The protocol of the Sustainable Fisheries Partnership Agreement (SFPA) between the European Union and Senegal will expire in November 2024.
This agreement has caused a considerable buzz in the European and Senegalese media, who are linking it to the depletion of fisheries resources and youth unemployment in Senegal. What is the reality of the situation, and what is at stake in the forthcoming negotiations for Senegal's artisanal fisheries sector?
At a time when the European Commission has launched the evaluation procedure and is preparing to start negotiations, we have sent a contribution, co-signed with 8 other civil society and environmental organisations. In it, we highlight the most important points to be taken into account for the renewal of the protocol, to ensure that the agreement has a positive impact for artisanal coastal fishing communities. These are mainly issues of transparency, but also access and the lack of scientific data, and finally the importance of stakeholder participation.
Transparency issues
A) TRANSPARENCY IS LONG OVERDUE
The recent study on fisheries agreements published by the European Commission emphasises that most SFPA now contain a clause requiring the parties to be more transparent. The only exception is the agreement with Senegal, where there is no such clause at all. Yet this clause is "essential to ensure the provision of relevant information to support the scientific analysis, in particular that required to assess the surplus."
This lack of transparency can be seen not only in the fisheries agreement, but also generally in the management of the allocation of fishing licences in Senegal. At the beginning of August 2023, the Conseil interprofessionnel de la pêche artisanale du Sénégal (CONIPAS) denounced the lack of transparency in the allocation of licences to foreign vessels.
Despite the mobilisation of civil society and small-scale fishing organisations, and despite the Senegalese government's commitments to implement the fisheries transparency initiative (FiTI), there is still no transparency with regard to the total fishing effort in Senegal, and this in a context of "scarcity of fish, which is pushing a large number of Senegalese fishermen and young people to take to the sea to go to Europe in search of a better future."
THE EU MUST DO MORE TO PROMOTE TRANSPARENCY
It is absolutely essential that the new protocol between the EU and Senegal includes a strong transparency clause to ensure that the overall fishing effort is known - who is fishing where, under what conditions - and that the detailed use of sectoral support funds is known to all (see point 3). In order to promote sustainability, good governance, transparency and participation, it is also essential that stakeholders, in particular representatives of the artisanal fisheries sector, are adequately informed and consulted throughout the implementation of the agreement, including through participation in meetings of the Joint Committee of the EU-Senegal Sustainable Fisheries Partnership Agreement.
B) OPAQUE JOINT VENTURES
The 2014 agreement promotes the creation of joint ventures in the fisheries sector (see article 10.3). At that time, the Association pour la promotion et la responsabilisation des acteurs de la pêche artisanale maritime (APRAPAM) and CAPE had warned that "the joint ventures that exist in Senegal today operate in a highly opaque manner. This is certainly not a model for us!"
In the decade that followed, Senegalese civil society raised its voice several times against the government's plans to allocate licences on the sly to Turkish and Chinese vessels reflagged to Senegal. But it's not just vessels from other distant fishing nations that are taking advantage of this opacity. In October 2021, CFFA sounded the alarm about vessels from the Senegalese company SOPERKA, belonging to GRUPO PEREIRA (Spain), which were trawling Liberian waters with an experimental (exploratory) fishing licence, under cover of the Senegal-Liberia fisheries agreement. These operations, on the seabed "at a depth of 400 to 600 metres, [where] there is a fragile environment made up of coral and sponges", provided access to a species with a high commercial value, carabineros, the largest shrimp in the world, sold for up to €80/kg. These catches, landed at the port of Dakar without any controls, also avoided Liberian export tax. Wasn't this experimental "plundering" in the proper sense of the word?
The African confederation of artisanal fisheries organisations (CAOPA) has long been raising awareness of the opacity of joint ventures in the fishing industry. It is calling for a framework to be defined to ensure that they "operate transparently, do not compete with local artisanal fisheries, and are in line with the objectives of sustainable development of fisheries in the third country concerned."
THE EU MUST INITIATE A DIALOGUE ON A SUSTAINABLE FRAMEWORK FOR Fisheries JOINT VENTURES
Within the framework of the EU-Senegal partnership, and more broadly, within the framework of the SFPAs with African countries, a reflection must be carried out on how to make joint ventures transparent, without having a negative impact on coastal communities or the fisheries resources and ecosystems of Senegal or any other country in the region.
2. Access issues
A) A SURPLUS CALCULATED USING 2016 DATA
Black hake is a demersal species that Senegal shares with Morocco, Mauritania and the Gambia. The most recent report by the Fishery Committee for the Eastern Central Atlantic (CECAF, December 2019) indicated overexploitation: in 2018, almost 22,000 tonnes were fished in the sub-region (see table 2.4.3.a, p. 278), "an excess of fishing effort of 24% compared to the MSY objective based on data available up to and including 2016." The report also notes that after 2015, "catches increased considerably with the resumption of activity by European and Senegalese trawlers" (p. 21).
