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The EU multiannual plan (MAP) for cod, herring and sprat fisheries in the Baltic Sea was unique in its kind when it entered into force in the summer of 2016. The aim was to create better conditions for complying to the Common Fisheries Policy and the objectives of environmentally, economically and socially sustainable fisheries and aquaculture.

Recently, the European Commission presented a first evaluation of the first four years with the MAP. It is no exaggeration to say that the development has not gone exactly according to plan. For many of the Baltic Sea's most important commercial fish stocks, the situation is critical. Worst off is the Eastern Baltic cod stock, which is on the verge of collapse.

EU Commissioner for the Environment, Maritime Affairs and Fisheries, Virginijus Sinkevicius, notes that the evaluation nevertheless shows that ‘we cannot blame the fishing sector alone’, and points out that many of today's serious problems are caused by impacts that began ‘long before 2016', such as eutrophication, overfishing and emissions of environmental toxins.

The trend of eutrophication is broken

The fact that several fish stocks in the Baltic Sea are now at critical levels can, as Sinkevicius says, hardly be blamed solely on the fishing sector. Fishermen try to fish the catch quotas (TACs) they are allocated from year to year. The Baltic Sea was heavily affected by overfishing, environmental toxins and nutrient emissions during the second half of the 20th century, but in recent decades, emissions of environmental toxins and nutrients have changed radically. Known toxins such as PCBs and DDT, for example, have long been banned, and the negative trend in eutrophication has been broken thanks to major efforts, primarily in agriculture and wastewater management.

There are still serious environmental problems in the Baltic Sea, not least due to eutrophication, which causes major problems for cod, among others. However, the decline in recent years for several important commercial fish stocks also raises questions about shortcomings in both the overall management and in the MAP itself.

Criticism from fishermen and NGOs

However, such issues are given very little space in the evaluation of the MAP. Instead, the Commission concludes that the MAP as a whole ‘constitutes a stable, long-term instrument for implementing the Common Fisheries Policy in the Baltic Sea, provides less uncertainty for setting quotas’ and ‘enables the fishing industry to better plan its fisheries’.

Member States and various stakeholders have also commented on the Commission's evaluation. The Regional Advisory Council for the Baltic Sea (BSAC) - with representatives from both the fishing industry and various NGOs – has a clearly negative view of  how the MAP has worked so far. Industry representatives think the MAP restricts fishing too much, while the environmental organizations believe that it allows too much fishing on vulnerable stocks.

This criticism may lead to further discussions about the MAP, that might continue at different levels within the administration now that the first evaluation is on the table.

An interesting starting point for such discussions could be to take a closer look one of the most crucial measures of Baltic fisheries management: the setting of catch quotas (TACs).

Shaky TACs for western cod

Every October, EU fisheries ministers meet for a few days to negotiate just how much should be fished from each stock next year. They carry with them advice and recommendations from the Commission and in particular the International Council for the Exploration of the Sea (ICES).

But in the end, it is the ministers themselves who, behind closed doors, decide the TACs and divide them among the fleets.

When the MAP came into force in 2016, the western Baltic cod stock was in very poor condition. ICES recommended a TAC reduction of as much as 88 percent to give the stock a chance to recover. EU ministers agreed on a 56 percent cut. The following year, ICES again recommended a sharp TAC reduction, but the ministers decided to keep it at the same level as last year.

Since then, TACs for the western cod have made drastic jumps between large increases and decreases from year to year – often exceeding scientific recommendations.

Prior to 2019, the western cod stock was considered to have recovered somewhat, which led both ICES and the Commission to recommend a cautious TAC increase of 30 percent. Ministers took those positive signals as a pretence to increase TAC by as much as 70 percent. This decision had serious consequences. In 2019, the western cod stock weakened sharply, which forced a 60 percent TAC reduction for 2020.

High TACs for eastern cod

For the eastern Baltic cod stock, the TACs have consistently been set above scientific recommendations. Thereby, the EU ministers have overestimated the stock's ability to deliver – since the fishermen have not managed to land their allocated quotas in over ten years.

Last year, the EU ministers decided to close all targeted commercial fishing on the eastern cod stock, but allowed a by-catch of 2,000 tonnes. For 2021, the Commission proposes to maintain fishing ban, and to reduce the allowable by-catch to 595 tonnes.

Science wants reduced fishing for central herring

The pattern of setting TACs that exceed the scientific recommendations is repeated for some of the Baltic herring stocks. According to ICES, the western herring stock has been outside safe biological limits since 2008. As recently as 2019 ICES recommended a fishing ban – i e zero (0) TAC – since the stock was clearly overfished and in risk of collapse. Despite this, the Council of Ministers set the TAC just over 9,000 tonnes, which was half the TAC from the previous year.

Over the past five years, fishing mortality for the central Baltic herring stock has been above the maximum sustainable catch limit (FMSY). The spawning biomass (SSB) has fallen so much that special measures are required. In addition, the stock is supported by a single strong year class (fish born in 2014). Earlier this year, the Commission proposed that the Council of Ministers follow the ICES scientific recommendation for a 36 percent TAC reduction for 2021.

Whether they will follow this recommendation or not, will be decided within a few weeks, when the Council of Ministers meet again to negotiate next year's TACs.

Climate change calls for long-term sustainability

Both single fish stocks and the ecological balance between different interacting species often benefit from a fairly constant sustainable fishing pressure without excessive variations from year to year. This also rhymes well with the fishing industry's need for continuity and predictability to be able to plan their activities. Therefore, "sustainability" and "long-term perspectives" are important keywords in the MAP as well as for fisheries management in general.

For several of the most important commercial fish stocks in the Baltic Sea, TAC-setting has hardly been characterized by these key words over past four years. The decline in cod and herring can not only be blamed on old environmental sins from the last century. It must also be seen as a sign that something is not right in the administration.

What these shortcomings are and how they should be remedied are issues that should be further examined, since the impact on the fish stocks will increase as higher water temperatures and other climate effects become apparent in the Baltic Sea. A close and critical examination of the MAP, and its role in the annual TACs for Baltic Sea fisheries, could be a first step in that direction.

The question is if the Council of Ministers will seize the opportunity to raise these issues when they meet again to negotiate next year's TACs for the Baltic Sea fisheries.