EAA has attended a meeting with Fisheries Commissioner, Joe Borg. EAA Secretary General, Jan Kappel together with Mark Lloyd and Stuart McPherson of the English national angling body ‘Angling Trust’ met with Mr Borg and key staff in Brussels to discuss and share information about the contentious Article 47 in the proposed new control regulation on fisheries.
The regulation text, as it reads now, before being amended by the Commission and Council of Fisheries Ministers includes recreational fisheries explicitly for the very first time. Taken at face value it could mean the introduction of registration of anglers’ catches, log-books and fishing authorizations for boats used for angling as well as catch and access limitations, bag limits and lots of paper work. However, Mr Borg has given assurance both publicly and at our meeting that only recreational fishing on "recovery stocks" and only fishing in the sea (not from shore, piers or those wadding out from the beach) could be made subject to the regulation.
"It was a fruitful and well timed meeting,” says Jan Kappel. “However, there are still many unresolved and worrisome issues at play so we will continue our lobbying efforts in this regard".
The Parliament gave its opinion on April 22. Now the focus moves on to the Council of Ministers. A working group is preparing a first draft for the Ministers’ to discuss in June. The final version of the Control Regulation is expected to be adopted some time in the autumn.
Below we bring some of the outstanding issues for the Ministers to discuss and agree on that are of importance for recreational angling accompanied by EAA positions.
In a letter to EAA of 28 April Mr Borg clarifies:
"Our proposal does not seek to subject every single hobby angler to fish quotas or controls, as is the case for professional fishermen. We simply propose to introduce some basic requirements concerning authorisations and reporting for recreational fishing conducted at sea on a very limited number of well-defined stocks that are biologically in a bad condition — the so-called recovery stocks.
Looking at the practical implications of our proposal it is important to note that there are currently only two fish species which are fished by recreational anglers and which are under relevant recovery plans, namely blue fin tuna and cod…Furthermore I have to emphasise that even in cases where a recreational angler is fishing for a so-called recovery stock on which recreational fisheries does have a significant impact, he will not necessarily be affected by the proposal. If an angler catches a negligible quantity of cod, for example, for his private consumption, he will not fall under the control regulation."
The European Parliament in its opinion report of April 22 suggests that much in the Art 47 should be left to the Member States to decide upon e.g. whether or not catches should be counted against the national quota if one or more recreational fisheries segments should show a "significant impact" on a recovery stock. Mr Borg does not agree fully with this but says he would "… support a further ring-fencing of the provisions by proposing that the Scientific, Technical and Economic Committee for Fisheries (STECF) should provide relevant Member States and the Commission with advice on which recreational fisheries have a significant impact on recovery stocks. Member States will then decide on what amounts to a “significant impact” for each recovery fish stock after they have received this advice from the STECF."
EAA agrees in principle with this new procedure as suggested by Mr Borg, which includes STECF and leaves it to the Member States to decide. But we urge the Commission to follow the Parliament’s opinion that it is not made a prerogative to count against quota in a rigid way or to oblige the Member States to reserve a quota for recreational fisheries.
Recreational fisheries quotas might be good in some but not all cases. Recreational tuna quotas were introduced in France and Spain this year and welcomed by recreational anglers. However, other “non-game” species like cod is a different case and some flexibility must be built into the regulation for the Member States to choose the preferred measures. There are other methods available than quotas to ensure that recreational catches of cod are taken fully into consideration in fisheries management.
We suggest that “significant impact” should be measured against the size and health of the fish stock and not against the national quota as suggested by the Commission. National quotas serve as a fishing allocation tool between Member States but it doesn’t reflect well the total fishing pressure or what pressure the stock can sustain.
Furthermore, the sub-segments of recreational fisheries (recreational angling vs. other recreational fisheries e.g. using nets, traps, long-lines, spear-guns) should be assessed in their own right. It should be evident that if e.g. recreational angling is deemed having a “significant impact” then all other fisheries having the same or a bigger impact must be deemed having a “significant impact” as well. However, we fear this might not be the case, that the term “significant impact” will be a loose one open to much interpretation and political battle. We do agree with the Commission that a case-by-case approach is needed but urge that the stakeholders are adequately involved before any measures are put in place.
To be able to make wise decisions the providing of both socio-economic and environment impact assessments should be made obligatory along with the fish stock impact assessment. This would also correspond well with requirements from the CFP itself e.g. Article 4. It is evident that recreational angling (rod and line) has very little impact on the environment making this kind of impact assessment less needed but unfortunately EU and Member States lack very much needed socio-economic data for most recreational fisheries.
