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SFPO skrivelse till EU-kommissionen med synpunkter om fiskerikontrollregelverket
Viewpoints from the Swedish Fishermen’s Producer Organisation (SFPO) on the review of Council Regulation (EC) No 1224/2009 of 20 November 2009 establishing a Community control system for ensuring compliance with the rules of the common fisheries policy – to the European Commission, DG MARE
General comments
SFPO will first underline and stress the need for a thorough review of the Control Regulation and the Implementing Regulation, they must be revised to be more coherent with the current CFP. When the current regulation was adopted in 2009 the fisheries policy was unfortunately characterized as micro-management, however with the new CFP we are now luckily moving away from this to a more result based management.
All CFP rules should as intended be applied in the same way regardless of where the offence occur. Level playing field is a basic prerequisite for the CFP. Differences in the application of Member States undermine the credibility of the policy.
There is a great need to simplify the regulatory framework, the current regulation is enormous in scale and is characterized by a high degree of complexity which is difficult to understand (detailed regulation). A fundamental requirement for a regulation is to be effective and understandable for its users.
It would be a considerable improvement if the Control Regulation and the Implementing Regulation was separated in two documents – one covering what applies to the fishery and another what applies to the institutions and the Member States. This would make it easier for the fishermen to comprehend and would make it easier for a better compliance of the rules. A fisherman is interested in the substantive and specific control rules so that they can be complied with, not what the obligations of the Member States are.
Recreational fishing is nowadays so extensive that it can no longer be ignored that there is a serious need for control. In Sweden, recreational fishing is still without any form of control.
The Control Regulation
Purely textual and structural, what is central to the regulation should be stated in articles. An article such as Article 2a should not exist. With other words the main provisions - the basis for the fisheries control policy – should be stated in articles. Provisions such as Article 2a should be placed in a note etc.
To achieve a uniformed application within the Union of the provisions of the CFP, consideration should be given to what extent national derogations could be made possible. On the one hand, those could be needed in regionalization process, on the other hand, they could undermine the objectives of creating a level playing field.
Considerations should be given to abandoning the VMS system and instead introducing AIS requirements, since the technology simply is better.
The pre-notification rules should be mandatory both upward and downward, i.e. it should not be possible to tighten these rules nationally. Such a measure is contrary to the idea of a common policy and, in addition, distorts competition.
A review of the information to be provided by fishermen must be done and in a serious manner with focus on relevance. The administrative burden is today to heavy. Fishermen must be able to comply in an easier way in accordance with the rules.
Control policies must be adapted to the reality and the level of ambition must be scaled down without sacrificing the ultimate purpose, in other words focusing on what is important and relevant and an elimination of what is not. An example of this is the rules on machine power monitoring which we see as redundant. As far as we know, this have never been checked in Sweden. There are many rules that do not fulfill and specific function, they are redundant and in many cases, they are even counterproductive. The rules existing must be enforced, otherwise it leaves us worry over the European fishing industry that the rules undermine and contribute to the belief that it is ok not to strictly comply with the rules (regulatory inflation).
As more or less all fishing boats are tracked, there is no reason to have designated ports. The regulation of designated ports impedes a natural development in the sense of emergence of new ports where fish can be landed. This is especially a constraint for the small-scale fisheries.
Both the traceability and the weighing rules in Articles 58 and 60 leave much to be desired. It could on good grounds be questioned as to whether there really is a need that is proportional to the total costs. Fish are organic living in water and dewaters and lose weight when not in the sea.
The point system is another package that leaves much to be desired. It is not applied everywhere or is applied differently in the Member States, which could not have been the purpose when introduced. Furthermore, SFPO considers it to be objectionable and fundamentally wrong that an item, a fishing boat, could be loaded with points. There is no such arrangement for any other businesses, and a fishing boat itself cannot make a mistake.
SFPO is of the opinion is that the monthly records should cease to exist.
In conclusion, we underline the importance of a proper and strict control, to ensure the same competitive conditions. Unfortunately, the present control regulation contains too much of naval shooting. A relevant and functional control where the fishermen can comply and do right must is an important fundamental part of the fisheries policy.
Kind regards
Peter Ronelöv Olsson
Chairman, Swedish Fishermen’s PO