Tuesday 11th February 2020

BSAC/2019_2020/22

Commission Questionnaire from DG Mare Implementation of PRF and SUP Directives in EU ports.

BSAC Secretariat note

On 18th February 2020 in Brussels DG Mare is holding its Workshop on the implementation of the Ports Reception Facilities and Single Use Plastics Directives in European ports

In advance of the meeting it sent a stakeholder survey with the aim of gathering input on key topics relating to the two directives.

The BSAC Secretariat has invited fisheries representaives of the Executive Committee to reply to the questionnaire and it has collated the answers.

The compilation of answers is below.

This is sent to DG Mare in advance of the Workshop, for use at the workshop or after the workshop.

Denmark The Danish Fishermen PO Answers to this questionnaire provide general Baltic fishermen’s experience in the following ports for the Baltic: Nexø, Rønne, Hasle, Gilleleje, Rødvig, Køge, Klintholm, Stubbehøj, Bagenkop, Gedser, Rødby Havn, Kerteminde, , Østerbro, Sletten and Vedbæk. There are adequate facilities to unload waste fishing gear and passively fished waste. Can highlight: convenient location of garbage bins in the ports, availability of garbage unloading equipment (e.g. cranes), support from port/waste management personnel and separate bins. The above facilities vary from port to port, so here are a few additional comments: • The location of garbage bins is not always convenient and could be better in some ports.

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• Generally, the personnel are helpful, and it is easy for fishermen to leave end-of-life fishing gear at the dockside, and it will be removed by the management personnel. • Separate bins are available for paints, oils and galley waste. However, there are no different or separate bins for fishermen to sort other waste such as their galley waste. Room onboard the vessels and the time to do this sorting are often limited for further waste management at sea. So, if further differentiation of waste from fishing vessels is necessary, it should be handled by the management personnel as they are responsible for the waste handling after landing – this is a service that is already included in the vessels port fee. It should also be mentioned that in general, capacity in the ports in question is thought to be sufficient; this may be because the fleet numbers in these ports have been reduced a lot. Some smaller ports might only have a part-time employee, so if further waste management is necessary, the capacity for this might not be enough. The waste managed separately in the ports is: operational waste, end of life fishing gear, ghost gear and passively fished waste. The amounts of waste are not weighed or counted or reported. However, in general, metal is weighed, as this is something the ports can actually get money for. The fisheries sector has for a long time been asking for more information on the amounts of waste in ports. This is because Danish fishermen have been cleaning the ocean for passively fished waste for nearly a decade. Of the ports mentioned above, it has been free of charge for fishermen to land this for the past 8-10 years. So, there is no fee for delivering waste to the ports. It was removed in the ports in question 8-10 years ago, and since then, fishermen generally bring ALL fished waste to port. There are no facilities for processing end of life fishing/ghost gear, such as dismantling and cleaning of the gear. Comment: By putting a “/” between end of life fishing gear and ghost gear in the question could imply that these (end of life gear and ghost gear) are the same. As these are not generally the same, linking them together does not generate a responsible rhetoric on the subject or help to provide an insight into the issue or possible actions to address the real source of plastics in our oceans. So, a clear distinction should be made between end of life gear and ghost fishing gear. Different waste, different waste streams, for example a lot of end of life fishing gear in goes to Plastix, , which recycles the gears. For general waste, it’s assumed that it’s managed through the local municipality, but this question should be put to the ports themselves. General comments: From the fishermen’s perspective of the DFPO, it is really crucial that: • the garbage bins are conveniently located and should be clearly signed and be very visible,

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• no further waste management onboard than what is carried out at present should be required from the fishermen, because space and time constraints at sea make this difficult and, in some cases, impossible – and fishermen pay for waste service in their port fees, • it continues to be free for fishermen to deliver the passively fished waste in ports • it should continue to be a good practice and service for the fishermen to be able to place end of life fishing gears and possible passively fished lost and/or ghost gear at the dockside, and for the port management personnel to remove this. This is a recommended best practice. For the workshop on 18th February 2020, an important topic to raise is that: Data on passively fished waste and lost and/or ghost gear should be gathered continuously by the ports.