A joint position by Senegalese and Mauritanian artisanal fishing organisations in 2019 also highlighted the problem in Mauritania of "by-catches of hake by other demersal and pelagic fishing vessels reaching or even exceeding the targeted catches of hake". In addition, they were astonished that 2 Spanish hake vessels had access to Senegal under the label of "experimental fishery" (see p. 37 of the 2019 evaluation) when "several trawlers of Spanish origin (reflagged to Senegal) have been active in this fishery for several years" and that CECAF was recommending a reduction in catches. They noted that "in view of the existing data, it seems unlikely that there is a surplus that can be attributed to European vessels" and called on the EU to put in place "a strategy to promote sustainable exploitation of this resource."
Even the 2019 retrospective and prospective evaluation of the Protocol concluded that "the relevance of the Protocol to CECAF's recommendations has weakened in the light of new scientific information published in 2018" (p. 77). It nevertheless suggested keeping hake in the agreement rather than moving to a tuna-only agreement, highlighting the "added value" that the EU could bring, with "greater leverage to improve the management of the sub-regional stock of black hake" (p. 89).
Five years on, nothing seems to have changed. The latest report of the annual meeting of the Joint Scientific Committee (JSC) on the SFPA in January 2023 notes that: "As regards scientific data from scientific observers [on board hake fleets, ed. ], there are no new ones, therefore, the JSC can only refer to its recommendations [of 2018, based on the CECAF data of 2016, ed] [...] [i.e.], the improvement of the collection of data from scientific observers and in particular the transmission of available data to the scientific institutes concerned (CRODT and IEO), as soon as possible."
At present, therefore, there is still no scientific data to demonstrate the existence of a surplus, while the scant information available points to overexploitation of the resource. Under the Common Fisheries Policy, the EU is only allowed to fish the surplus resources identified on the basis of the best scientific data available. As far as we know, these resources are overexploited and hake trawlers are competing with local artisanal fishing both in terms of seasonal hake fishing in Kayar and, more generally, with regard to by-catches from this fishery that are targeted by artisanal fishing. There is no reason to retain access to hake in a future protocol.
The argument that access to an overexploited species provides a lever for the EU to promote its sustainable management is irrelevant. Within the framework of a partnership for sustainable fisheries, the EU has every opportunity to raise issues concerning resources to which it does not have access. In 2017, the EU supported Liberian artisanal fishermen in protecting their reserved area from pressure from foreign trawlers, even though the agreement between the EU and Liberia was solely for tuna.
THE EU MUST SUPPORT THE COLLECTION OF SCIENTIFIC DATA
It is crucial that CRODT is given the resources to collect the scientific data needed for a proper assessment of the surplus. The EU should also encourage regional management of shared stocks (see point 2C).
B) OUTDATED ALLOCATION SYSTEMS AT ICCAT
The EU-Senegal agreement is essentially a tuna agreement and quotas for the main commercial species of tuna are allocated by the International Commission for the Conservation of Atlantic Tunas (ICCAT). Under the SFPA, "the EU [...] simply pays Senegal a right of entry into its waters” and that is “why the compensation for a tuna agreement is lower than for a 'mixed' agreement."
Since the protocol was signed in 2020, the European and Senegalese media have accused European vessels of overfishing the species targeted by Senegalese artisanal fishermen, thereby driving them into unemployment and illegal immigration. In response, CAOPA asked the African media "to ask the right questions," in particular why Senegal was not developing its tuna fishery, and called on Senegal to submit an "ambitious plan for the development of a Senegalese tuna fleet to ICCAT". It also asked the EU to encourage "reflection at regional level on the development of a small-scale tuna fishery [...] and the submission by Senegal, at ICCAT level, of plans for the sustainable development of such a fishery."
THE EU MUST SUPPORT FAIRER ALLOCATION SYSTEMS
The Common Fisheries Policy provides for priority access to be given to those who fish in the most responsible and selective manner. Within tuna Regional Fisheries Management Organisations (RFMOs) such as IOTC and ICCAT, the EU should be consistent and advocate for access allocation systems that give priority to those fishermen who fish in the most sustainable way and bring the most social and economic benefits to the developing coastal countries that are members of these RFMOs.
C) SMALL PELAGICS: A DEARTH OF POLITICAL WILL
The fishing of certain species of small pelagic fish is a source of employment and income for the populations of the West African coast, particularly in Senegal, and in particular for the women who process it, smoke it and market it throughout the region. These fish also provide proteins, vitamins and amino acids, essential nutrients for food security. However, several species of small pelagic fish, notably round and flat sardinella, and ethmalose, continue to be overexploited, especially as a result of fishmeal and fish oil production, the number of factories having increased exponentially in the last decade.
A recent report, funded by the European programme PESCAO, noted that the per capita availability of small pelagics had fallen from around 16kg/year to 9kg between 2009 and 2018. Admittedly, population growth has to be taken into account, but other data show a decline in small-scale fish processing in the face of an increase in fishmeal production - in Senegal alone (see adjacent). At regional level, the problem is even more serious, with more than 25 fishmeal and fishoil factories in operation in Mauritania.
