Miljø- og Fødevareudvalget 2020-21
MOF Alm.del Bilag 188
Offentligt
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Subject: Urgent Need for Fully Documented Fisheries - AGRIFISH Ministers Meeting - 15/16
th
December 2020
Dear Co
issio er Si ke ičius a d Federal Mi ister Klö k er,
European Union (EU) fishers are currently being granted extra quota despite general non-
o plia e with the Co
o Fishe ies Poli y CFP s la di g o ligatio
1
.
A recent scientific paper
2
confirms that since 2015, fishers have been given additional quota to account for the extra non-
commercial catch that they have to land. However, unaccounted discarding has continued in excess
of the set quotas and Member States are not enforcing accurate documentation to monitor and
contain this behaviour. According to International Council for the Exploration of the Seas (ICES) and
Scientific, Technical and Economic Committee for Fisheries (STECF) scientist Dr Lisa Borges, this
combination of increased quotas, unaccounted discarding and lack of Remote Electronic Monitoring
(REM, including CCTV), is causing unprecedented pressure on our public resource and threatens to
i plode the Total Allo a le Cat hes TACs syste , hi h is the fu da e tal asis of EU fisheries
management
2
.
In 2015, the EU initiated the obligation to land and count all fish caught. To ease the transition to a
system where TACs refer to catches rather than landings only, the majority of EU TACs were increased
to account for the portion of catch that was previously discarded and would now be landed
3
. Dr Lisa
Borges’
paper
2
now shows an average annual upward adjustment of 36% in TACs in 2015, increasing
https://ec.europa.eu/fisheries/press/fisheries-north-sea-and-north-western-waters-landing-obligation-not-respected_en
Lisa Borges (2020), The unintended impact of the European discard ban, ICES Journal of Marine Science, IN PRESS, DOI:
10.1093/icesjms/fsaa200
3
ClientEarth (2020). Setting Total Allowable Catches (TACs) in the context of the Landing Obligation.
https://www.clientearth.org/latest/documents/setting-total-allowable-catches-tacs-in-the-context-of-the-landing-
obligation/
2
1
 MOF, Alm.del - 2020-21 - Bilag 188: Henvendelse af 5/12-20 fra Mogens Schou om mandat til fiskeriforhandlingerne 15.-16. december 2020
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to 50% i 2020 through the appli atio of top-ups to o er pre ious dis ards a d the
(for continued exemption discards).
top-do
s
However, discarding has not declined at any significant level and
Member States have not complied
with their obligation to account for all catches. T
he magnitude of the TAC increases and the continued
discarding have likely resulted in a substantial and widespread increase in fishing mortality, which
undermines the accuracy of scientific data, the ability of scientists to give reliable advice for fishing
limits, and therefore the ability of governments to make appropriate fisheries management decisions
in line with EU legislation and international fisheries obligations.
The Solution:
The European Commission and the Council of the European Union must urgently clamp down on this issue,
when setting fishing limits for 2021 and beyond. This includes both the fishing limits set by the EU alone
through the TAC Regulation for 2021 (being discussed on 15th-16th December 2020) and those set in
negotiations on stocks shared between the EU and the UK.
The CFP cannot meet its sustainability objectives without full catch documentation and accountability.
The
extra quota top-ups that have been granted to Member States and fishers over the past few years
through the TAC Regulation to cover the previous discard fraction should be withheld where compliance
a d a ou ta ility a e ot de o st ated. I othe wo ds, the dis a d f a tio of the uota should o ly
be released for fishers and Member States that can fully and accurately document and report their total
catches, for example by using REM, including CCTV. This should be implemented from 1st January 2021,
starting with the most critical fish stocks.
At the same time, the Commission and the Council should agree on a mandatory REM regime in the revision
of the Fisheries Control Regulation. Indeed,
REM has proven to be one of the most effective and efficient
tools to ensure fully documented and reported catches. However, while we await an effective revision
of the Fisheries Control Regulation that ensures that all catches are documented and reported, including
through a mandatory REM regime, the TAC and Quota Regulation is the key vehicle to prevent
overfishing in 2021.
Fully documented fisheries have been given quota increases in several TAC and Quota Regulations in
recent years. It is a feasible and practical approach that will incentivise sustainable fishing practises to
the benefit of both fishers and fish stocks.
Yours sincerely,
Marta Marrero Martin, Director of Ocean Governance at The Nature Conservancy
 MOF, Alm.del - 2020-21 - Bilag 188: Henvendelse af 5/12-20 fra Mogens Schou om mandat til fiskeriforhandlingerne 15.-16. december 2020
On behalf of:
Birdwatch Ireland
Coastwatch
ClientEarth
Environmental Justice Foundation
Danmarks Naturfredningsforening
Deutsche Umwelthilfe
Dutch Elasmobranch Society
Fundacio Ent
Good Fish Foundation
Irish Whale and Dolphin Group
Living Sea Denmark
Marine Conservation Society UK
Oceana
Ocean Care
Our Fish
Sciaena
The Nature Conservancy