 2017 based on a precautionary approach.
The livelihoods of many LIFE members using hook and line are critically dependent on access to bass stocks. A complete fishery closure would mean bankruptcy for these small scale enterprises.
Observations from LIFE members in relevant member states on the availability of bass are contradictory. Along the French Atlantic coast, fishers using hook and line report a general absence of bass, both North and South of the 48th
for catches of a variety of year classes, although the fishing has declined recently in some areas, whilst in the North Sea, many of the UK bass fishers have moved to potting for whelks. Dutch hook and line fishers report having had a poor year, although they have seen very significant shoals of juvenile Bass. The North Sea and eastern Channel fishers have reported large concentrations of undersized sea bass, raising very significant concerns that these shoals will be decimated by active gears such as those used by the very large Dutch fly shooters utilizing relatively small mesh nets.
With regard to this particular activity, we also highlight the concerns expressed by LIFE Members on the western coast of Denmark where the traditional ropes used by large fly shooting vessels have been replaced by steel wires. This, together with the very powerful engines used by these vessels is result
ing in the laying waste of the seabed by cutting off the limestone nodules that have provided effective protection for juveniles for decades. Prompt action now, and especially within the technical regulations would prevent any further damage being done to the long term sustainability of currently viable fisheries and the stocks on which they rely. This is an opportunity to reverse an approach that has almost inevitably resulted in only acting when a stock of fishery has already suffered degradation and the means of revitalising it are significantly more painful than if the problem had been addressed at the outset.
Mediterranean Sea
The fishery crisis in the Mediterranean Sea is of great concern toLIFE Members, where they consider that the intensive use of trawls in sensitive inshore areas has had a major impact on both fish stocks and the supporting environment. They consider that there is a need to establish extensive trawl free areas in designated coastal waters which are sensitive habitats, and reproductive and nursery areas for many species.
At the same time, it is clear that it would be wrong to lay the blame for all the ills of the Mediterranean exclusively at the feet of mobile gear operators. There is a fast growing recognition by smaller scale fishers that the Mediterranean is in dire need of an overarching and robust management plan that takes the impact of all gears into account, not just that of heavier mobile methods and that the responsibility for the rejuvenation of Mediterranean fisheries is the responsibility of all concerned and not just a single sector.
LIFE Members welcome the reported recovery of Bluefin tuna stocks in the Eastern Atlantic and Mediterranean Sea, and the proposal of the European Parliament “to distribute national quotas fairly among the various fleet segments giving consideration to traditional and artisanal fisheries, and to provide incentives to Union fishing vessels deploying selective fishing gear or using fishing techniques with reduced environmental impact.”
LIFE fervently hopes that this statement reflects the recognition by decision makers at all levels of the need to provide real and meaningful support to the 80% of the European Union fleet that is deemed to be small in scale but large in social, economic and environmental benefits if managed effectively.
Annex 1: LIFE comments on Baltic Sea fish stocks’ TACs
and accompanying measures following the ICES advice for 2017
Eastern cod and relation to pelagic species
LIFE is strongly concerned about the continued lack of analytical assessment of this stock by ICES, in spite of numerous efforts to this end. The lack of larger cod individuals and reliance on small number of incoming year classes increase risks ahead of this key Baltic Sea stock.
Furthermore, ICES points to increasing discard rate, which is most probably higher than 15%. LIFE Members’ observations confirm the information available to ICES that “modification of selectivity properties” does take place at large scale in demersal trawl fishery.
The condition of cod individuals has improved a little, but it is still much worse than long-term average; this must not be used as an excuse for complacency. There is no single cause of this phenomenon. However, LIFE Members point to a root cause of continued cod food deprivation, especially for 3 to 4-year-old cod, which should mainly feed on sprat in normal conditions. In LIFE’s view, it is because forage fish is simply not available, due to excessive effort exerted on pelagic species, particularly sprat in Subdivisions 25 and 26. ICES advice is quite clear on this.
The situation described above calls for a moderate TAC decrease, in view of increased risks for the stock. It is, however, immensely more important for decision-makers to adopt without delay measures leading towards:
Much better food availability for 3 to 4-year-old and older cod individuals;
Significant and strong decrease of discards. They are a disgrace to the region hitherto seen as example for the rest of Europe to follow.
