Positions & Papers

An assessment of the effectiveness of the Baltic Sea MAP

September 24, 2019

Fit for purpose? An assessment of the effectiveness of the BSMAP is a joint analysis of the Baltic Sea Multiannual Management Plan (BSMAP) by Pew Charitable Trusts, Birdlife International, WWF, FishSec and Oceana. We conclude that the BSMAP has failed to improve fisheries management in the Baltic Sea. The state of the Baltic ecosystem and its fish stocks speaks for itself. In place since July 2016, the BSMAP, was the first management plan adopted by the EU after the reform of the Common Fisheries Policy in 2013. Having been in place for three years it is being evaluated by the European Commission and has had a stakeholder consultation. We conclude that the BSMAP has failed to improve fisheries management in the Baltic Sea and recommend that MAPs and the CFP definine a maximum level of fishing mortality in future. The state of the Baltic ecosystem, its fish stocks and the decision-making process speaks for itself.

In summary:
  • MAPs were introduced in the CFP to address three specific challenges: the need for longer-term (multiannual) management geared towards achieving the CFP’s objectives; the need to take into account regional and ecosystem specificities; and the desire to bring decision-making closer to the regions in question.
  • The Baltic MAP was instrumentalised to serve other purposes, key among which was the facilitation of the implementation of the LO and providing decision-makers with flexibility regarding fisheries management – not only in the Baltic region, but first and foremost in other European seas.
  • The flawed design of the Baltic MAP led to management decisions and fishing practices that have failed to fulfill the intent of the CFP and achieve the MSFD’s Good Environmental Status target. The intended regionalisation elements have failed to ensure the MAP delivers on the specific needs of the Baltic in a timely manner, and lastly the MAP has failed to help deliver TACs in line with MSY and scientific advice.

Joint NGO response to the Commission consultation on the setting of fishing opportunities for 2020 under the CFP

August 21, 2019

In response to the Commission Communication on fishing opportunities for 2020, The Pew Charitable Trusts, Oceana, ClientEarth, Seas At Risk, FishSec and Our Fish have provided a joint response.

We urge the Commission to ensure that the TACs proposed and set for 2020 meet the objectives and requirements of the Common Fisheries Policy (CFP), ensure that the Landing Obligation (LO) is effectively implemented, and commit to a process of proposing and setting fishing opportunities that is transparent to citizens and civil society organisations.

In our recommendations to the Commission we call on them to follow scientific advie in all of its TAC proposals for 2020, for both target and bycatch stocks. Moreover, we highlight the need for correct implementation of the LO and provide seven policy improvements. In addition, we call on the Commission to improve the transparency and accountability of the TAC setting process.

DSCC Position Statement on Deep Seabed Mining

July 19, 2019

DSCC-Position-Statement-on-Deep-Seabed-Mining_July2019The Position Statement explains the overarching goals of the Deep Sea Conservation Coalition (DSCC) regarding Deep Seabed Mining. FishSec is a member of the DSCC. The coalition is made up of more than 80 non-government organizations, fishers organizations and law and policy institutes working together to protect vulnerable deep-sea ecosystems. We aim to substantially reduce the greatest threats to life in the deep sea and to safeguard the long-term health, integrity and resilience of deep-sea ecosystems. The main focus is on ensuring the sustainability of deep-sea fisheries and addressing the potential threat of deep-sea mining. Read the statement here.

Joint NGO letter to new Parliament: “EU needs committed and ambitious MEPs to save our ocean”

July 15, 2019

In a letter to newly elected MEPs serving in the European Parliament for the next five years, environmental organisations BirdLife, ClientEarth, The Fisheries Secretariat, New Economics Foundation, Oceana, Seas At Risk, and WWF called on politicians to deliver on 8 concrete EU commitments that protect marine life, habitats and biodiversity. The letter highlights that "the EU already has the laws, obligations and commitments. Now we call on you to move from words to actions. We count on your determination in this challenge."

These commitments include "4. Fully implement the Common Fisheries Policy. 5. Eliminate Illegal, unreported and unregulated fishing, and strengthen fisheries control and enforcement; introduce fully documented fisheries. 6. Save the Mediterranean - the most overfished sea of the world - by reducing the excessive fishing effort, minimizing fishing impacts on vulnerable species and habitats and substantially improving the culture of compliance in the region."

Joint NGO letter to European Commission – urgent action needed to stop cetacean bycatch

July 10, 2019

A coalition of 27 NGOs have written to the European Commission calling on them to implement emergency measures in order to protect cetaceans, such as dolphins and porpoises, killed and captured during unselective fishing operations. These bycatch killings contravene the EU Habitats Directive and the Common Fisheries Policy which aim to conserve biodiversity and ensure that fishing has a minimal impact on non-target species. The letter states: "Bycatch is the greatest threat to the conservation of cetaceans, globally and in European waters. Commercial fishing is the last human activity targeting wildlife on a grand scale where the killing of other large sapient wildlife occurs on such a regular basis.

Article 12 of the Habitats Directive mandates that Member States establish a system of strict protection for cetaceans prohibiting all forms of deliberate capture or killing of specimens of these species in the wild and that conservation measures are taken to ensure that bycatch does not have a significant negative impact on these species. The Habitats Directive also mandates that Member States take appropriate steps to avoid the disturbance of the cetacean species for which Natura 2000 areas have been designated. To date, however, Member States have failed both to implement and enforce a general system of measures to reduce bycatch and to manage cetaceans’ Natura 2000 sites to make them safe spaces contributing to restoring these populations to favourable conservation status. As a result, cetacean populations in Europe are under great stress."

