1. Introduction

Since the adoption of the multiannual plan for the Baltic Sea in 2016 (MAP), three of the eight stocks covered by the plan have basically collapsed. A fourth stock, the central Baltic herring, has suffered a major decline with clear indications of regional severe depletions. A fifth stock, Bothnian herring, appears to be affected by a significant regional decline of large herring most attractive for human consumption.

The Commission writes that in the Baltic Sea, “the positive trend in recent years has reversed due to the dire environmental situation and past overfishing. This has led to a habitat loss for a number of fish stocks, to decreases in the amount of fish in the sea and to smaller sizes for Baltic cod and now also other Baltic stocks.” While environmental conditions are indeed an important part of the explanation of the situation, in particular for the eastern Baltic cod, the role of single species fisheries management for the development of other stocks cannot be ignored.

A key problem is an over-emphasis on trying to achieve a narrowly defined Maximum Sustainable Yield for single stocks, with little or no consideration of its environmental limitations or interrelationships. Important information is not considered, or not included, or not highlighted in the scientific advice used as the basis for decision-making.

2. Progress in achieving sustainable fishing in the EU

Included in the objectives of the CFP is to implement an ecosystem-based approach to fisheries management so as to ensure that negative impacts of fishing activities on the marine ecosystem are minimised and avoid the degradation of the environment. In particular, fisheries policy should contribute to achieving the objective of Good Environmental Status under the Marine Strategy Framework Directive (MSFD).

A natural first step towards achieving this goal would be to take consideration of predator-prey relations between commercial species when deciding on both TACs and technical measures. However, this does not appear to be the case. For example, a key explanation for the decline of the eastern Baltic cod is likely to be food quality changes.(1) This might in turn be due to a decline of the key prey species herring in areas where the cod still exist. This relationship could be taken into consideration when determining regulations TACs and spatial regulations for fishing herring.

Descriptors of Good Environmental Status in the MSFD can, in lieu of better information, serve as a proxy for ecosystem considerations. Besides commercial fish and shellfish, these include Biodiversity, Food webs and Sea-floor integrity.

During the past years and in particular this summer, the lack of large herring in the Bothnian sea has received attention. This deficit is now resulting in the closure of factories dependent on large fish suitable for production of fermented herring. In a recent document, the Swedish University of Agricultural Sciences (SLU) states that fishing according to the current MSY target often leads to a changed size structure, where the share of large fish is decreased. SLU further states that the question of the size structure of the stock is neither requested by the EU nor managed by ICES in the ongoing scientific advice despite the adoption of the MSFD in 2008. SLU concludes that the most effective way to recover a higher share of large herring in the stock is to reduce the fisheries mortality, that is, reduce TACs.(2)

Although ICES does provide some indications of some of the issues that might give a more nuanced approach than the current focus on narrowly calculated MSY, these qualifiers are often “buried in the fine print” and easy to miss by decision-makers used to focusing on the headlines. For example, the graphs showing the retrospective analyses provide some indication on the historical uncertainty of the advice. But these graphs are not clearly explained, nor are the consequences.(3) Further, when biomass measured in SSB does not increase despite catches being limited to estimated Fmsy (such as has often been the case for Bothnian herring), this indicates that something is seriously wrong in the calculations and/or the system. This is crucial information that ICES could and should highlight.

ICES advice would be more helpful for managers and contribute better to healthy fish stocks for the benefit of both the environment, the fishing sector and coastal communities if it would answer questions like:

-    What factors, that could be relevant for managers has ICES not taken into account when preparing its advice?
E.g.

o    The impact of fishing this stock on other associated commercially fished stock
o    The impact of fishing this stock on other associated species e.g. in the food web
o    The impact of fishing this stock on sea-floor integrity
o    Impacts on sub-populations or stock components, i.e. threating long lasting reductions in production level and possibly reducing biodiversity
o    Impacts on the age and size structure of the stock, i.e less valuable catches, changes in ecosystem function, possible evolutionary responses
o    If the condition of the stock seems to be improving or declining
o    The consequences of the dominance of a relatively strong year class, and the impact of fishing it or leaving it in the water
o    Uncertainties due to with the quality of the data, e.g. misreporting of species or of stocks (i.e. if herring caught on a particular voyage is caught in the Bothnian Sea, or the Central Baltic)
o    Signs of density dependence resulting in impaired growth rates
o    The general degree of uncertainty in the assessment, e.g. due to changing environmental factors or evidenced by SSB not increasing despite fishing at or below estimated Fmsy.