Small-scale fishers of the Baltic Sea can ill-afford a repetition of the situation of Western cod stock in the East.
Sprat
LIFE considers that, in a situation of cod food deprivation in Central Baltic and on the basis of just one strong year class, the TAC increase suggested by ICES should not be followed. We hope that decision-makers shall act moderately here to avoid steep sprat TAC decreases in the future. LIFE recommends a rollover of the TAC with a robust spatial management plan to move large-scale pelagic effort away from SDs 25 and 26 and leave the sprat as prey for hungry cod, as advised by ICES.
Central Basin Herring
LIFE feels it necessary to bring to the table a worrying anecdotal evidence provided by one of our Members: some fishers specialized in herring for bait, operating in southern Swedish waters, have pointed out to very bad situation of herring in their area, with i.e. the fish growing very thin. This has resulted in some bait-specialized boats going out of business this year.
Impact of seal predation
LIFE calls upon ICES to take full account of the extent of fish mortality caused by the huge increase in seal population over the last decade. This is particularly important for the assessment of cod and salmon stocks. Furthermore, environmental organizations, as well as the relevant EU and national authorities, need to re-think their seal conservation policies to ensure that the balance in Baltic Sea ecosystem is kept.
Sign the petition of the artisanal fishermen of Spain! Firma la petizione dei pescatori artigianali spagnoli! Signez la pétition des pêcheurs artisans espagnols! Potpišite peticiju o zanatski ribara Španjolske!
Hundreds of polyvalent small-scale fishers in the Mediterranean who traditionally fished Bluefin tuna are effectively excluded from the fishery. Spanish small-scale fishers are getting organized to take action and demand to their Government to review the allocation of quota system into a fairer and more sustainable one, according the article 17 of the CFP, that requires that states use “transparent and objective criteria, including those of an environmental, social, and economic nature” when allocating fishing opportunities”.
Artisanal fishermen still don’t have access to the quota they deserve! Let’s stop this unjust system and help them put pressure on the Ministry to do what it has to do: implement Art.17 of the CFP!
You don’t need to be based in Spain, sign wherever you are!
France, like many EU Member States, has administrative and management systems that are ill suited to the needs of the small scale fisheries sector. Despite much promise, two years on, the implementation of the CFP has so far failed to deliver tangible benefits for fishers who have chosen to fish ways that limit their impacts on the environment, who want to combine traditional small scale fishing ways with modern technology and decent working conditions, and who want to support the local communities in which they are rooted.
Despite the lack of delivery to date, LIFE is optimistic that Article 17 does provide the possibility to reward those who fish sustainably, so long as the political will is there to apply its provisions in the spirit as well as in the letter of the law.
The authors of the article below speak not only for themselves and for the French Platform for Small Scale Artisanal Fisheries, but for small scale fishers across Europe who share their worries and frustrations. Their concerns are very much our concerns.
The French Platform of Small Scale Artisanal Fisheries, a founder member of LIFE, represents fishermen from the French Atlantic facing coasts and from the Mediterranean. The Platform was launched in June 2012 by a group of associations representing 500 fishers.
The Platform was set up to defend the under 12 metre fleet segment that uses predominantly passive fishing methods. Despite the importance of this fleet segment, it is often marginalised, treated unfairly, not given proper consideration by the authorities, and not given sufficient space within professional organizations.
The aim of the Platform is not to fight against vessels over 12 meters. The complementarity of small scale and large scale activities is recognized and respected by the Platform, which considers that fleet diversity is important for the economic and social wellbeing of both fishing harbours and the sector as a whole.
Of course there are points of contention, and we may disagree on a number of issues. However, like the Platform, LIFE contends that the management of small scale fisheries require a differentiated approach, and that measures are needed to ensure that a balance is maintained between small-scale fishing and other fleet segments, and the small scale low impact segment can thrive.
LIFE identifies with, and wholeheartedly embraces these objectives and views.