Denmark The Association for Low Impact Coastal Fishery Are operating in Jutland and from the Danish islands. There are adequate facilities for unloading fishing gear, by way of convenient location of garbage bins in the ports and support from port/waste management personnel. All types of waste are managed separately in the ports they operate in. The amounts of waste are weighed/counted/reported in bulk. There is a fee for the delivery of waste fishing gear and passively fished waste in the port(s) they are operating in. And there are facilities offered at the port they are operating in for processing end of life fishing/ghost gear. Waste, nets, plastic etc. reduce the ability of all kinds of fishing gear to catch fish, which is why it’s always brought to the harbour.

Estonia Estonian Fishermen's Association All the ports in Estonia have big waste containers, where the operational waste can be unloaded Ports do not have any special collection of old fishing gear All companies must handle their gear themselves All fishing companies have storage facilities where the old gear is collected After a while, the old gear is sent for recycling (Nofir (nofir.no) etc.) They have even caught a Volkswagen Golf in the trawl from the sea and have brought it to the shore To sum up: all operational waste is collected in the port, everything else (old fishing gear, old lubricants etc.) is the responsibility of the fishing companies

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Finland Finnish Fishermen's Association (FFA) Providing some background from Finland. Mr Pekka Kotilainen, Finnish Environment Institute, SYKE, presented their project: Retrieval, reception and handling of ghost nets in the Western coast of Finland at the Clean Nordic Oceans Final Conference 21st-22nd November 2019. Part of that work (of which the Finnish Fishermen’s Organisation representative Markku Saiha is a member) is to try to establish how much fishing gear is in the harbours etc. During that they have found out that they have no recycling instructions with respect to fishing gear, so all is just treated as waste. Markku Saiha has prepared a draft to demonstrate what could be done in the fishing harbour; that paper is now part of preparation work towards national rules in Finland. So, the process has begun, but the timetable had not been established. Thus, for the time being, there are no instructions on how to deal with the fishing gear in harbours, other than to put it in the rubbish bin. FFA supports this questionnaire as a very good to start to evaluate the entire EU situation. The questionnaire should at the start explain what the requirements are of the PRF and SUP Directives, and what is meant by “adequate facilities” etc. One example in Finland is lead: it is considered as dangerous waste, but how to deal with it should be explained first, in order to write an answer. The same applies to most of the questions …

To some of the questions from the questionnaire, please see below as track changes comments and clarification provided by leading Finnish expert Helena Dahlbo (Helena Dahlbo, Senior Research Scientist, D.Sc. (Tech.) / Center for Sustainable Consumption and Production / Finnish Environment Institute SYKE). These suggestions are here: Under Collection of waste in the port Are the amounts of waste weighed/counted/reported? Please specify what and how [waste] is weighed/counted/recorded and to whom it is reported? Are there any facilities offered at the port you are operating in for processing end of life fishing/ghost gear, such as dismantling, sorting and cleaning of the gear? Who performs these operations?

Under Post port waste management Is there co-operation between ports in the organisation of waste management? Who/what is responsible for keeping the co-operation working? How are the different waste materials treated? Recovered as material or as energy?

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Finland Federation of Finnish Fisheries Associations No specific comments provided to the above answers from the FFA.

Germany German Cutter-and Coastal-Fishermen’s Association Fischereigenossenschaft Fehmarn eG (producer association)/ Fischverwertung Lübecker Bucht eG (producer association) The companies organized by them fish exclusively in the Baltic Sea. The main fishing area is sub-division 22, with a small percentage of fishing trips to SD 24, when fishing is allowed! The fishermen of Fischergenossenschaft Fehmarn eG operate from the port of Burgstaaken on Fehmarn, the fishermen of Fischverwertung Lübecker Bucht operate from the ports of Lübeck-Travemünde and Niendorf Ostsee. Herring fishing can be regarded as an exception. With a few isolated exceptions, it takes place in SD 24. Here the members operate from the port of Sassnitz on Rügen. Germany's only herring processing facility (Euro Baltic) is located there. On port reception facilities: Yes, there are appropriate facilities in our ports where their fishermen can dispose of their waste. This is done in accordance with the disposal guidelines applicable in Germany (separation of household waste, paper and plastic). Their fishermen have two possibilities for the disposal of nets or other fishing material: as a cooperative they usually organize one or more containers twice a year into which the corresponding material can be disposed of. The respective cooperative pays the costs. As a further (only fished up objects) disposal possibility, containers of the project fishing4litter are permanently available in the ports of Burgstaaken and Niendorf. The project https://www.nabu.de/natur-und-landschaft/aktionen-und-projekte/meere-ohne- plastik/fishing-for-litter/index.html) was initiated in cooperation with the nature conservation organization NABU and the local fishery. The project has already been running on Fehmarn since 2011. Collection of waste in the port: Operational waste and end of life fishing gear are managed separately in the port(s): The amounts of waste are not weighed/counted/reported. The disposal of all waste is free for the fishermen. The costs are paid by the associated cooperative. No statistics are kept on the quantities disposed of. The waste, which is disposed of through the project fishing4litter, is taken over by a local waste management company (ZVO Ostholstein), which also participates in the project as a partner. Facilities are offered at the port for processing end of life fishing/ghost gear, such as dismantling and cleaning of the gear.

