EAPO Europêche dogger mpa

EAPO and Europêche has raised concerns about the UK’s MPA plan for Dogger Bank

The EAPO and Europêche have expressed their concerns about the United Kingdom’s proposal for a Marine Protected Area on the Dogger Bank.

Responding to the consultation on the MPA measures, the EAPO and Europêche outlined the position of their EU members on the issue.

EU fishing industry response to the consultation on the UK Dogger Bank MPA measures

The Dogger Bank is a series of sand banks in the North Sea. It is an area that is straddling the Danish, German and Dutch waters along with the UK ones. This area has been a traditional fishing ground for fishing communities of 7 EU Member States, the UK and Norway. Management measures Dogger Bank Special Areas of Conservation (SAC): from 2004 to 2011, Germany, the Netherlands and the UK proposed adjoining sites to form a Natura 2000 zone under the Habitat Directive Annex 1 Habitat Type ‘Sandbanks which are slightly covered by sea water all the time’ [1]. Different projects and proposals of fisheries measures were made to reduce the pressure on the benthic habitats. A Joint Recommendation by the Scheveningen Member State Group was submitted to the Commission on June 19, 2019.

UK proposal to prohibit bottom towed gears

The UK has left the European Union with the transition period ending on January 1st, 2021. The UK government, though DEFRA started on February 1st, 2021 a consultation process on a proposal to prohibit “all bottom towed fishing, including demersal and semi-pelagic trawls, demersal seines and dredges throughout the SAC [Special Area of Conservation], and a small buffer area around the SAC”. This proposal will also apply to EU vessels with fishing access rights.

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The EU fishing industry would like to comment on this proposal because it will directly restrict fishing in a traditional fishing ground for numerous EU fishers from Denmark, the Netherlands, Belgium, Sweden, France, Germany, and Ireland. Work on management measures in this area has been ongoing for about 10 years now. Stakeholders’ input has been instrumental and will continue to be so in order to reach balanced measures aiming for environmental and economic sustainability goals. The Dogger Bank is an area straddling on waters of different countries and cooperation is therefore key when setting up management measures.

EAPO and Europêche are deeply concerned about the proposal made by the UK government to close the UK SAC of the Dogger Bank to many fishing gears. This will directly affect the viability of many fisheries and in turn strike coastal fishing communities around the North Sea. The proposal to completely ban bottom towed gears, semi-pelagic trawls, bottom seines and dredges in the entire area is far from reaching a balanced approach to the three pillars of sustainability, namely economic viability, environmental protection and social equity. It completely disregards the stakeholder’s position and the socio-economic consequences that are entailed.

The proposal utterly neglects pre-existing work on management measures that has been carried on for the past 10 years, including the Joint Recommendation of the Scheveningen Group, to which the UK was a party. The EU fishing sector is absolutely puzzled to see this work overlooked when this agreement had been signed by the UK competent authorities and agreed by all Member States of the group. Moreover, the proposal is opposed to the Habitat Directive Article 2(3) by putting forward provisions not considering economic, social and cultural requirements and regional and local characteristics. Furthermore, the proposal foregoes the need to consult and take into consideration the socio-economic factors which is certainly a breach of the spirit of the Brexit Treaty. Therefore, also in light of the continuous nature of the marine environment and the ability for many species to move freely from one area to another, including across borders, a co-ordinated management of sites is necessary, as a minimum, the Dutch, German and Danish Ministries, as well as the European Union as a whole, should be consulted in that process as a contiguous neighbouring State, and with waters which also cover the Dogger Bank.

The EU fishing industry has been working on reducing the bottom impact of gears for years with nonstop improvement and continues working in that direction. Nonetheless, some gears are the only ones available for a viable fishery targeting a number of species. It is unacceptable to completely ignore the constant technical innovation in fishing gears made due to joint efforts from scientists and fishers, announce such blanket ban, and shift the problem elsewhere. This creates displacement of fishing in other areas with potentially negative environmental consequences, let alone the increasing socio-economic stressors in these other areas caused by this dislocation. In cases where fishermen cannot catch their usual quotas, it might also lead to an increase of fish imports from third countries with less stringent fisheries management measures. When new fisheries management measures are proposed, especially as rigid as these, they should be backed-up by scientific and socio-economic arguments for the sectors affected.

Effective fisheries management is the solution

To conclude, EAPO and Europêche would like to highlight that science-based management is the most efficient way to achieve the UN Sustainable Development Goal (SDG) 14 while achieving other equally relevant SDGs such as food security and socio-economic development simultaneously (SDG2 and SDG 8 respectively). Fencing off fishing in large parts of the ocean and denying EU and UK consumers the benefits from sustainable, local, nutritious food is not the way forward to a sustainable food system. Furthermore, the EU fishing sector fully endorses the FAO target of 100% of seascapes to be sustainably managed on the basis of the ecosystem approach. Regarding the high complexity in managing marine areas, it is paramount that all stakeholders are consulted and involved from an early stage in sustainable ocean management.

In the case of a shared fishing ground like the Dogger Bank, priori work undertaken by stakeholders and Member States, including the UK, cannot be taken off the table in a unilateral way. Without cooperation from all parties, it is not possible to achieve effective fisheries management. The baffling proposal is completely counterproductive in this respect.

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