Position Papers

FISH produces position papers – often together with NGO partners – on current fisheries issues being addressed by e.g. BALTFISH, BSAC, the European Commission, Parliament and Council.

The position papers are often aimed towards a specific audience – government officials, various stakeholders, other NGO representatives and the media.

2015

MoU with ICES and information on biomass levels of stocks – joint NGO letter

This letter was sent to Director General João Aguiar Machado at The European Commission, DG Maritime Affairs & Fisheries regarding the MoU with ICES and information on biomass levels of stocks.

In this letter we ask Mr Machado to confirm that in 2016, the Commission will seek advice from the International Council for the Exploration of the Sea (ICES) on the status of biomass in relation to levels capable of producing maximum sustainable yield (MSY).

Joint NGO letter to Commission’s Directorate-General for Maritime Affairs and Fisheries on MoU with ICES and information on biomass levels of stocks

The landing obligation and 2016 Atlantic fishing quotas – joint NGO letter

This letter was sent to the Commission’s Directorate-General for Maritime Affairs and Fisheries ahead of the Commission’s proposal for 2016 Atlantic TACs.

In this letter we urge Mr Machado to consider the impact of the landing obligation’s partial implementation on the fixing of Atlantic fishing quotas, and asked him to incorporate our suggestions into the imminent Commission proposal on fixing Atlantic fishing opportunities

Joint NGO letter to Commission’s Directorate-General for Maritime Affairs and Fisheries on the landing obligation and 2016 Atlantic TACs


Commission Consultation on Fishing Opportunities for 2016

In September 2015 the Fisheries Secretariat responded to the Commission consultation for fishing opportunities for 2016 published in June. This Communication not only sets out the principles for the fixing of fishing opportunities for 2016, but also aims to fulfil the reporting obligation of the Commission in Article 50 of the Common Fisheries Policy on the progress toward achieving Maximum Sustainable Yield (MSY) and the state of fish stocks. We respond to the Commission’s general approach and raise concerns over data transparency in their analysis of the state of the stocks. Submissions from other organisations are available on the Commission’s website.

FISH response to Commissions consultation on 2016 fishing opportunities


Fishing opportunities for Baltic Sea fish stocks in 2016 – FISH recommendations to BALTFISH

FISH has produced a short briefing and annex with recommendations for BALTFISH to consider in the discussions regarding Baltic TACs at the meeting on September 1, 2015. The recommendations are based on ICES advice including the update on Western Baltic cod which was published on 16 July.

2016 TACs for the Baltic Sea – FISH recommendations to BALTFISH

2016 TACs for the Baltic Sea – FISH Annex recommendations to BALTFISH


Multiannual Plan for the Baltic Sea – joint NGO priorities for the European Parliament

This briefing was sent to Members of the European Parliament (MEPs) ahead of the Plenary in Strasbourg on April 27, 2015, where MEPs vote on Jarosław Wałęsa’s report concerning the EU Commission’s proposal for a Baltic Multi-Annual Plan (MAP).

In this letter we urge MEPs to support and further strengthen the Report from the Fisheries Committee, which voted on the file on the 31st of March, 2015. In particular we urge MEPs to support the objectives of multiannual plans, sustainable fishing mortality rates, conservation reference points, and the ecosystem-based approach.

Multiannual Plan for the Baltic Sea – Joint NGO priorities for the European Parliament


Multiannual Plan for the Baltic Sea – joint NGO priorities for the Fisheries Council

This briefing was sent to Fisheries Ministers in advance of their AgriFish Council meeting on 20 April, 2015, National Fisheries Ministers discuss the Commission’s proposal for the Baltic Multiannual Plan (MAP) (2014/0285 (COD)), and in particular the Presidency proposal for a compromise.

In this letter we urge Member States to adhere to the binding objectives of the Common Fisheries Policy (CFP), to be mindful of the Fisheries Committee vote of 31st March.
Multiannual Plan for the Baltic Sea – Joint NGO priorities for the Fisheries Council


Multiannual plan for the Baltic Sea – joint NGO priorities for the Fisheries Committee

This briefing was sent to MEPs in advance of the Fisheries Committee  meeting on 31st of March 2015 and their vote on Jarosław Wałęsa’s report concerning the EU Commission’s proposal for a Baltic Multi-Annual Plan (MAP) on cod, sprat, and herring 2014/0285 (COD).

