DG MARE: Common Fisheries Policy Reform - Green Paper
JNCC Consultation 0962
Submission by the Joint Nature Conservation Committee
Enclosed is JNCC's response to the consultation from DG MARE based around their Green Paper for a Common Fisheries Policy Reform. Submitted on 16th December 2009.

Summary of key points

We are disappointed at the limited consideration of the marine environment in the Green Paper. A clean and healthy marine environment is critical for fisheries, and equally fishing has much responsibility to help ensure that marine ecosystems are sustained. The links between the Common Fisheries Policy and, in particular, the Marine Strategy Framework Directive (MSFD) are not explicit. In addition, no analysis of whether further CFP reform is needed to help support Member States’ obligations under the Natura directives is presented.
We believe that all actions under the Common Fisheries Policy must be compatible with Member State obligations to achieve Good Environmental Status under MSFD. There are only limited and currently rather ad-hoc tools in use to limit the environmental impact of fisheries. We believe that the introduction of strategic environmental assessment or a similar mechanism (e.g. a fisheries-ecosystem plan) uniformly throughout EU fisheries would benefit both fisheries and the environment. Certification schemes could both benefit from, and could support, such environmental assessment.
We believe that the European fleet overall is too large to be profitable and the size of the fleet has been a driver of excessive pressure on fish stocks. Some sectors, such as the pelagic fleet, are currently profitable despite being larger than necessary to harvest the stock sustainably. We recommend that fleets that are currently over-capacity and unprofitable should be reduced in size and that controls on numbers of days at sea are a suitable control on fishing effort. We note also that downward pressure on fleet activity will be needed so long as further technical advances to make fishing more effective continue. We suggest that public funds should not be used alone for any decommissioning but that vessels remaining in the sector should also bear some or even most of the cost.
We believe that the current policy setting and management mechanisms in the Common Fisheries Policy are not fit for purpose. Detailed decision-taking on relatively minor aspects of fisheries management should not be at Council (or Parliament) level. These high level bodies should be responsible for setting overall policy and harvest objectives and should also debate and decide upon the balances between social, economic and environmental sustainability. The Marine Strategy Framework Directive calls for Good Environmental Status to be achieved at the regional seas level; co-ordination and agreement by Member States at this level will be required for this Directive. Given the close links to the Common Fisheries Policy, we recommend that it too be managed at the Regional Seas level. We understand that full devolution of power from Council is not possible but feel sure that some form of practical working at this spatial scale is possible.
The Green Paper addresses the distinction between small- and large-scale fisheries. We can see value in such a distinction, but note that this is not simple in practice. In order for appropriate distinctions to be made, we consider the definition of fishery scale probably needs to be made at a regional, national or local level, rather than centrally.
Please cite as: JNCC Consultation 0962, (2009), DG MARE: Common Fisheries Policy Reform - Green Paper, Submission by the Joint Nature Conservation Committee