On behalf of the BASS Restoration Project, Steve Pitts has made the following formal reply
To: Mr Mark Holden, Sea Fisheries Conservation Division, Room 423b Nobel House, 17 Smith Square, London SW1P 3JR
On: 14th June 2002
Reference: The European Commission Proposals On The Future Of The Common Fisheries Policy.
Dear Mr Holden
Thank you for your letter dated 29th May 2002, enclosures relating to the above and to the current consultation process. We would be grateful if you would record the following response from The Bass Anglers’ Sportfishing Society.
We broadly agree with many of the findings of the commission and most of the recommendations contained within the proposal documents.
The self-admission that severe over fishing, leading in many cases to stock collapse, has been aided and abetted by financial and political support from the EU is welcomed. Decisions that should have been taken earlier, but have been deferred due to political expediency, now mean that decisive action is required to avert the likelihood that our seas will be devoid of fish for future generations.
In your letter you have posed a number of questions:
The new CFP – Roadmap’ and framework regulation
(a) Do you agree with the revised set of objectives for a reformed CFP?
(b) Do the proposed reforms coincide with the commission’s stated aims?
(c) Are there areas that you feel have been insufficiently covered?
(d) Do you have any other comments on the proposals or the issues covered by the roadmap?
(a) We are in broad agreement with the revised set of objectives for a reformed CFP.
The restoration of our beleaguered fish stocks is paramount if there is to be any future for our marine environments and the ‘new approach’ detailed within the reforms goes some way to putting the well-being of the resource above that of profit at ‘any expense’. Strengthening management measures, aimed at ensuring the conservation of resources, such as ongoing scientific and economic assessments, greater adherence to the precautionary approach, wider stakeholder recognition and empowerment are all well and good but these safeguards should take precedence over the political horse trading that has prevailed and failed the under current CFP.
The proposals place great emphasis on wider stakeholder involvement but if stakeholders are not recognised in the regulations, then there is a real danger they will continue to be overlooked. Recreational fishermen are referred to within the Commission’s ‘roadmap’ but we are not sure whether this document is legally binding. Article 32 of the conservation regulations does not refer to recreational fishermen in the composition of RACS. Why not? Ideally, we suggest that the term “Recreational fishermen” should be included in Article 32. We believe that the Commission’s plethora of environmental controls will fail and wider stakeholder involvement is really the only way of guaranteeing sustainability by taking the focus away from the fishing industry.
(b) In our opinion, generally, the proposed reforms coincide with the commission’s stated aims. There is however one significant area that the commission’s proposals fail to fully recognise and offers no direction or support. Whilst the CFP recognises aquaculture as a sector requiring a strategic action plan (3.6 page 18), the Recreational Sea Angling (RSA) sector (fishing with rod and line for sport or leisure), which is conservatively estimated to generate revenue10 -12 times that of the aquaculture sector and for certain species, up to 15 times the value when compared to that derived from commercial exploitation, is afforded only a token acknowledgement.
How can the commission ignore the undeniable potential that leisure use of our fish stocks offers?
How can this activity/sector be left out of the CFP proposals when EU funds already directly support its development in both Wales and Ireland ?
(c)The CFP ‘road map’ recognises Europe’s 10 million Recreational Sea Anglers as stakeholders in the use and stewardship of our fish stocks yet does not provide one management guideline aimed specifically at that sector. Recreational Sea Angling generates estimated EU-wide spending of 25 billion Euros yet is mentioned briefly, only twice within the ‘road map’. How can such a key activity which generates such a high level of participation, so much revenue without subsidies, is recognised as having low impact on fish mortality due to its selective nature and encompasses the ethics of conservation be ignored by the new CFP?
(d) Recreational Sea Angling generates truly sustainable VALUE from our fish resources in that it employs many thousands of jobs in tourism, manufacturing, servicing, retailing, leisure publication and all at no cost to the EU taxpayer. The development of Recreational Sea Angling and the restoration and future protection of key target species should be an inherent, if not fundamental part of the new CFP.
Structural assistance and aid for scrapping fishing vessels
Do you have any comments on the proposals for the above?
Over-capacity and the massive unquestioned subsidies afforded the EU commercial fishing fleet have created the crisis now facing our fish stocks. We can find no other example in the commercial world where public funds have been used to such an extent in order to plunder and ruin a publicly owned resource. The scrapping of vessels is wholly necessary in order to remove their damaging effort from the sector and remaining vessels must not be allowed to increase their capacity. If vessels are unprofitable then the rules of commerce should prevail and they should not be kept afloat with on-going subsidies. If structural assistance (EU funded compensation) is deemed appropriate it is essential that such funds are rigorously employed to ensure a real reduction in effort and are not surreptitiously re-directed in order to sustain the unsustainable.