To restore round and flat sardinella to a reasonable level of exploitation, CECAF recommended a 50% reduction in the number of catches (p. 6). European fleets have not had access to small pelagics in Senegal for several protocols. In Mauritania, their access is limited to 15 nm, and is conditional on Mauritania adopting a management plan. Nevertheless, the opinion of the EU-Mauritania SFPA Joint Scientific Committee in June 2022 was that "the current version of the draft Small Pelagic Fisheries Management Plan (PAP-PP) is a voluminous and not very elaborate document, but it contains a lot of scientific information drawn mainly from the bibliography."
As the European Parliament has pointed out, the European Commission has sufficient leverage through its various partnership agreements in West Africa to encourage regional management of fisheries resources. For several years now, West African civil society has been calling on the EU to step up its commitment to regional management by setting up a Regional Fisheries Management Organisation for stocks shared by the countries in the region. This request has been echoed by stakeholders of the European long distant water fishing. A study by COMHAFAT deemed this RFMO "indispensable". Despite the cumbersome nature of the undertaking, the Commission is still betting on transforming CECAF into an RFMO. An undertaking that seems to be making little headway...
THE EU MUST COMMIT POLITICALLY AND TECHNICALLY TO SUPPORT REGIONAL MANAGEMENT OF SMALL PELAGICS
While the increased attention of the EU, especially the European Parliament, to the overexploitation of small pelagics in West Africa is to be welcomed, the question also arises as to what additional support the EU could provide for the regional management of these species, in particular through the creation of an RFMO. This is a request from European stakeholders and local civil society organisations.
3. Sectoral support issues
A) GOOD INTENTIONS...
At an event at the European Parliament with small-scale fisheries representatives in May 2023, MEP Caroline Roose stated the following with regard to sectoral support: "Some EU-funded projects start out with good intentions but in practice are not necessarily adapted to or do not benefit small-scale fisheries". She gave as an example the landing quay and refrigerated container she had visited in Senegal, which did not satisfy the beneficiaries. Moreover, the communities benefiting from these projects are generally not aware that they are funded by the EU, as the SFPA evaluation published by the Commission also points out.
The main problem is the lack of transparency in the allocation and use of sectoral support funds. Not only that, but the countries' annual reports to the European Union are not made public. It is clear that without stakeholder participation, top-down decisions on sectoral support projects will have neither the approval of communities nor the hoped-for impact.
Civil society organisations and the Senegalese artisanal fishing sector are calling for transparent and participatory mechanisms to be put in place to ensure transparency, proper use and accountability in the way sectoral support is spent. The impact of this sectoral support should also be evaluated.
B) ...BUT MIXED RESULTS
As local communities and artisanal fishing organisations have been pointing out for some time, Senegal's only research vessel, the Itaf Deme, refurbished with funds from sectoral support, is an obsolete vessel that does not meet current needs. What's more, the vessel, which is over two decades old, has not operated since 2022 following a breakdown. CRODT has reportedly submitted a report to the government proposing that the vessel be replaced.
TRANSPARENCY, PARTICIPATION AND THE INFORMATION OF STAKEHOLDERS
Beneficiaries, in particular small-scale fishing communities, must be included in identifying priorities for the use of sectoral support, as well as being involved in implementation and evaluation.
Conclusion
At a time when opaque joint ventures are flourishing in Senegal and fisheries resources are becoming scarce, we believe that the best framework for European fleets is the SFPA, provided that the EU respects its own international commitments on sustainability, allocation criteria and transparency.
To this end, the EU must demand the inclusion of a transparency clause in the next protocol and its effective implementation. Local stakeholders are also calling on Senegal to honour its own commitments in terms of transparency, in particular by publishing the list of licensed vessels and the content of its fishing agreements.
On the other hand, it is essential to invest massively, in a coordinated way at regional level, in research, in particular data collection, so that a substantiated scientific opinion can be given with regard to stocks shared between West African countries, such as black hake or small pelagics. It is unacceptable for a surplus to be calculated on the basis of data that is 8 years old, as in the case of black hake.
In addition to technical and scientific support, the EU should also use its partnerships with the countries in the region as a lever and commit itself politically to setting up an RFMO for shared stocks. As part of this drive for coherence and sustainability, the EU should transpose its own criteria for allocating fisheries resources, prioritising those who fish in the most sustainable way, to ICCAT.
"The European Union must be credible and demonstrate that European taxpayers' money is being spent wisely to support sustainable fishing," Harouna Lebaye, a small-scale fisherman from Mauritania, stressed at the European Parliament last May, calling for the publication of reports on the use of sectoral support. For this agreement to be an effective instrument for promoting sustainable fishing in Senegal, the informed participation of stakeholders is essential, especially the men and women in Senegal's artisanal fisheries. This participation must be genuine, both in the negotiations and in the implementation of the agreement, in particular the identification of priorities for sectoral support, its implementation and its evaluation. But to ensure informed participation, we need greater transparency. We need transparency at all levels.
Banner photo: The artisanal fish landing and processing site in Kafountine, Casamance, Senegal, by Agence Mediaprod.