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On good practices: to share experience concerning the collection of waste and garbage in ports: it is recommended to make a contract with the local waste disposal company (s).

Germany The Union of German Cutter Fishery Questions whether it should be the responsibility of the ACs to check the responsible authorities for the implementation of port reception requirements. Others, such as local authorities, are better qualified to reply.

Germany The Association of Fisheries Protection Operating in the ports in Schleswig-Holstein Germany. Port reception facilities are adequate, with convenient location of garbage bins in the ports and separate bins for different waste types. But sometimes the space available is poor. Operational waste is managed separately in the ports. The amounts of waste are not weighed/counted/reported. There is no fee for the delivery of waste fishing gear and passively fished waste. There are no facilities offered at the port for processing end of life fishing/ghost gear. The waste company comes periodically to collect the waste. Understands that in German ports the collection of waste is included in the yearly fee paid in order for the vessel to use the harbour. In the gillnet fishery a recycling of ropes and lead lines has been in force for years because they can be used for a second life. This means both saving money and avoiding unnecessary waste. Thinks that the loss of gillnets is exaggerated by NGOs. The loss of trawls, in particular of rock hopper gears, occurs. The same problem is close to wrecks because there is an expectation to catch an increasing amount of fish. Latvia Latvian Fisheries Association Operating in the ports of Ventspils, Liepaja and Skulte Port reception facilities are adequate, with convenient location of garbage bins in the ports and availability of garbage unloading equipment (e.g. cranes) and depending on where in the ports. Waste managed separately is: operational waste, end of life fishing gear and ghost gear. The amounts of waste are weighed/counted/reported as per separate waste type. Companies engaged in waste collection in ports must submit quarterly reports to the State Environmental Service on the ship-generated waste that is collected. A fee is charged on waste fishing gear and on passively fished waste. Each port has rules on the charge for waste disposal. In some ports, the charge for waste transfer is included in the total port costs. In Ventspils, fishing vessel companies pay 0,04 EUR per 1 GT. There are no facilities for processing end of life fishing/ghost gear. In the ports there are special containers where waste is collected. It depends on the waste managing companies how often waste is taken to the facilities which are not in the ports. Plastic waste management should be developed in the ports. Fishermen are interested in collecting plastic waste and delivering it to the ports.

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To be considered at the Workshop on 18th February 2020: collection of and disposal of plastic waste in the ports.

Lithuania Confederation of Fisherman and Fish Processors of West Lithuania Operating in the Danish port of Skagen and in the Baltic ports of Ventspils, Liepaja and Klaipeda. Port reception facilities are adequate in Skagen, with convenient location of garbage bins in the ports. Facilities are not adequate in Ventspils, Liepaja and Klaipeda. The following types of waste are managed separately in the port(s) operated in: operational waste, end of life fishing gear and passively fished waste. The amounts of waste are not weighed/counted/reported. There is no fee for the delivery of waste fishing gear and passively fished waste. Facilities offered at the port processing end of life fishing/ghost gear, such as dismantling and cleaning of the gear are not applicable.