Future funding should also be made available for the development of stock restoration projects, Recreational Sea Angling development linked to tourism and re-training and re-deployment in the underdeveloped leisure and tourism sectors.
(EU funds are being used under TRAM “The Tourist and Recreational Angling Measure” in Ireland to provide grants for the purchase of angling charter boats).
Environmental Integration and IUU fishing.
Do you have any comments on the above?
We unconditionally support all attempts to eradicate IUU fishing and commend the concept of environmental integration within the new CFP.
The very foundation of the revised CFP and future fisheries management ethos must be based on the maxim, ‘the resource comes first’.
We would like to see amendments, under the heading of Strengthening of technical measures (page 7 of the road map), where the recommendation is to introduce restrictions on fishing to protect juvenile fish, sensitive non-target species and habitats, with the inclusion of ‘including the seasonal closure of areas’ and ‘spawning or pre-spawning aggregations’ to read thus:
Restrictions on fishing, including the seasonal closure of areas, to protect spawning or pre-spawning aggregations, juvenile fish, sensitive non-target species and habitats;
This would ensure that our fish stocks are allowed to complete their spawning wthout capture at such a crucial point in their life cycles and that the by- catch of cetaceans, often associated with these fisheries, is reduced to agreed targets.
Scientific evidence, and/or more judicious use of the precautionary approach, must be utilised in order to protect our brood stocks from exploitation or the protection of juveniles becomes almost futile when many of our fish stocks are deliberately targeted at or below their known size of maturity and whilst gathered prior to or during reproduction.
Under the heading of UK Priorities:
Do you agree with this set of priorities? Are there other issues, which you think the UK, should give priority to? Which issues should be pursued in the context of the review?
Generally we agree with the UK’s list of priorities.
However, as consultees to the UK consultation period of May 2001 we are dismayed that the overwhelming majority of the respondents to that process have been ignored.
During that consultation process we, along with 70% of those participating, called for ‘the UK Government to recognise RSA as a valid stakeholder and to prioritise the establishment of a policy for the integration and development of Recreational Sea Angling within the CFP’.
Our response advocated that the U.K should embrace the concept of utilising fish resources to benefit leisure, sport and tourism by the development of Recreational Sea Angling. Many examples of successful ‘sport fish’ utilisation projects from around the globe were put forward and offers of comparable data were made.
We would therefore respectfully ask;
What is the point of conducting a consultation exercise when the recommendations and achievable objectives of the majority are totally ignored?
Are we wasting our time again by responding to a consultation document that is already beyond amendment?
Our case is as follows;
Sport fishing meets all of the stated aims of the new CFP.
- It offers sustainable use of resources by selectivity with minimal lethal by catch.
- It offers employment, enjoyment and the opportunity for re-deployment of displaced commercial fishermen.
- It offers immense social benefits, providing a healthy outdoor leisure pursuit combined with the optional provision of a high quality food source if the participant so chooses.
- If the participant practices ‘catch and release’, then the value of the resource is preserved and available for re-use.
- Perhaps, above all, Recreational Sea Fishing is available to all who wish to participate. It is not the preserve of the rich or of big business. There is no social exclusion due to age, sex, race or physical ability. It engenders an acute awareness of the environment and enriches the lives of so many people from all walks of life.
A Proposal should be added to the UK Priorities to develop sea angling and particularly sea angling tourism for the benefit of our coastal communities, particularly as the sector is already being developed in Wales and Ireland. After all the “Objectives of the Common Policy” on page 5 of the roadmap refer to the need for good governance and confirms that this includes ” coherence with other Community policies, in particular environment and development policies”. If EU grants are being used to develop sea angling in Ireland and Wales and given that sea angling involves the exploitation of aquatic resources, surely it would be logical to make reference to the development of the sector in the proposals.
The rights of the people of Europe, to participate in Recreational Sea Angling, are unquestionable. Specific proposals for its protection and future development should be an integral element of the new Common Fisheries Policy.
We restate our previous submission (above) and call on the representatives of the British people, DEFRA, to support our views and to adopt them by their inclusion within the UK list of priorities, Then, take them forward for presentation to the commission and robustly negotiate for the inclusion of Recreational Sea Angling as a vital element within the new CFP.
On behalf of the Bass Anglers’ Sportfishing Society
Please support our campaign by making your own reply before 30 June 2002