Summary

1. Management has not been successful in the Baltic.

2. To take account of uncertainty in the scientific assessments, the Commission should propose TACsin line with F-lower for stocks assessed as being in good shape; for others, TACs should by 50% of Fmsy.

3. Until further information is available, the Commission should propose an “ecological share” of 20% of the TAC as a proxy for reduced impacts of fisheries on the ecosystem.

4. Efforts to improve selectivity should be focused on species selectivity, not size selectivity.

5. The Commission should propose measures to restrict the indiscriminate fishing of large industrial trawlers in the Baltic as a steptowards giving greater consideration to the issue of sub-populations in management. The Commission should conduct a survey of how Member States in the Baltic are using the opportunities provided by Article 17 in the CFP to incentivise more sustainable fishing.

6. The Commission should request that STECF develop a pilot programme for the Baltic with a method of identifying overcapacity and capacity reduction options that does not favour large industrial trawlers at the expense of small-scale, coastal fishers.

Explanatory note

1. Seven years into the reform from 2014 and five years after the adoption of the Baltic multiannual plan (MAP) we feel it is time to draw more substantial conclusion than the Commission does in its Communication. The background is the serious situation of some of the historically most important stocks in the Baltic. This year, ICES:

- Notes that the SSB for Central Baltic herring appears to have dropped below Btrigger and recommends a decrease of the TAC of 36% or more. This is on top of the reductions in the past years: 36% for 2021, 10% for 2020 and 26% for 2019.

- Recommends a 0 TAC for the western Baltic spring spawning herring for the fourth year in a row

- Recommends a 0 TAC for the eastern Baltic cod for the third year in a row

- Was unable to present a recommendation for the western Baltic cod.

Clearly, management has not been successful in the Baltic.

2. One reason for the failure of management for a number of key species is the uncertainty in the scientific advice and the failure of managers to draw the consequences of this uncertainty in their decisions. A review of the ICES advice for the Central Baltic herring shows that the stock and its potential yield have often been overestimated. Thus, management decisions that at the time were believed to have been in line with scientific advice have, in retrospect, been shown to be too high.

The consequences for the fish stocks, the fishery and the environment of TACs that are too high are much more serious than if the TACs are set below the estimated Fmsy. Therefore, a reasonable conclusion of the consequences of the scientific uncertainty is that TACs should consistently be set substantially below estimated Fmsy. For stocks assessed as being in good shape we recommend F lower as allowed for in Article 4.2 in the MAP. For other stocks we propose 50% of Fmsy as allowed for in Article 4.3 of the MAP.

For further explanation and details, see our Policy brief: Adapt herring fisheries to scientific uncertainty (2254 Kb) .

3. The Commission correctly notes the failure of the CFP to contribute to achievement of the objectives of the Marine Strategy Framework Directive from 2008. It is significant that 13 years after adoption of the MSFD and one year after the target year of 2020 has passed, there are still not threshold values for descriptors such as sea-floor integrity or reference values for criteria such as age and size distribution. This appears due in part to a genuine scientific uncertainty, but also largely to a lack of political will to supply the resources that would be needed. Indeed, it might even be the case that there are perceived to be incentives, from the short-term perspective of parts of the fishing sector, to NOT realize such reference points and threshold values as these, were they incorporated into fisheries management decisions, might lead to lower quotas in the short term.

Therefore, it is not enough as the Commission proposes that together with scientists “the Commission will further speed up work on the ecosystem effects of fishing, to feed those factors into fisheries management.”

Further, ICES writes “[l]imitations on fisheries may be required in order to achieve environmental objectives, especially regarding biodiversity, habitat integrity, and foodwebs. This will not affect the catch that can be taken from a stock in accordance with the objectives of MSY and the precautionary approach, and will therefore not affect ICES advice on fishing possibilities. The limitations may, however, affect the fisheries’ opportunities to fully utilize the advised fishing possibilities. ICES may, if requested, advise on the likely impact of such limitations on the catch but will, as explained, not include such considerations in the advice on fishing opportunities.”[1]

The Commission should therefore consistently request ICES to advise on the likely impact of such limitations on the catch so that the Commission can take those impacts into account in making its proposals for TACs and other regulations. As an alternative, or if ICES is unable to supply the requested advice, the Commission should propose an “ecological share” of, say, 20% as a proxy for reduced impacts of fisheries on the ecosystem aspects reflected in the descriptors in the MSFD. This would be a material step in contributing to fulfilment of the objective in article 3.3 of the MAP and the intentions of the EU Biodiversity Strategy.

4. As the Commission reports, the EU and Member States are investing a lot of money in increasing selectivity of gear as a means to achieve the objective of the landing obligation. However, increasing size selectivity of fishing without reducing quotas or effort will result in more pressure on older and larger fish. Even though this is not monitored, it is likely in direct conflict with D3C3 in the MSFD. It can have significant negative implications both for the health of the stocks, the fishing sector and for the ecosystem in general. Efforts to improve selectivity should be focused on species selectivity and include spatial and temporal changes to fishing patterns. Increased size selectivity on the other hand must go hand in hand with reducing quotas and fishing pressure.

5. Fishing management currently gives too little consideration to the implications of local sub-populations or stock components. As a result, local sub-populations can be wiped out without managers even being aware of it. Aside from the loss of biodiversity and the local environmental consequences, this can in the longer-term impact negatively on the viability of the fish stock. This was a major factor in the destruction of the Kattegat and Skagerrak cod. It may be an important factor in the declines of the western Baltic spring spawning herring, the central Baltic herring and the Baltic cod stocks.

In particular, the Commission should propose measures to restrict the indiscriminate fishing of large industrial trawlers in the small, sensitive Baltic. The increase in trawler size and capacity (in terms of actual ability to capture fish) may result in a higher, more concentrated fishing pressure locally, leading to a continuous erosion of the herring stock structure as the remaining large vessels move from year to year among fishing sites. This is not compatible with the intentions of the EU Biodiversity Strategy. Such measures could include spatial restrictions (such as keeping the industrial trawlers outside the 12-mile zone), temporal restrictions (not allowing industrial trawling where when herring from several potential sub-populations congregate in common feeding grounds or in over-wintering shoals) or other measures. Further, the Commission should conduct a survey of how Member States in the Baltic are using the opportunities provided by Article 17 in the CFP to incentivise more sustainable fishing.

6. The current system for reducing fishing fleet overcapacity is not working, which contributes to a number of other problems including overfishing, environmental consequences and control issues. STECF has repeatedly pointed out serious deficiencies in the system.

Further, some measures ostensibly taken to reduce overcapacity may on the contrary have made the problems worse. For example, if the introduction of ITQ leads to larger and newer vessels, that may accelerate the “technological creep” leading to a greater capacity to catch fish with a given gross weight and engine power.

Also, the way of identifying overcapacity in segments is biased in favour of larger vessels fishing over greater distances at the expense of small-scale and coastal vessels. When a Baltic stock is overfished, for example, larger vessels fishing on various stocks in the North Sea and the Baltic are classed as not having overcapacity – even though their fishing pressure on the limited stock in the Baltic is much greater than the smaller vessels classed as having overcapacity. The Commission should request that STECF develop a pilot programme for the Baltic with a more adequate method of identifying overcapacity and capacity reduction options.
 

Reference

[1] ICES. 2019. Advice basis. In Report of the ICES Advisory Committee, 2019. ICES Advice 2019, section 1.2. https://doi.org/10.17895/ices.advice. 5757