-    For each factor, would consideration of this factor be likely to lead to a higher or lower TAC than basing a TAC proposal on the current standard calculation of Fmsy and not taking this factor into consideration?

With the exception of density dependence, each of these factors, if given adequate consideration, would likely result in lower removals of fish. Failure to consider such factors, together with an effort to achieve maximum sustainable yield is very risky approach, likely to lead to overshoot. It can take years to rebuild a stock after depletion. Giving adequate consideration to uncertainty would lead to lower catch rates.

It should be feasible for ICES to provide the information mentioned above in a transparent and clear manner. This can in turn help to correct the misguided impression that some decision-makers seem to have, that simply following the ICES headline advice on TACs will lead to sustainable fishing. It would thereby improve the potential for achieving the objectives of the CFP and reduce the risks for negative spirals such as have been experienced in the Baltic since the adoption of the MAP.

The Commission should consider requesting ICES to provide such information. This would be a way of approaching the target of fishing at 50% of MSY as proposed by e.g. Sidney Holt during the preparation of the Baltic MAP.(4)

3. State of the EU fleet

In section 3, the commission describes the situation regarding overcapacity and the action plans Member States are to adopt to deal with it. At the same time, as the Commission highlights in section 3, Member States have not been willing or able enough to deal with the problem.

The current measures of capacity, gross tonnage and engine power, in all probability give an overly optimistic view of the situation. They do not take into consideration “technological creep”, the incremental increase in the actual capacity to catch fish due to technical innovations. The Commission has previously estimated this as about 2-3 per cent per year on average. This may be even more in segments where there is considerable new investment in more modern, efficient and effective vessels. Measures of capacity need to be updated.

Further, the national level, or an aggregation of national reports, are not necessarily adequate to assess overcapacity in a region such as the Baltic Sea. Regional considerations should be included in the estimation of fleet capacity, ensuring a viable basis for regional fisheries. 

The Commission could be more active in using the tools at its disposal (such as reporting guidelines). It is also urgently important to come to terms with counterproductive policies such as harmful subsidies on fuel.

4. Economic performance and harmful fuel subsidies

Capacity-enhancing subsidies counteract efforts to come to terms with overcapacity. They are harmful when they help a fishing fleet or a vessel catch more fish and reach a better financial result than they would have in the absence of these subsidies.(5) This is also part of the background to the target 14.6 in the Sustainable Development Goals adopted by the United Nations.(6)

A main capacity-enhancing subsidy in EU fisheries is the fisheries sector’s exemption from fuel taxes. It is important that the fisheries sector has the same price for carbon emissions as other sectors, whether this is achieved through a revision of the Energy Tax Directive or the Emissions Trading Directive. Progress on this is slow. In contrast, the EU was very quick to introduce a new fuel subsidy in response to the fuel price increases following the Russian invasion of Ukraine. This is a step in the wrong direction. Although a hasty and uncontrolled fleet reduction can cause problems, given the lack of progress on efforts to reduce overcapacity these efforts need to be intensified even more to counteract the negative effects of the new subsidy.

Summary

•    A key cause of the disastrous development of fishing stocks in the Baltic Sea is an over-emphasis on trying to achieve a narrowly defined Maximum Sustainable Yield for single stocks, with little or no consideration of its environmental limitations or interrelationships. Important information is not considered, or not included, or not highlighted in the scientific advice used as the basis for decision-making.
•    ICES advice would be more helpful for managers and contribute better to healthy fish stocks for the benefit of both the environment, the fishing sector and coastal communities if it would answer questions like:
o    What factors, that could be relevant for managers has ICES not taken into account when preparing its advice?
o    For each factor, would consideration of this factor would further uncertainty be acknowledged, pointing to the necessity of keeping TAC substantially below what can be estimated from current MSY procedures?
The Commission should consider requesting ICES to provide this information in a clear and transparent manner in the advice sheets, highlighting the factors contributing to the uncertainty related to a specific advice.
•    Measures of fleet capacity need to be updated to reflect the effects of “technological creep” and the Commission should more actively use the tools at its disposal to reduce overcapacity. Regional considerations should be included in the estimation of fleet capacity, ensuring a viable basis for regional fisheries.
•    Exemptions from fuel taxes are a particularly harmful subsidy that contributes to overcapacity and excess fishing pressure, damages the marine environment and increase climate-heating emissions. The fishing sector should pay the same price for climate emissions as other sectors.

Henrik Svedäng has contributed to this response to the consultation.

On behalf of Stockholm University Baltic Sea Centre
Charles Berkow
Policy Analyst