Director-General of DG MARE, Charlina Vitcheva has dismissed EAPO concerns over ICES selection process for VME closures to bottom fishing. Photo: Xaime Ramallal
Concerns raised by the European Association of Fish Producers Organisations (EAPO) and the Killybegs Fishermen’s Organisation (KFO) over the processes which led to the European Commission’s decision to close 87 sites of vulnerable marine ecosystems to bottom-fishing have been dismissed by the Director-General of DG MARE, Charlina Vitcheva.
In a letter dated 04 August 2023, the EAPO wrote to the Director-General with concerns over the process used by the International Council for the Exploration of the Seas (ICES) which led to the Commission’s Implementing Regulation 2022/1614 that entered into force early October 2022.
The EAPO laid out to the Director-General that during this initial process, the EU fishing industry had listed 4 major concerns:
- A lack of proportionality, with the selection of option 2.1 which increases the economic impacts, whereas option 2.2 would have limited them.
- A non-respect of the legal basis, caused by the inclusion of buffer zones in the Implementing Regulation, whereas no VMEs are known to occur inside those zones.
- An injustice for netters and longliners, which are prohibited to fish inside the specific trawling buffer zones.
- A non-equality of treatment, represented by smaller zones being closed in Northern Waters, and larger ones in Southern Waters.
Following the publication of a new ICES advice in April 2023 an EAPO member, the Killybegs Fishermen Organisation, conducted a thorough assessment of ICES’s VME methodology and identified 9 fundamental shortcomings. This assessment was carried out using data from ICES division 6.a (West of Ireland and Scotland):
- A lack of transparency in the assessment process on which the advice is based.
- Errors in ICES VME Database and VME Map Portal.
- Lack of support for the current delineation of five out of nine polygons in the study area.
- Inconsistencies between the VME Index layers in the 2021 and 2023 VME advice.
- Inappropriate definition of the depth zones that are the foundation of the assessment.
- Inappropriate delineation of VME Habitats at the c-square resolution level.
- Potential confounding of the VME Confidence Index.
- Questionable exclusion of the VME Confidence Index.
- Biasing of the VME Index due to the exclusion of absence data.
The EAPO, following KFO’s thorough and in-depth analysis, recommended the following steps to be taken to ensure VMEs are effectively protected using best available science:
- To be in line with ICES’s Guide to ICES advisory framework and principles 100% of the data that has been used by ICES to issue their advice should be available on the ICES data portal.
- Similar work should be carried out for other areas not included in KFO’s analysis (Celtic Sea, Bay of Biscay, and Cantabrian Sea).
- ICES should investigate the reported errors and confirm that the shortcomings identified by KFO will be addressed. • Updated advice taking into account the issues identified above should be reissued without delay.
- The Commission, in the meantime, should reopen the areas that have been wrongly identified as VMEs or as potential VMEs for bottom contacting gears.
Replying to the EAPO, Director-General Charlina Vitcheva wrote:
“The European Commission had already taken note of the report prepared by the Killybegs Fishermen’s Organisation (KFO) as it was sent to my services at the time of its release in June 2023. We had then informed the KFO that we transmitted the report to ICES for their consideration and for review by the experts working on Vulnerable Marine Ecosystems (VMEs).
“I wish to underline that, for both ICES advice on VMEs released in 2021 and in 2023, all stakeholders – and notably KFO – were fully included in the process and could take part to the advice drafting groups as observers.
“This allowed all interested parties to make comments and raise issues, which are, I believe, best addressed in these fora, with the relevant scientists and in a collaborative manner. I note that the concerns listed in the KFO report was raised neither during the advice drafting process, nor during the ICES methodology benchmark which took place in April 2022.
“However, I remain convinced that the best use of top scientific inputs lies within the scientific process, and we remain committed to encouraging stakeholders’ involvement in the preparatory stages of this process.”
The Director-General closed her letter assuring the EAPO that their report would be transmitted to the ICES.
