Baltic Sea Centre reply to EU consultation on the Communication Sustainable fishing

This submission from the Stockholm University Baltic Sea Centre focuses on conditions in the Baltic Sea. For references, see below.

This reply has been prepared by Charles Berkow, advocacy and analysis officer at Stockholm University Baltic Sea Centre, in collaboration with Baltic Sea Centre researchers Sara Söderström and Henrik Svedäng. 

 

Eels

The mismanagement of the European eel offers a clear illustration of the state of play of the common fisheries policy. 

  • The immediate economic interests of a small group of people are allowed to dominate over the conservation of our common biological heritage and the resource base some of their income depends on.
  • Scientific advice is used when it suits these interests, disregarded otherwise
  • Governments that use failures in another policy area – here, habitat destruction – to justify continued overfishing are the same governments that delay action in that very area.
  • Ineffective measures – here, closures of fisheries during periods when there has been little fishing anyway – give a false appearance of action.
     
 

MSY OBJECTIVE

The Commission’s communication presents the ”MSY objective” as fishing activity at Fmsy. This disregards the biomass objective in the CFP and MAP regulations - restore and maintain stocks above levels that can produce MSY. The STECF report, referred to by the Commission, reports on both of these objectives. Incidentally, it is impossible to fish at Fmsy for all stocks in a mixed fishery.

 
The Commission carries its misinterpretation of the CFP into its request for advice from ICES. It should request that ICES, in an executive summary, informs on whether the two MSY objectives are met, and on other important information in the body of the report. It should also indicate if the advice takes into consideration the impact of catch levels on key aspects of good environmental status under the Marine Strategy Framework Directive such as biodiversity, food webs and habitat integrity.

 
By its faulty interpretation of the MSY objective, the Commission delays progress on restoring fish stocks.

Due to inherent problems in the MSY approach as such, including the weakness of the scientific basis for making assessments and forecasts, we suggest that the MSY approach is used with a stronger precautionary buffer.
 

 

STATE OF THE FLEET, BALANCE

Efforts to achieve balance between fishing fleets and fishing opportunities are undermined by the continued subsidies for fuel, in the form of exemptions from carbon emission pricing. These subsidies also reduce incentives to decarbonise the sector and are harmful to the marine environment and sustainability of the fishing sector. Funds for decarbonisation and fleet renewal should be conditional on full carbon pricing. Better capacity indicators are needed.

 

ENVIRONMENTAL AND SOCIO-ECONOMIC OBJECTIVES

The Communication implies that the Commission will continues to disregard the environmental objectives in the CFP and MAP when making its proposals for fishing opportunities.

 
The Commission should clarify that environmental objectives are not taken into account in the proposal, but should be under the CFP, and that this would normally result in lower TACs than those proposed unless there is evidence suggesting otherwise. A further step towards a more ecosystem based fisheries management would be to differentiate between forage and predator fish.


It is difficult to untangle the relative impact of various of environmental pressures on Baltic fish stocks. The existence other environmental pressures should lead to more precautionary TACs until these pressures are reduced.

 
Socio-economic impact assessments should look beyond the coming year and highlight the longer term socio-economic consequences of rapidly restoring fish stocks.

 
Economic analyses should disaggregate the fleet into at least the small-scale coastal fleet and the large-scale mobile fleet. Employment and down-stream value for the local economy per ton fish are likely greater for the SSF than the LSF, or with fishing for direct human consumption instead of fish meal, for example in the Baltic pelagic fisheries. 
 

 

REFERENCES

European Commission DG Mare ICES: European Maritime, Fisheries and Aquaculture Fund (EMFAF). Specific Grant Agreement 4500095912 under Framework Partnership Agreement MARE/2023/ICES.  

Graham J. Edgar et al.: Stock assessment models overstate sustainability of the world’s fisheries.Science 385,860-865(2024).

Havs- och vattenmyndigheten (2024): Ekonomisk, social and ekologisk hållbarhet i Södra Bottenhavet. Rapport 2024:02.

Henrik Svedäng, Oleg Savchuk, Anna Villnäs, Alf Norkko, Bo G Gustafsson, Sofia A Wikström, Christoph Humborg: Re-thinking the “ecological envelope” of Eastern Baltic cod (Gadus morhua): conditions for productivity, reproduction, and feeding over time. ICES Journal of Marine Science, Volume 79, Issue 3, April 2022, Pages 689–708.

P. A. Larkin: An Epitaph for the Concept of Maximum Sustained Yield. Transactions of the American Fisheries Society, Volume 106, Issue 1, January 1977, Pages 1–11.

Froese, Rainer & Steiner, Noa & Papaioannou, Eva & MacNeil, Liam & Reusch, Thorsten & Scotti, Marco. (2025): Systemic failure of European fisheries management. Science (New York, N.Y.). 388. 826-828.

Scientific, Technical and Economic Committee for Fisheries (STECF): The 2024 Annual Economic Report on the EU Fishing Fleet (STECF 24-03 and 24-07), PRELLEZO, R., SABATELLA, E.C., VIRTANEN, J., TARDY MARTORELL, M. and GUILLEN, J. editor(s), Publications Office of the European Union, Luxembourg, 2024.

U. Rashid Sumaila et al.: WTO must ban harmful fisheries subsidies. Science374,544-544(2021).

Stockholm University Baltic Sea Centre (2024): För många fartyg jagar fortsatt för få fiskar. (swedish)

Stockholm University Baltic Sea Centre (2022): POLICY BRIEF: Adapt herring fisheries to scientific uncertainty.

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