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Although most NGOs have been barred from observing the informal meetings, they have been busy in the corridors. NGO comments have been tabled on the EC paper on suggested guidelines for conservation and management and international cooperation. The comments include the idea that in addition to ecosystems, the viability of the coastal fisheries and the communities that depend on them must be addressed. The right of the marine ecosystem to exist unimpaired must be the paramount consideration. The marine habitat also needs protection and monitoring. "Acceptable uncertainty" is not a criterion that can be defined for global application, since it is subject to arbitrary decision-making processes. Transparency must include public access to information. The precautionary principle is a fundamental tool for fisheries management that must be applied at all times. Part II of the paper states that the regional bodies must be nested in a global framework, both to set minimum standards and to encourage cooperation to manage highly migratory stocks throughout their geographic range. The NGOs also urged nations to move beyond UNCLOS.

NGOs have also drafted a statement on the consistency principle. For straddling and highly migratory fish stocks, a consistent conservation and management regime based on an ecosystem approach is needed. Such a regime must be applied throughout the ranges of the stock as a safeguard against over-exploitation. Any elaboration of States' rights regarding the stocks must deal with responsibility for conservation of the stocks and protection of the marine habitat.