November 27th, 2019
Inaction to ensure sustainable fishing levels has created a situation where significant cuts in quotas and even closure of fisheries must now be considered to meet the EU’s binding 2020 deadline to end overfishing.
This is the warning from the Environmental Pillar in a submission to the Department of Marine (DAFM) to feed into Ireland’s response to a European Commission proposal to ensure that fisheries are ecologically, economically and socially sustainable. 
The Pillar – a coalition of national environmental groups – is clear that the Commission’s proposal falls short of this objective and Common Fisheries Policy (CFP) requirements to restore and maintain sustainable populations of fish stocks that must be met by 2020.
However, the EU is not on course to make the final 2020 deadline, with 41 per cent of the catch limits agreed for 2019 exceeding scientific advice. 
Research carried out by BirdWatch Ireland and other groups has shown that over the last three year, our Government has one of the worst records at driving overfishing, arguing for fishing limits to be set above scientific advice, resulting in vulnerable stocks collapsing.  
With the Total Allowable Catches (TAC) for 2020 set to be agreed at the AGRIFISH Council in December, there are only weeks to ensure fishing limits are set in line with scientific advice.
We call on the Minister Creed to now change tack and work with all parties concerned to ensure that the final Council decision is fully compliant with the requirements of the CFP.
In particular, the Pillar calls on the Government to ensure that:
1. Total catch limits are set in line with best scientific advice 
2. We commit to end overfishing by rejecting roll-over proposals in EU negotiations
3. Take precautionary approach for stocks with no scientific advice on maximum catches
4. Push for greater transparency around decision-making 
Our problem with overfishing
The industrialisation of European fisheries post-World War II has driven overfishing across the North Atlantic and the decline and collapse of many commercially important fish stocks.
This has ravaged marine habitats biodiversity, fundamentally altered the balance within marine food webs, and aided the collapse of breeding colonies of seabirds who can’t find enough food to feed their hungry chicks.  
Overfishing has also driven a nail, year by year, into the coffin of our coastal fishing communities as vessels chase fish populations that are dropping by the year.
Recognition of the dire situation led to the reform of the CFP under the watch of the Irish EU Presidency in 2013, with the EU committing to end overfishing by 2015 – now missed – by setting fishing limits at or below the levels set out by the best scientific advice.
While progress has been made to improve the numbers of some commercially important stocks, we are slow and even going backwards in some places as states refuse to reduce fishing pressures despite the obvious benefits of medium to long-term sustainability and profit.
By listening to the science and rebuilding our fish stocks we could provide Ireland with an additional 200,000 tonnes of fish landings annually. This would generate an additional €270 million in earnings potentially supporting 2,200 new jobs. 
Environmental Pillar spokesperson and submission author, Fintan Kelly, said:
“Over the last six years, environmental groups have constantly reminded our Government that we need to make incremental progress year-on-year to reduce fishing pressure on all harvested stocks.
“This is vital, not just to restore healthy and profitable fisheries, but also very importantly to ensure that we comply with the EU’s Common Fisheries’ Policy.
“Poor decision making to date, driven by an obsession with short-term profits, has created a situation where we need to make deep cuts in quota numbers in order to stand a chance of complying with our EU commitments.
“This is deeply frustrating as this situation was both foreseeable and preventable. The state of numerous stocks is so bad that the closure of entire fisheries must now be considered, something that would hit the fishing community hard.
“Going into this year’s critical negotiations, we hope that our voices will be heard and that the pressure of meeting EU targets will rest firmly on the shoulders of Minister Creed who must start making difficult decisions to rebuild stocks, instead of fighting to maintain the status quo.”
 European Commission (2019) Council Regulation fixing for 2020 the fishing opportunities for certain fish stocks and groups of fish stocks, applicable in Union waters and, for Union fishing vessels, in certain non-Union waters. See the Environmental Pillar submission here: https://tinyurl.com/skgflg2
 Article 2 of the Common Fisheries Policy Regulation requires that “In order to reach the objective of progressively restoring and maintaining populations of fish stocks above biomass levels capable of producing maximum sustainable yield, the maximum sustainable yield exploitation rate shall be achieved by 2015 where possible and on a progressive, incremental basis at the latest by 2020 for all stocks.”
 This year the fishing limits some around 40% of stocks are above scientific advice. 35% are outside safe biological limits. In the Baltic Sea and Celtic Sea progress has even gone backwards in recent years.
 See the following for analysis of Ireland’s position. PEW (2019) Analysis of Fisheries Council agreement on fishing opportunities in the north-east Atlantic for 2019; NEF (2018) Landing The Blame: Overfishing in the Atlantic; Client Earth (2019) Taking stock – are TACs set to achieve MSY?
 EU Ombudsman (2019) Recommendation in case 640/2019/FP on the transparency of the Council of the EU’s decision-making process leading to the adoption of annual regulations setting fishing quotas: https://www.ombudsman.europa.eu/en/recommendation/en/120761
 For specific details on individual species, see the Environmental Pillar submission here https://tinyurl.com/rzrrdas
 A lack of transparency around decision making hinders accountability and facilitates poor decision making. Issues around the transparency of the December Council’s decision-making process was recently subject to an inquiry by the EU Ombudsman who recommended that the Council proactively make documents available when they are circulated to Member States or as soon as possible thereafter
 Christensen et al. 2003. 100‐year decline of North Atlantic predatory fishes. Fish and fisheries
 Cook A.S.C.P., et al., 2014b. Indicators of seabird reproductive performance demonstrate the impact of commercial fisheries on seabird populations in the North Sea. Ecological Indicators
 NEF (2017) A Fair Fishing Deal for Ireland – How to Manage Irish Fisheries in the Public Interest http://bit.ly/2zpe4NY