July 24th, 2009

North Atlantic Producers Organization – Poland - position on reform of CFP.

North Atlantic Producers Organization – Poland - position on reform of CFP.

Introduction:

NAPO agrees with main diagnosis relating to need of reform. However NAPO does not agree that all aspects of EU fisheries can be seen in such a negative perspective.

Some positive aspects of CFP in our view are:

-streamlining of fishing activity resulting from quota SWAPS mechanism

-importance of EU catches within third countries agreements in protein supply to developing countries, as well supplying EU market.

Additional possible causes of the fact that CFP is perceived as more of the failure than success that Green Book is not placing enough emphasis on :

-lack of market policy resulting in export of processing capacity of EU. This is particularly a problem when   EU fished half products are exported , and subsequent importation of value added product into EU market takes place.

-lack of export support measures for products/catches that are strongly depended on export ( like pelagic spieces )

-lack of transparent and effective process of accountability of the work performed by The Commission and National Administrations. Lack of performance based criteria for public servants in EC in position of strategic and technical management.

- complicated and expensive public management ( on EU and Member State Level ).

- lack of real support for investments , technology and know how transfer, to countries that are parties to Third Party Agreements with EU.

-lack of market development support in context of significant EU enlargement. Exclusion of new member states from benefits of some agreements third party agreements where fishing rights access is in fact market access related.

 

NAPO would like to express it’s strong disagreement with following ideas suggested in The Green Papers:

- relative stability is one of the causes of over capacity

- value of EU fleet presence in non EU waters is questionable

 

Main concepts crucial to successful reform:

 

- Introduction of RBM system where not only fishing rights but also capacity rights and effort rights   are subject to RBM system.

- Maintenance of fishing fleet capacity ceilings and comprehensive plan for fleet reduction.

- Relative stability should remain a key principle, however it’s application should take into account     “changing world”- enlargment of EU is one of examples how picture changes.

- National quota’s should be maintained.

- Multiannual management plans with inbuilt flexibility to move quotas from one year to other.

- Increased SWAP flexibility for quotas, extended to temporary SWAPs of effort and fleet capacity 

- Comprehensive market policy including structural support for market creation in new member        states

- Transfer of responsibilities to industry should be parrallel with suitable rights and financial    measures.

- Agreements with third countries should be continued , however concrete support should be given   to parties that are engaged in on shore activity in these countries. Negotiations process of these      agreements should utilize know how that is available in the industry, while public engagement s  should be reduced to supervisory status. Supervision of these agreements should engage to much  greater extend representatives of the industry.

- EU and Member State administration should be subject to transparent and objective performance based review.

 

 

NAPO supports the concept of separating decision making process into categories of decisions and allocating them to best suited bodies for consideration. These “bodies”should be allocated with suitable means to carry out it’s work, and should participate in review of performance of EU and member stated public administration.