EAA agrees with the Commission and Parliament that sales of recreational catches should be banned.
The Commission has expressed a wish that it should be made clear in the control regulation that recreational fisheries shall "respect the CFP". EAA believes that recreational fisheries – as a fish exploiting sector – is already included in the scope for the CFP (Article 1). If the Commission wants this made more explicit we suggest it should be done under the ongoing reform of the CFP, not in this sub-ordinated control regulation.
Recreational catches of cod. All parties seem to agree on the need for more and better data to be made available to identify, which recreational segment(s) might have a "significant impact" on cod stocks. The Data Collection Regulation does require some cod data from Member States but this is not at the quality level needed. EAA urges that more and better socio-economic data be provided. The decision-makers need more than just catch data to be able to make wise decisions on recreational fisheries for cod.
Recreational catches of cod in the Western Baltic Sea
The Commission has referred to a study, which – according the Commission – shows a “significant impact” by recreational fisheries on the cod stock in the Western part of the Baltic Sea. The Commission’s conclusion is based on a comparison with the quota allocated to the German commercial fisheries. EAA has criticized the study for painting an inaccurate picture of the recreational anglers’ catches on that stock. EAA also criticizes the Commission for only bringing to the public the highest set of catch figures out of six high and low values given for the years 2004/05/06. The distances between high and low values are so immense that it leaves far too much to guessing and (political) interpretation and squabble. Furthermore, the catch figures fluctuates both up and down between the 3 years making it difficult to point out any long-term trend. Nevertheless, the authors have set the catch trend to double over ten years based on pure guesswork. The German angling organisation VDSF now has provided a new study which shows considerably less recreational impact on that cod stock. The Commission is now scrutinising this study and the new findings.
It is worth noting that both the cod stocks in the North Sea and in the Baltic Sea are improving. Last year the North Sea cod quota for commercial fishing was increased by as much as 30%. The cod stock improvement has happened as a result of improved management, control and enforcement aimed at the commercial fisheries sector alone. Nothing of this has been aimed at the recreational sector, which is a strong indication that this sector has very little impact on the ups and downs in the cod stocks.
“The national quota alone is not a good benchmark to use as an indicator on the state of any fish stock as when it’s fished by more than one country, which is often the case for cod. To compare national anglers’ catches with the national quota allocated to the commercial fishing sector would be wrong, says Jan Kappel and continues:
“The Total Allowable Catch (TAC) is a better figure to use for a comparison but not optimal either. Any impact and eventual management measure should be based on reliable data, which compares against the total biomass of that fish stock, what pressure it can sustain and what fishing pressures are caused by various fishing sectors. A lot of cod is removed legally in the form of by-catches and discards outside the TAC and quotas system. Illegal catches are not counted either of course but they can be significant. In 2006 illegal catches were estimated to be about 30% of the total cod catches in the Baltic Sea (2)”.
EAA urges that STECF includes this “invisible” fishing mortality from the legal by-catches and discards in the advice to Member States on which recreational fisheries might have a significant impact on recovery stocks. “Not to do so would be very unfair towards the recreational fisheries”, says John Crudden, Chairman of the EAA Subgroup Sea Angling.
"If recreational angling is made subject to count against quota anglers most likely would be made subject to other provisions, too, e.g. log-books. One should be very careful before introducing a new expensive and burdensome layer of bureaucracy if it is not really needed. There are other ways, less cumbersome, to achieve the management objectives, which we have suggested to the Commission and will suggest to the Ministers shortly", says John Crudden.
Other issues discussed at the meeting with the Commissioner 28 April:
– The importance of data about recreational sea angling which is collected scientifically and can be trusted by everyone involved.
– The need for clear definitions of recreational sea angling and other recreational fisheries segments.
– Concerns about the impact of bag limits, in particular those based on weight, on recreational anglers.
– Clarification of whether the regulations would apply to individual anglers or boats and which boats? (a definition of "vessel" is lacking).
– Artisanal, small-scale and subsistence fisheries
– The impact of the regulations on the significant UK charter boat industry.
– The Data Collection Regulation vs. the draft control regulation.
– The importance of recognising that recreational sea angling is a sustainable activity (arguably no European fish stock would be in trouble if recreational angling was the only form of fishing taking place).
– The fact that recreational sea angling supports many local economies and has considerable social benefits.
