Open letter to the Minister of Agriculture Food and Environment Mr Arias Canete


Dear Mr. Arias Cañete,

We are approaching the final phase of the negotiation regarding reform of the Common Fisheries Policy (CFP). The trilogue, between the European Parliament, the European Council and the European Commission, will determine in the following months the future characteristics of fisheries and the marine environment of Spain and of the rest of Europe. Being aware of the historical relevance of this moment, we would like to bring to your attention the following considerations:

Maximum Sustainable Yield

A key aspect to the negotiations is the fisheries management based on Maximum Sustainable Yield (MSY).  The Council, as well as the Parliament, agrees on developing a fisheries regulation based on surplus production models, thus considering MSY as a reference and as a tool to determine fishing mortality (Fmsy). The main discrepancy between both bodies relies on establishing the fishing mortality (Fmsy) that permits the achievement of MSY:

  • the General Agreement proposal does not to take into account the current state of the stock
  • the Parliament suggests establishing the fishing mortality based on existing biomass for the purposes of having a healthy and sustainable stock on a certain date.

In view of the different opinions, we, the undersigned, are in favor of establishing a fishing mortality based on the existing biomass and set temporary goals that are as accurate as possible for the recovery of the stocks, a position better reflected in the current proposal by the European Parliament (Article 2.2., through amendment 60):

“The Common Fisheries policy shall apply the precautionary approach to fisheries management, and shall ensure that, by 2015, fishing mortality rates are set at levels that should allow fish stocks to recover, by 2020 at the latest, above levels that are capable of producing the maximum sustainable yield and allow all recovered stocks to be maintained at these levels”.

There are several examples of fisheries management based on the existent biomass, that aim to reach a certain final state of stock. The most well-known case is probably the experience in the USA regarding the recovery of fishing stock, which were in a state of overfishing, until reaching healthy levels. This goal was achieved thanks to the Magnuson-Stevens Act of 1996, subsequently amended several times. Its application relies on establishing an overexploitation limit based on the biomass, consisting of less than 50% of the biomass. Those stocks under this level are considered to be overexploited and a recovery plan is designed. In these plan,s the fishing mortality (F) is limited to the necessary level required to achieve the recovery of population within a specified term. The report submitted by the NRDC (Natural Resources Defence Council) in February 2013 shows how 64% of the 44 initially overfished stocks have recovered successfully or have shown a significant recovery. From an economic stance, these results have meant a 54% increase in the income of fishermen between 2008 and 2010, compared to the income they earned at the beginning of the recovery of stock.

Scientific criteria and mechanisms of control and enforcement

In order to achieve the goals related to fisheries management, it is highly important to adjust the fishing effort in an adaptive, sustainable and consistent manner, through different models of fisheries evaluation. For such purposes, it is vital to apply Scientific Criteria in accordance with Article 16 proposed by Parliament regarding the determination of fishing possibilities.

Equally, as scientific professionals, we support the implementation of the Ecosystem Approach for the purposes of minimizing the human impact produced by the fishing activities and fish farming on the ecosystem, as proposed by Parliament in Amendment 60.3.

Together with the scientific recommendations, it is essential to establish enough mechanisms of control and enforcement to ensure compliance with what was agreed.  If rules are not implemented, it is very likely that it may be impossible to reach the planned goals.

As an example, it is important to highlight the failure of the multiannual plan for the recovery of the southern hake and nephrops of the Cantabric sea and west area of the Iberian Peninsula (Council Regulation (EC) No. 2166/2005 of 20 December 2005). That plan came into force in January 2006 with the aim to increase the biomass of reproductive hake until reaching 35,000 tons within a ten-year term and to reduce the fishing mortality to F=0.27. According to the CIEM report of 2010, the plan was not effective mainly due to deficiencies in its application.  Due to this, in 2010 the fishing mortality goal (FMSY = 0.27) was practically tripled (FMSY = 0.74), with landings 2.2 times higher than the Total Allowable Catch (TAC). The same report expresses that one of the causes of the failure was very likely the incorrect management of the national fishing effort. 

Management of capacity and fishing effort

The fishing effort is the result of the fishing capacity of a vessel multiplied by its activity. Traditionally, and in accordance with Council Regulation (EC) No. 2371/2002, the fishing capacity is expressed through power measured in kilowatts (Kw) and the loading or tonnage capacity, expressed in Gross Tons (GT). In view of the fact that measurement of the capacity through power does not provide a true and real assessment of the fishing capacity and therefore a real measurement of the fishing effort, it would be convenient to work with other parameters which may provide a measurement of capacity closer to reality. For such purposes, it is possible to use more representative indicators for each fleet: the trawling speed and the opening surface of the net in the trawling, the number of hooks in the line, the size of nets and, in the case of fish traps, the number and size, etc.