Joint NGO letter to MEPs: EU needs committed and ambitious MEPs to save our ocean

July 10, 2019

In a letter to the newly elected Members on European Parliament the environmental organisations BirdLife, ClientEarth, The Fisheries Secretariat, New Economics Foundation, Oceana, Seas At Risk, and WWF lists concrete EU commitments and crucial actions in the next five years, i.e their term in the Parliament, to save our oceans.

Joint NGO recommendations on Baltic Sea fishing opportunities for 2020

June 10, 2019

In October 2019, EU fisheries ministers will agree on fishing opportunities in the Baltic Sea for 2020. This will be the final Council meeting where fisheries ministers have the opportunity to end overfishing of Baltic Sea species by 2020, as is legally required by the Common Fisheries Policy (CFP).

We urge the European Commission (EC) to propose, and the Council to agree on, Total Allowable Catches (TACs) in accordance with the following recommendations:
  • Set TACs not exceeding scientifically advised levels based on the Maximum Sustainable Yield(MSY) approach for all stocks for which MSY-based reference points are available.
  • Where MSY-based reference points are not available, to not exceed the precautionary approach catch limits advised by the International Council for the Exploration of the Sea (ICES).
  • Set TACs not exceeding the FMSY point value specified in the Baltic Multi-Annual Plan (MAP), following the ICES MSY Advice Rule when spawning stock biomass (SBB) is below the MSY Btrigger reference point.
  • Take into account the lack of implementation of the Landing Obligation (LO) when setting TACs, and ensure that TACs are respected by increasing monitoring and control of the LO.
Read the NGO briefing here.

Joint NGO letter to European Parliament lead candidates

May 17, 2019

The environmental organisations BirdLife, ClientEarth, The Fisheries Secretariat, Oceana, Seas At Risk, and WWF are calling on the newly elected members of the European parliament to take “committed and ambitious leadership to save our ocean”. In a joint NGO letter to MEP lead candidates to the European Parliament elections on 23-26 May 2019, NGOs highlighted the need for the European Union to provide committed and ambitious leadership to save our ocean. Referring to commitments made under the UN Sustainable Development Goals, Common Fisheries Policy, Marine Strategy Framework Directive, EU biodiversity strategy and Birds & Habitats Directive we call on the EU to implement the laws and obligations to which it is committed. NGOs urge the fulfillment of eight crucial actions over the next five years in order to ensure the future of European seas and our collective future is protected. The European Green party replied stating "The European Green Party is glad to inform you that the Green Lead Candidates, Ska Keller and Bas Eikchout, commit on the crucial actions that you mention in your letter." The European People's Party replied saying "Combatting climate change and defending our environment are fundamental for our future. This is why fighting climate change is one of our election priorities....We would like to express our support for your work in defending our nature and oceans."

Joint NGO letter – Commission proposals on fishing opportunities for 2020

March 28, 2019

In the letter to the Commission regarding their proposals for fishing opportunities in 2020 the NGOs highlight that this is the last opportunity to meet the 2020 legal deadline to end overfishing.

The Commission has stated its ambitions to deliver on the CFP’s requirements regarding sustainable fisheries and progress has been made in the last decade to bring fishing mortality levels closer to scientifically advised levels.

According to the 2018 report from the Scientific, Technical and Economic Committee for Fisheries (STECF), “many stocks remain overfished and/or outside safe biological limits, and [...] progress achieved until 2016 seems too slow to ensure that all stocks will be rebuilt and managed according to FMSY by 2020.” Our own analysis of the decisions demonstrates that, only one year before the 2020 deadline, more than 40% of TACs are still set higher than scientific advice.

It is therefore crucial that the Commission’s proposals for 2020 do not exceed scientific advice for any stock, in order to meet the CFP’s requirements. This will be particularly important as the Council adopts, for the first time, “effort quotas” under the Western Mediterranean demersal multi-annual plan. The Commission has a responsibility to send a strong signal that fisheries management in the Mediterranean – the most overfished sea – should now follow scientific advice.

Several international agreements require urgent progress toward fisheries sustainability, and the CFP built in a lengthy lead-in period to allow the EU to meet its 2020 deadline, after a reform in 2013 that was backed by unprecedented public support.

EU Control Regulation Review – factsheets

March 15, 2019

On 6 November we have produced an updated and consolidated document: Joint NGO priorities on the revision of the EU Fisheries Control System

The following factsheets present the NGO priorities on the revision of the EU Control Regulation:

Joint NGO priorities on the revision of the Control Regulation

Remote Electronic Monitoring





Small-scale fisheries

The European Fisheries Control Agency (EFCA)

These call on decision-makers to:
  • Ensure full compliance with the landing obligation;
  • Adapt the general control framework to the control of technical measures;
  • Maintain and improve the EU legal framework for enforcement and sanctions;
  • Mandate the use of cost-efficient tracking devices and the electronic reporting of catches and fishing operations for small-scale vessels;
  • Improve the control of recreational fisheries;
  • Improve traceability requirements;
  • Improve data management and sharing;
  • Ensure the monitoring and control of fleet capacity;
  • Effectively control fishing in restricted and marine protected areas;
  • Introduce transparency requirements;
  • Minimise the amendments to the EU IUU Regulation by staying within the scope of the Commission’s proposal and by strengthening only those provisions opened for review;
  • Revise the European Fisheries Control Agency (EFCA) mandate.