Poland National Chamber of Fish Producers The facilities that are available depends on the species and quantity of fish, but the following harbours are availalbe for unloading: Swinoujscie, Dziwnow, Kolobrzeg, Darlowo, Ustka, Leba, Wladyslawowo, Hel. There are some boxes provided by the harbour authority for waste; this is a question for the harbour authorities to answer. Waste fishing gear should be delivered first to places where they can be disassembled and divided according to different material. There are facilities in some harbours which are able to divide the gear into different pieces/materials. The followng waste is managed sepearately in the ports: operational waste, end of life fishing gear, ghost gear and passively fished waste. An example of good practices: Their PO has an agreement with an external company which is authorised to utilize the plastic parts of the fishing gear. Other parts made of steel are collected by people which deliver that to steelworks. There is no specific fee for the delivery of waste fishing gear and passively fished waste in the port(s) operated in: it’s included in the harbour fee. What topics could be brought up at the meeting on 18th February: Discussion about logistical matters such as collection and division of waste into different materials which can be ready for suitable utilization for specific purposes. Poland Darlowska Group of Fish Producers and Shipowners Are operating in the port of Darlowo. There are adequate facilities to unload waste fishing gear and passively fished waste (collected during normal fishing operations) in the ports. This is because of the convenient location of garbage bins in the ports and separate bins for different types of waste. At collection of waste in the port, end of life fishing gear is managed separately in the port. The amounts of waste are not weighed/counted/reported.

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There is no fee for the delivery of waste fishing gear and passively fished waste in the port: fees for recycling are covered by the port administration. There are no facilities at the port for processing end of life fishing/ghost gear, such as dismantling and cleaning of the gear. On post port waste management: waste collection after delivery at the port is on the basis of an agreement with the port.

Sweden Swedish Pelagic Federation PO (SPF) Operating in the following Danish ports: Skagen, Hirtshals and Grenå. And Swedish ports: Kungshamn, Rönnäng, Ellös, Simrishamn, Västervik, Norrsundet, Rone hamn and Byxelkrok. Yes, there are adequate facilities to unload waste fishing gear and passively fished waste. Facilities are deemed adequate because of convenient location of garbage bins in the ports and separate bins for different waste types. The following waste is managed separately: operational waste and passively fished waste. There is no ghost gear caught in the pelagic fishery. End of life fishing gear is either disposed of at trawl binder’s (where useable parts are reused ant other parts recycled) or at general recycling facilities. They don’t know if the amounts of waste are weighed/counted/reported: this is a question for the ports/municipalities that are handling the waste in ports. Fees for delivering waste fishing gear and passively fished waste vary from port to port. Handling of waste is often either included in the port fee, or in a service fee (based on % of landings) or may be free. Facilities offered at the port processing end of life fishing/ghost gear, such as dismantling and cleaning of the gear are not applicable. This is more commonly at the trawl-binders, where parts from old trawls are reused and waste parts are recycled. Questions on post port waste management are for the ports/municipalities that are handling the waste in ports. On good practices: Many ports have good systems for leaving waste close to the vessels and sorting of waste products. Topics for the workshop on 18th February: No; This is not a problem in the pelagic fishery.

Sweden The Swedish Fishermen PO Agree mainly with the comments from the Swedish Pelagic Federation PO, that this is mainly a question for the ports (i. e. the municipalities and regional authorities for the ports). Marine litter has been discussed in Sweden for 25-30 years. The situation on the Swedish west coast is really bad: more than 80 % of the marine litter ending up on beaches in Sweden is foreign. It contains waste and debris from fisheries, but the main pollution is from plastic used on land by humans… Sweden has an excellent system of recycling most kind of wastes and the municipalities are responsible for this. Most Swedish municipalities have solved this by now.

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Sweden Fishermen's Federation for Small-Scale Fishery in Sweden Operating in Rönneby. There are not adequate facilities to unload waste fishing gear/passively fished waste. Improvement to this could be to provide separate bins for different types of waste. Questions about collection of waste in port are not applicable. There is no weighing, counting or reporting of the amounts of waste. There is no fee charged in the ports for delivery of waste gear/passively fished gear. There are no facilities offered at the port for processing end of life fishing/ghost gear, such as dismantling and cleaning of the gear. Post port waste management takes place periodically. No good practices to suggest.

Recreational One input from the recreational fishermen – Danish Recreational Fishermen

The questionnaire is directed towards the fishermen.

The need for facilities by the recreational fishermen are small: when gears are at the end of their life, they are usually dismantled and thrown away; and they re-use the parts that can be used, such as weights and floats. Are familiar with the application of extended producer responsibility (e.g. electronics, batteries, car tyres, etc). They anticipate the same thing to apply here. Think it’s up to the sector to develop and implement.

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