Therefore, we support the proposal for the regulation of the fishing capacity submitted by the European Parliament in Article 5.19 through amendment 85, which defines the fishing capacity as “the ability of a vessel to catch fish, measured in terms of vessel characteristics, including a vessel’s tonnage in GT (Gross Tonnage), its power in kW (Kilowatt) as defined in Articles 4 and 5 of Council Regulation (EEC) No 2930/86 of 22 September 1986 defining characteristics for fishing vessels, as well as the character and size of its fishing gears and any other parameter that affects its ability to catch fish”.

If we continue applying the classical measurement system of fishing capacity, it will still be very hard to correctly evaluate the actual fishing effort.

Likewise, in order to balance fishing effort with the existing living marine resources, it is essential that the new legislation considers the measurement of the fishing capacity of the fleet in relation to the capacity of the ecosystem, evaluating annually the ratio between the fishing capacity and the biomass. This ratio should be a key factor when granting access or not, as well as the fishing opportunities, to the funds of the European Fisheries Fund in order to ensure that these resources are employed only to foster and reestablish the fishing effort-biomass balance of fisheries, thus improving the fishing capacity and ensuring that they do not favor the overcapacity of the fleet.

The correct use of these indicators translates into biological, economic and social benefits, for the fishing professionals as well as for the rest of the community. Due to this, we express our firm support towards the proposal prepared by the European Parliament in Article 34.1 bis, ter and quarter.

Co-management plans

We welcome that there exists a shared vision regarding a Common Fisheries Policy which emphasizes a decentralized management and, in particular, we support the idea that the management of national stocks is better performed through Co-management plans. This will imply the requirement of justifications in case the Government chooses to deviate from the resolutions of the Co-management committees. This position is expressed in Article 17.2 octies submitted by the European Parliament. As a consequence, we encourage the Cabinet of Spain to support the regulation of fishing stocks through these Co-management models, thus favoring the well-being of fisheries, in its biological, social and economic context.

Promoting prosperity in coastal communities

The social and economic importance of small-scale coastal fleets and aquaculture in certain regions calls for specific measures for these fleets. The measures should support green, smart and inclusive growth and should contribute to sustainable, low-impact fishing and aquaculture, innovation, income diversification, reconversion, improvement of science and a culture of compliance (COM(2011) 417 final, subsection 2.3).


The undersigned express their support towards the introduction in the Common Fisheries Policy of a fisheries management based on the Maximum Sustainable Yield based in the existing biomass, establishing a clear calendar to ensure the recovery of the stocks. Moreover, we stress the importance of the use of Scientific Criteria in the fixing of the fishing mortalities and we consider vital to establish new indicators to measure fleet capacity and, as a consequence, indicators of the fishing effort, which therefore permit to strike a balance with the recovery capacity of the ecosystem. Moreover, we, the undersigned consider that the management of fisheries at a regional level through the application of Co-management Plans is highly important and we highlight the socioeconomic importance of the artisanal coastal fleets, which shall have a special consideration within the objective of promoting sustainable development of coastal communities.

We hope that these considerations are useful to you and we trust that the Ministry that you represent keeps them in mind during the final negotiations of the Common Fisheries Policy reform.

Kind Regards,

Associació Catalana d’Oceanògrafes i Oceanògrafs
(Catalan Oceanographic Association) 

Asociación de Oceanógrafos de Galicia
(AOG, Galician Oceanographers Association)

Federación Española de Oceanógrafos
(FEO, Spanish Federation of Oceanographers)

Sociedad Atlántica de Oceanógrafos
(Atlantic Society of Oceanographers)


  1. Bringing Back the Fish: An Evaluation of U.S. Fisheries Rebuilding Under the Magnuson-Stevens Fishery Conservation and Management Act. NRDC (Natural Resources Defense Council) Report, February 2013. r:13-01-a.
  2. Proposal for a Regulation of the European Parliament and of the Council on the Common Fisheries Policy – 2011/0195 (COD) – REV 5. Brussels, 5 march 2013.
  3. Regulation (EC) No. 2371/2002 of the Cabinet dated 20 December 2002
  4. Regulation (EC) No. 2166/2005 of the Cabinet dated 20 December 2005.
  5. Report from the Commission to the European Parliament, to the Cabinet, to the Economic and Social Committee and to the Regions Committee. Application of the recovery program for European hake and nephrops. Brussels, 12 May 2011 COM(2011) 260 final.

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