In France, as in other European countries, there are many hurdles to setting up as a small scale owner operator. First of all, it is necessary to obtain the PME (Fishing Vessel License). Then a plethora of permits must be obtained, including AEP (European Fishing License), licenses for gears, and licenses for different species like bass, shellfish, sole etc. For bass, no more licenses are available for fishers using hooks, despite this being the most responsible fishing method as far as the resource and the marine environment are concerned, and on which hundreds of fishers depend. Their contribution to the overexploitation of the species is minute compared to the pelagic trawl fleet, where the number of licenses has remained unchanged.
And then there’s the painful question of quotas; a management tool much feared – and with reason – by small scale fishers. It is applied through a mechanism – based on catch history – that is deeply unfair. It rewards those who fish the most, whilst overlooking those who practice low impact fishing.
LIFE and the French Platform both denounce the current distribution system of quotas and its many perverse effects. Last December in France, the Competition Authority raised concerns on how quota is distributed among fishermen, the anti-competitive nature of the practices, the opaque allocation and management mechanisms, particularly in the POs (Producer Organizations).
The quota allocation system for Bluefin tuna graphically illustrates these concerns, with almost all the quota allowances reserved for purse seiners, pelagic trawlers or large longliners. This system should be fully reviewed in order to establish a distribution system based on environmental, social and economic criteria, as set out in Article 17 of the reformed CFP.
Some EU regulations include special provisions that favour small boats, by exempting them from certain fishing authorizations. However, in the case of access to cod in some areas, the exemption for vessels under 10 metres has been overturned by the professional organizations. Instead they have imposed a European Vessel Licence (AEP) on vessels under 10 meters, which penalizes them heavily. The French Platform also strongly objects to the unequal charges levied on small boats compared to large boats. Our sector is the main contributor, but not the primary beneficiary.
Then there is the administrative straitjacket, where bureaucratic requirements are not at all adapted to the constraints of small-scale fisheries. These include safety requirements, the need for life-rafts, the system for weighing the landings, manning levels, direct sales, and so on. It’s a real burden for small scale owner operators.
We are not asking for the exemption of small fishing from all management measures. However, we denounce a management system that is inappropriate. We depend on the areas where we fish – our fishing territories. We need to target the species found in our immediate vicinity, distributing our effort, based on a logic that is not to maximize profit.
It’s a philosophy and a socioeconomic model that the current system constantly undermines. There is nothing more absurd for us than having to avoid catching bluefin tuna that abounds all around us, or to discard it dead, and then having to travel great distances to find fish that we are allowed to catch.
Our critics contend that “if we followed your demands, then the coastal zone would simply fill up with vessels”. But we already find large ships on the coast, notably supertrawlers, other trawlers and 24 metre longliners, which thanks to derogations can operate within the 3-mile zone. All we are asking is that the maritime space be shared amongst vessels according to their size, and for the rules applied to be respected and strictly controlled. Our small vessels will never go far out enough to compete with vessels of 20 or 25 meters.
Similarly, we continually hear officials congratulating themselves on the sound state of stocks. But which stocks they talking about? Bass? Red seabream? Black bream? All these species are far from well managed. Many fishers will tell you how red seabream was decimated by high opening trawls, and how black bream has virtually disappeared in some places because of pelagic trawling. We call for a comprehensive scientific assessment, but are under no illusions that this will happen any time soon.
In the Mediterranean, too, there is an urgent need for progress to be made to improve the state of resources. But when addressing the problem, sports fishing (which is totally unregulated), pollution and coastal urbanization must also be factored in. Better recognition of the roles of prudhommies, ancient secular management bodies, should also be included in the equation. It is by strengthening theses indispensable institutions that we can make progress in fisheries management in the Mediterranean.
We had placed certain hopes in the new CFP, particularly concerning the provisions of Article 17. This article requires Member States to allocate quota using transparent and objective criteria, and to favour fishing vessels “deploying selective fishing gear or using fishing techniques with reduced environmental impact, such as reduced energy consumption or habitat damage.”
But where are these famous criteria that each state is supposed to define and implement? We fear that Danish seines and electric trawls may be the ones to eventually benefit from the misapplication of these environmental and social criteria.
LIFE
Observations from 
intensive use of trawls in sensitive inshore areas has had a major impact on both fish stocks and the supporting environment. They consider that there is a need to establish extensive trawl free areas in designated coastal waters which are sensitive habitats, and reproductive and nursery areas for many species.
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