In this letter we urge MEPs in the Fisheries Committee to ensure that the objectives of the reformed Common Fisheries Policy are not undermined in the new MAP.

Baltic Sea Multiannual Plan – joint key NGO priorities


Multiannual plan for the Baltic Sea – joint NGO priorities

The European Commission’s proposal for a management plan for the stocks of cod, sprat and herring in the Baltic Sea is the first multi-species plan to be delivered by the new Common Fisheries Policy. This is a first step to address fisheries management through an ecosystem based approach, looking at multi-species interactions instead of single-species management.

In this joint NGO letter we aim to address the priorities on the multiannual plan for the Baltic Sea.

Joint NGO Priorities on the Baltic Sea Multiannual Plan


 

2014

Priorities for MSFD programmes of measures – a joint NGO paper

The Marine Strategy Framework Directive (MSFD) has entered a crucial implementation phase as countries are now developing their programmes of measures (PoMs), which are to achieve or maintain Good Environmental Status (GES) in marine waters by 2020. Early and effective public participation and consultation in the development of these PoMs is a prerequisite for their success.

This paper aims to facilitate this process and to support NGOs and national authorities in their work with developing measures. It includes the priority measures and targets NGOs would like to see implemented for a selection of the MSFD descriptors, i.e. commercial fish and shellfish, biodiversity, eutrophication, contaminants and marine litter, as well as recommendations for the establishment of an ecologically coherent network of well-managed marine protected areas. It also provides good practice guidance for organising effective public participation and consultation.

NGO joint statement on priorities for MFSD PoM


MSFD Descriptor 3 and GES – joint  NGO comments

A joint letter from The Fisheries Secretariat (FISH), Oceana, Coaltion Clean Baltic and Seas At Risk regarding Descriptor 3 and the objective to reach Good Environmental Status (GES) for commercially exploited fish stocks within the Marine Strategy Framework Directive (MSFD).

Joint NGO comments on Descriptor 3 and GES


Priorities for environmentally responsible aquaculture in the EU – joint NGO position paper

A joint position paper from Seas At Risk, The Fisheries Secretariat (FISH), Coalition Clean Baltic (CCB), BirdLife International, Marine Conservation Society, The North Sea Foundation, WWF, The Swedish Society of Nature Conservation, BUND, European Bureau for Concervation and Development and ENT addressing our shared priorities for environmentally responsible aquaculture in the EU.

Priorities for environmentally responsible aquaculture in the EU 


Baltic ecosystem based multispecies management – briefing from FISH and CCB

The EU as a whole has an ambition to move towards long term multispecies management, rather than single-species management. As with several efforts in the past, the Baltic Sea region is to move ahead. For these reasons, a Baltic multispecies management plan has been discussed over the past three years.

The latest advice provided by the International Council for the Exploration of the Sea (ICES) now urgently needs to be revised since the status of the eastern Baltic cod stock has changed dramatically. We now urge decision-makers to be patient and not push through a premature proposal for a Baltic multispecies plan.

FISH and CCB briefing on Baltic ecosystem-based multispecies management


Seal damaged fish – a joint NGO letter to BALTFISH

A joint letter from Oceana, The Fisheries Secretariat (FISH), Coalition Clean Baltic and the Finnish Association for Nature Conservation (FANC) regarding the BALTFISH High Level Group Joint Recommendation on the Outline of a Discard Plan for the Baltic Sea dated 14 May 2014 and specifically seal damaged fish.

Joint NGO letter to BALTFISH on seal damaged fish


BALTFISH draft discard plan – joint NGO considerations 

A joint response from Oceana, The Fisheries Secretariat (FISH), WWF, Coalition Clean Baltic and the Finnish Society for Nature Conservation on the BALTFISH DRAFT Outline of a discard plan for the Baltic Sea for consideration before submission of the joint recommendations to the European Commission.

