The Stockholm University Baltic Sea Centre’s comments below refer primarily to the proposal to amend the Baltic MAP. They are to a large extent also relevant for the other MAPs.

Summary

• The Commission proposal should be withdrawn. It is faulty in content and the process leading up to the proposal was deficient.
• The Commission proposal would increase the level of risk permitted by the MAP.
• The Commission justification for the weakening of the MAP is based on a misunderstanding of the science and of the structure of the MAP.
• The MAP, as implemented, has major deficiencies. These should be urgently remedied.

A proposal to increase risk

Deletion of Art. 4.6, with no compensating measures, removes a safeguard and increases the level of risk in management of Baltic fisheries. It allows the Council to decide on TACs with a high probability of SSB falling below Blim, as the October 2023 Council did when, disregarding Art. 4.6, it set a TACs for two herring stocks with a probability of SSB falling below Blim next year of over 20% - more than four times the risk level than the MAP currently allows. This is not compatible with the objective of stronger stocks in Art 3.1 in the MAP regulation and in Art. 2.2 in the CFP regulation.

Failure to meet MAP objectives

Most of the fish stocks covered by the MAP in the Baltic have declined since its adoption, contrary to the objectives in the MAP and CFP. This is the reason why Art. 4.6 has come into focus.

The development of fish stocks is dependent on a number of factors, both internal and external to management. To the extent that environmental factors contribute to the decline of fish stocks it is important that management, if possible, counteracts these rather than making it worse and applies a more precautionary rather than a riskier approach. Declining environmental conditions are reasons to reduce fishing pressure below present uncertain estimates of levels around MSY. Further, the environmental objective of the MAP (Art. 3.3) and the CFP (Art.2.3) appears to be completely ignored when implementing the MAP, underlining the risk-prone acceptance in management.

The MAP, as implemented, has major deficiencies. These need to be urgently remedied. An opportunity to start is the report on the results and impact of the MAP required in July 2024 under Article 15 of the MAP.

A misunderstanding of the science and the MAP

The Commission’s justification for its proposal is based on a misunderstanding of the science. The Commission has also confused the remedial measures to be taken under Article 5 to be substitutes to the provisions for setting fishing opportunities under Art. 4, instead of supplements. This is explained in more detail here:

ANALYSIS: Weakening the management of Baltic fisheries

Faulty process

We disagree with the COM conclusion in its proposal that no proper public consultation or impact analysis is necessary. This consultation itself is inconsistent with that contention.

Further, the socio-economic arguments mentioned appear to only consider the immediate short-term (the following fishing year). The Commission has not assessed the medium- and long-term socio-economic consequences or the environmental consequences of this increased risk level.

The process of preparing this proposal is difficult to reconcile with the Interinstitutional Agreement on better law-making. This is explained in more detail here:

ANALYSIS: Forgetting the deal

Revising the MAP

Any revision of the MAP needs clearer definitions (so that e.g. herring caught in fish-meal fisheries is not classed as a “by-catch”) as well as substantially more precise and precautionary rules.