(Full feedback in attachment)
● We, the European Anglers Alliance (EAA) and the European Fishing Tackle Trade Association (EFTTA), support Option 2:
‘Amendment of the Fisheries Control Regulation’
● Our response follows up on our response to the consultation of last year:
Our present response focuses mainly on these shortcomings in the Commission’s ‘Inception Impact Assessment’:
- “Fisheries data still incomplete: the Control Regulation sets a number of important provisions for data and information recording, management and sharing, including access by the various stakeholders. However, a number of those provisions appear to be obsolete with regard to available technologies, unclear, open to different interpretations or not fully adequate to the specificities of the various fisheries/sectors, in particular for small scale fisheries. The provisions also allow for too many derogations and exemptions which hinder the quality of the data collected and jeopardise full compliance with the CFP. Additionally, there is a need to review the provisions enabling sharing and exchange of data with other parties with a legitimate interest, enabling synergies and cross-sector use, especially as regards VMS positioning data.”
1): To streamline the EU fisheries management two-tier system (commercial- and recreational fisheries), by identifying and to legislate ‘semi-commercial’ or ‘semi-subsistence’ fisheries to fit regulations under one or the other of the two sectors.
2): To aim at “fully documented fisheries”
3): To make use of one and the same recreational fisheries sector definition across EU fisheries management acts.
4): That the 2020 objectives in EU fisheries, biodiversity and conservation policies and acts as well as targets set in the ‘Malta MEDFISH4EVER Ministerial Declaration’ of 30 March 20174 are reached on time
Ad 2: To aim at ‘fully documented fisheries’
Vessels below 12 metres should be better controlled, and more and better catch and discard data provided. A big step to achieve ‘fully documented fisheries’ would be to delete or modify relevant exemptions in the Control Regulation e.g.:
- Article 9: VMS should be required for more or all commercial fishing vessels
- Article 14(1): The 10 metres and 50kg thresholds should be removed
- Article 15: The 12 metres threshold should be removed
- Article 16 (see text below)
- Article 17(6): Delete
- Article 21(6): Delete
- Article 23(1): The 10 metres threshold should be removed
- Article 24(1): The 12 metres threshold should be removed
- Article 58(8): Delete
- Article 59(3): Delete
- Article 65: Delete
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