NGO considerations BALTFISH draft discard ban plan


 

2013

National priorities for HELCOM contracting parties – joint NGO letter 

At the upcoming HELCOM Ministerial Meeting on 3 October 2013 in Copenhagen, the region’s Environment Ministers will agree on further actions in order to reach the objectives of the HELCOM Baltic Sea Action Plan (BSAP) from 2007. Many of the actions set out in the BSAP in 2007 have still not been implemented – overall implementation has been slow and patchy. The following document presents a set of proposals for national actions to be taken in order to fulfil the objectives agreed upon by HELCOM countries in 2007.

National Priorities for HELCOM contracting parties


Joint NGO letter to Ministers at HELCOM

Joint NGO letter to ministers at HELCOM ahead of the HELCOM Ministerial Declaration meeting 2013 highlighting that we have already agreed on many of the necessary targets and what we need now is action to secure the environmental objectives already agreed upon in 2007 HELCOM Baltic Sea Action Plan (BSAP) and 2010 Moscow Ministerial declaration.

Letter to Ministers HELCOM


Baltic Discard ban – joint NGO considerations  

Joint response from Coalition Clean Baltic (CCB), Oceana, The Fisheries Secretariat (FISH), Finnish Association for Nature Conservation and the Swedish Society for Nature Conservation (SSNC) on the BALTFISH High-Level Group paper State of play with regards to the implementation of a ban on discards in the Baltic Sea for consideration at the joint BALTFISH and 9th HELCOM Baltic Fisheries/Environmental Forum in Tallinn, Estonia, on 29–30 April 2013.

NGO considerations Baltic Discard Ban


 

2012

BALTFISH discard workshop – joint NGO response 

Joint response to the BALTFISH discussion paper “Way forward for discard-free Baltic Sea fisheries” prepared ahead of the BALTFISH meeting in May 2012, as well as the BALTFISH technical working group discussion paper “Implementation of a ban on discards in the Baltic Sea” circulated ahead of the meeting in Tallinn on 28 August 2012.

NGO paper for technical working group on discards


Danish compromise open letter from NGOs

FISH as part of the OCEAN2012 coalition send and open letter to EU fisheries ministers ahead of the General Approach voting.

Joint NGO open letter


BALTFISH Presidency – joint NGO position paper 

We fully support a more regional approach to management of European fisheries; one better tailored to finding appropriate regional and local solutions to management issues. However, if be the platform for regionalised management in the Baltic Sea region, we see make some changes to its structure and organisation.

NGO position paper to the BALTFISH Presidency


Aid for engine modernisation – joint NGO position 

In the proposals for the European and Maritime Fisheries Fund (EMFF), the Commission has recommended legislation to end subsidies for the replacement and upgrade of vessels engines. In this joint NGO position paper we support the move and highlight some additional points that needs to be considered such as the long-standing difficulties in assessing the catching capacity of fleets because of the way in which the actual engine power available on board is able to change.

NGO position on no aid for engine modernisation


 

2011

Baltic Salmon mutliannual plan – joint NGO comment

We greatly welcome the Commission’s proposal for a new multiannual plan for Baltic salmon (COM(2011)470). In order to ensure the recovery of the weak wild populations of both salmon and sea trout, the plan has to be based on the precautionary principle and the ecosystem approach.

111202 Joint response on Baltic Sea Salmon LTMP


Rodust draft report on the Basic Regulation – joint NGO response

Rebuilding fish stocks is one of the key issues in the CFP reform. The status quo of overfishing has been criticised by a consensus of stakeholders and the Commission has proposed that fish stocks achieve the maximum sustainable yield by 2015. Rodust echoes this amibition and has been supported by the coalition of NGOs.

The Commission’s proposal for a reformed CFP Regulation sets out some useful new directions, but does not go far enough in setting clear targets and deadlines for priority actions to end overfishing and protect fish stocks and their marine habitats. We therefore urge members of PECH Committee to take their responsibility for a healthy future for fish, our seas and fishermen by voting in support of amendments to the CFP Regulation which fully reflect these principles.

NGO response to Rodust draft report 

Robust draft report 


Discards – joint NGO briefing

Recommendation in response to Commission proposal in order to ensure efficient and comprehensive approach to avoiding unwanted catches and discontinue the wasteful practice of discarding.

NGO briefing on discards

Last updated: January 12, 2016