ACV-Transport en Communicatie Register No: 22039112812-17 ACV-Transcom Visserij: Opinion on the 2009 Fisheries Green Paper. In April 2009 the European Commission published its Green Paper on a reform of the common fisheries policy. Why a Green Paper? In the EU context, when a Directive is being drafted the European Commission can publish a Green Paper. This is a discussion document intended to stimulate debate and take stock of opinions on a particular topic at the European level. Usually the Green Paper sets out a range of different ideas on the subject, on which interested citizens and organisations can comment. A Green Paper may be followed by a White Paper, which will contain more detailed legislative proposals and can be used as the basis for a new Directive. All EU citizens and associations are therefore entitled to respond to the Green Paper, and as ACV-Transcom we will now do so in coordination with ETF. The present situation in the fishing industry: Reforms in 2002 have made EU fisheries policy (the common fisheries policy ) more sustainable stakeholders now have more influence on policy-making; many fish stocks are now managed through comprehensive long-term plans (not annually, as before); but big problems remain:
plummeting fish stocks - some 80% of all species in EU waters are currently overfished and some 30% of these are at risk of collapse. There is significant risk that European stocks will collapse across the board; there are too many fishing vessels for the number of fish that can safely be removed from the seas; most EU fishing fleets are making either very low profits or a loss, causing an added incentive to overfish; catches have fallen so much that Europe now relies on imports for two-thirds of its fish consumption. The Commission considers that the above outcomes are due to five main structural failings: a deep-rooted problem of fleet overcapacity; imprecise policy objectives resulting in insufficient guidance for decisions and implementation; a decision-making system that encourages a short-term focus; a framework that does not give sufficient responsibility to the industry; lack of political will to ensure compliance, and poor compliance by the industry. The Commission wants to open the debate around these five issues and welcomes suggestions and opinions. Sustainability??? This is where our basic input to the discussion lies: the Green Paper approaches the fishing industry as a purely ecological concern and ignores policy aspects which we think are crucial. That the fishing industry is one where many employees have to earn their bread in a highly unsafe and unstable environment is not taken into account. Safety, training, social security, working conditions, etc, apparently have no place in a new fisheries policy. By way of illustration: even the development in job numbers, either in the past or in the future, is not considered. Fishery is approached exclusively from a quantitative economic angle. As a trade union we find this unacceptable and entirely contrary to the general aims of a sustainable fisheries policy.
Sustainability is regarded as a balance between economic, ecological and social aspects (see definition in the UN's Brundtland Report). The social aspects are completely absent from the EU's new plan. To illustrate this: you are given no insight into the average level of education, age, aptitude, usability, qualifications, etc, of the employees working in this sector. Without this information it is impossible to outline a policy for 2013-20. As a trade union we want the focus to be on the fisherman rather than the fish. A plan or a discussion at European level which does not even refer to ILO Conventions is not worthy of the name. The same applies to the STCW-F and the Torremolinos Protocol for the Safety of Fishing Vessels. Lacking a proper objective, the Green Paper is more about the way you carry out a policy than about the objectives of the policy. The industry urgently needs these objectives to be discussed. In the absence of these factors, discussion and consultation on the Green Paper could well degenerate into an argument on technicalities and pragmatics. This might be just the thing for Eurocrats, but is not ACV-Transcom's cup of tea. We also find that Europe wants more and more to make the decisions, at the expense of the authority of the Member States. We do not think this is the right way to go. On the contrary, from other dossiers (e.g. Port Package and Bolkenstein) we learn that Europe's social dimension has a very low profile. On the other hand, Europe is highly necessary in such an international dossier as fisheries. For this reason we suggest that Europe should speak out on the major principles but leave implementation and certainly enforcement to the Member States. Europe is welcome to monitor enforcement, of course. Does this fundamental criticism mean that we do not want to get involved? No, not at all: the future of the fishing industry depends on EU policy. So the future of fishermen does too. We would therefore respond as follows to a number of points made in the Green Paper: 1. Overcapacity: defined according to economics or ecology? Definition is unclear and certainly not neutral. 2. If overcapacity the legislator must take restrictive action. Not like in agriculture, where milk overcapacity has to be resolved by the market. Legislation provides possibilities for accompanying measures. 3. Economic lower limit or minimum activity must always be guaranteed. Belgian fishery is below the critical lower limit.
4. Scrapping fund: has reached rock bottom. Belgium will no longer either request or use it. 5. Transferable rights: doubtful whether this can work well for Belgium; but we certainly do not want to rule the system out yet, so leave the choice to the Member States. 6. Lack of basic figures on the social component makes it hard to define realistic objectives. 7. Decision-making level: we are mainly in favour of giving free rein to the subsidiarity principle. Also, legislation and control have to be at the same level (see also the first part of this text). 8. Regional Advisory Councils (RACs) have to be closer to the industry. Advisory role of RACs to be reinforced. 9. Responsibility of the industry: industry has to become more uniform. Compulsory membership of Producer Organisations (POs) essential for a policy if POs to be given more responsibilities. Or a system of generally binding declaration. Government must keep a finger in the pot with regard to control. 10. Financing of fisheries policy has to be linked to control responsibility. Aiming at a European control system difficult (equal treatment necessary), EU must monitor enforcement. 11. Two-track policy towards small vessels (77% of vessels are below 12 metres)? No, but there should be a special policy for small fleets. Hence better definition of what a small coastal fleet is. 12. Management plans for fisheries: difficult to map and a heavy administrative burden. 13. Discarding is debatable from various angles. Need for clarity on what exactly is meant by discarding. 14. Fishing effort and/or TACs: we prefer a combination. 15. Relative stability (each country's share stays relatively the same each year): we are for keeping this system. 12-mile zone reserved for fishery and transport and no other economic activities except in a global maritime policy. 16. Import over land or from non-eu countries has to be included in the (labelling) policy. 17. Fishery (socio-economic aspect) must have a prominent place in maritime policy. Efforts of the fishing industry must also be compensated. 18. Fishing can also be included in the monitoring of pollution and possible consequences of climate change. 19. Whether or not public aid is granted must be linked primarily to the social dimension.
To sum up, we would like to see the following added to the Green Paper: 1. A vision of training, education and standardisation of professional certification and occupational profile. Employees in the fishing industry now chiefly lack knowledge of safety and health standards and ecosystems. In the light of fleet reductions, retraining for other trades should also be made possible (preferably in maritime careers). 2. Something must be done about a safety culture in the fishing industry. Statistics on numbers and causes of accidents are indispensable for this. In this context STCW has to be implemented as the minimum safety standard throughout the EU. 3. Measures to improve working conditions on board. The industry has a poor image and is not very attractive to the young. 4. Status of fishermen is very poorly regulated in the EU. Flanders is fortunately a positive exception to this. Three major problem areas in the EU: bogus self-employment; lack of a guaranteed minimum income and competition from third countries (Philippine fishermen increasingly numerous and not covered by any EU laws). 5. An efficient monitoring and sanctions policy. 6. A structural implementation of the social consultations. Before a White Paper is drafted, we want the trade unions to enter into dialogue with Europe on the social aspect of the policy. As we already hear that only some of the first few hundred comments on the Green Paper even vaguely concern the social aspects, such dialogue is urgently necessary and unavoidable.