ClientEarth's response to the Commission's communication concerning a consultation on fishing opportunities for 2017 under the CFP

ClientEarth critiques the European Commission's 2017 fishing opportunity proposals, asserting that using FMSY point values as targets rather than limits fails to meet the legal requirement to maintain fish populations 'above' levels capable of producing MSY. The organization highlights a decline in stocks within safe biological limits between 2013 and 2014 and criticizes the Commission's Article 50 report for being misleading and lacking data on biomass levels. Furthermore, ClientEarth warns that quota top-ups for the landing obligation could increase fishing mortality if not strictly based on validated discard data. The response calls for clearer quantitative criteria for socio-economic derogations and a more transparent, comprehensive reporting framework for the landing obligation.

• The European Commission's intention to use FMSY point values for 2017 Total Allowable Catches (TACs) is legally insufficient because Article 2(2) of the Basic Regulation requires populations to be maintained 'above' levels capable of producing MSY. Fishing exactly at FMSY would only result in biomass being above the required level 50% of the time.
• Recent data indicates a regression in stock health, with the number of stocks within safe biological limits falling from 22 to 20, and those where fishing mortality does not exceed FMSY decreasing from 35 to 31 between 2013 and 2014.
• The state of fish stocks in the Mediterranean Sea is described as 'dire', with overall overfishing levels estimated to be between 2 and 3 times the FMSY.
• ClientEarth argues that the Commission's Article 50 report is misleading because it suggests progress continued in 2014, whereas corrected STECF analysis shows a decrease in the percentage of stocks fished in line with MSY compared to 2013.
• There is a lack of quantitative clarity regarding the 'exceptional cases' where socio-economic reasons can justify delaying MSY achievement. ClientEarth notes the Commission has not defined what constitutes a 'very large' reduction in fishing opportunities or what 'seriously jeopardise' means in a quantitative sense.
• The use of FMSY ranges in the Baltic multiannual plan is criticized for potentially allowing TACs to be set above the FMSY point value, which risks jeopardizing the MSY objective.
• The reporting on the implementation of the landing obligation is deemed inadequate due to a reliance on general statements and a lack of quantitative data, specifically regarding catch profiles, compliance, and the uptake of exemptions.

APA

ClientEarth (2016). ClientEarth's response to the Commission's communication concerning a consultation on fishing opportunities for 2017 under the CFP. https://www.clientearth.org/media/wyvaboqi/clientearth-response-to-the-commission-s-consultation-on-fishing-opportunities-for-2017.pdf

Chicago

ClientEarth. ClientEarth's response to the Commission's communication concerning a consultation on fishing opportunities for 2017 under the CFP. 2016. https://www.clientearth.org/media/wyvaboqi/clientearth-response-to-the-commission-s-consultation-on-fishing-opportunities-for-2017.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=ClientEarth's response to the Commission's communication concerning a consultation on fishing opportunities for 2017 under the CFP |date=August 2016 |url=https://www.clientearth.org/media/wyvaboqi/clientearth-response-to-the-commission-s-consultation-on-fishing-opportunities-for-2017.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2016clientearths, author = {{ClientEarth}}, title = {{ClientEarth's response to the Commission's communication concerning a consultation on fishing opportunities for 2017 under the CFP}}, publisher = {ClientEarth}, year = {2016}, month = aug, url = {https://www.clientearth.org/media/wyvaboqi/clientearth-response-to-the-commission-s-consultation-on-fishing-opportunities-for-2017.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }