A fundamental problem with the CFP as implemented in the Baltic Sea is the effort to fish at levels corresponding to a narrowly estimated maximum sustainable yield (Fmsy, our emphasis).

This approach was criticized already in the run-up to the reform, including by one of the leading scientists associated with the concept of MSY, Sidney Holt, who instead suggested that fishing at 50% of Fmsy would be far more profitable.

Calculations of Fmsy are based on modelling, assuming correct data, robust models and stable environmental conditions. It can be questioned if these apply in the Baltic Sea, which increases the inherent uncertainties in estimating Fmsy. Declining environmental conditions due to global warming, ocean acidification, eutrophication etc, can be expected to lead to an even greater tendency than otherwise to overestimate Fmsy. 

It is more damaging to fish stocks, the marine environment, the fishing sector and fishing communities to fish above Fmsy than below Fmsy. This is another reason to aim below estimated maximum sustainable yield.
EU fisheries are in practice seldom based on the ecosystem-based approach to fisheries management or the precautionary principle, as these terms are defined in the CFP Basic regulation. 

The Commission should take a step towards implementation of an ecosystem-based approach and better coherence with the Green Deal and EU environmental policy by requesting ICES to a) list relevant factors not adequately taken into consideration in the advice and b) for each factor, indicate if taking consideration would lead to higher or lower quotas than following ICES Fmsy advice as currently calculated. Such factors include:

• The impact of fishing on other associated commercially fished stock
• The impact of fishing on other associated species e.g. in the food web
• The impact of fishing on sea-floor integrity
• Impacts on sub-populations or stock components
• Impacts on the age and size structure of the stock
• If the condition of the stock seems to be improving or declining
• The consequences of the dominance of a relatively strong year class, and the impact of fishing it or leaving it in the water
• The general degree of uncertainty in the assessment, e.g. due to the quality of the data, to changing environmental factors or evidenced by Spawning Stock Biomass not increasing despite fishing at or below estimated Fmsy.

Failure to take these uncertainties and limitations into account, together with recurring questionable short-term socio-economic considerations, has led to serious negative socio-economic impacts in the medium (=longer than one year) term. This has been exacerbated by a failed fleet policy that does not take regional considerations or account of technological creep, and by massive subsidies in the form of exemptions from fuel taxes.

Notes:

1. Michael Earle, Maximum sustainable yield in the EU’s Common Fisheries Policy - a political history, ICES Journal of Marine Science, Volume 78, Issue 6, September 2021, Pages 2173–2181, https://doi.org/10.1093/icesjms/fsab037

2. SLU svarar på frågor om sill/strömming https://www.slu.se/globalassets/ew/org/inst/aqua/externwebb/radgivning/faq-sillstromming/faq-sill-stromming-pdf-v2021-06-01-komplettering-2022-03-15.pdf 

3. Baltic Sea Centre, Policy Brief, Adapt herring fisheries to scientific uncertainty https://www.su.se/polopoly_fs/1.580543.1635509572!/menu/standard/file/PBsillosakerEngWEBB.pdf