COMMISSION STAFF WORKING DOCUMENT Details of the report Accompanying the document Report from the Commission to the European Parliament and the Council First report on the implementation of the Multiannual Plan for the stocks of cod, herring and sprat in the Baltic Sea and the fisheries exploiting those stocks
Date: 2020-09-14
Institutions: Directorate-General for Maritime Affairs and Fisheries, European Commission
Subjects: Baltic Sea, authorised catch, catch by species, catch quota, common fisheries policy, conservation of fish stocks, fishing area, fishing controls, sea fish, sea fishing

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 14.9.2020  SWD(2020) 171 final  COMMISSION STAFF WORKING DOCUMENT Details of the report  Accompanying the document Report from the Commission to the European Parliament and the Council First report on the implementation of the Multiannual Plan for the stocks of cod, herring and sprat in the Baltic Sea and the fisheries exploiting those stocks {COM(2020) 494 final}  
 
 
This Staff Working Document provides more details about certain chapters of the report1 on 
the  implementation  of  the  multiannual  plan  for  the  Baltic  Sea2,  some  information  about 
control-related aspects, and the detailed replies given in the stakeholder consultation.  

Contents 

1.  Modifications of the MAP .................................................................................................. 2 

2.  TAC setting ......................................................................................................................... 2 

3.  Landing obligation .............................................................................................................. 4 

4.  Eco-system based approach ................................................................................................ 5 

5.  Socio-economic developments ........................................................................................... 8 

6.  Control ................................................................................................................................ 8 

7.  Stakeholder consultation ..................................................................................................... 9 

7.1.  Baltic Sea Advisory Council ......................................................................................... 11 

7.2.  Baltic Sea Fisheries Forum (BaltFish) .......................................................................... 16 

7.3.  Association of Fisheries Protection (Germany) ............................................................ 24 

7.4.  Clean Coalition Baltic ................................................................................................... 38 

7.5.  Confederation of Fishermen and Fish Processors of West Lithuania ........................... 44 

7.6.  Danish Fishermen Producer Organisation ..................................................................... 48 

7.7.  Darlowska Group of Fish Producers and Ship Owners ................................................. 53 

7.8.  Latvian Fisheries Association ....................................................................................... 58 

7.9.  The Fisheries Secretariat ............................................................................................... 62 

7.10.  World Wildlife Fund ................................................................................................. 71 

7.11. 

The PEW Charitable Trusts ....................................................................................... 80 

ANNEX ...................................................................................................................................... 87 

1  
2  

COM(2020) XXX of XYZ 2020. 
Regulation (EU) 2016/1139 of the European Parliament and of the Council of 6 July 2016 establishing 
a multiannual plan for the stocks of cod, herring and sprat in the Baltic Sea and the fisheries exploiting 
those stocks (OJ L 191, 15.7.2016, p. 1). Hereafter “MAP”. 

1 

 
 
 
 
 
                                                 
1.  Modifications of the MAP 

The MAP was modified twice in order to take account of the latest developments in scientific 
knowledge.  ICES  found  that  the  two  herring  stocks  of  the  Bothnian  Sea  and  Bothnian  Bay 
were one single stock. The two TACs were hence combined and the target fishing mortality 
ranges and conservation reference points were updated.3 When ICES updated the MSY ranges 
and conservation reference points in its advice for the 2018 fishing season it became apparent 
that these fixed numbers in the MAP were not in line with the best available scientific advise. 
This  led  to  the  adoption  of  TAC  decisions  that  did  not  reflect  the  objectives  of  the  MAP. 
Therefore, the co-legislators agreed to replace those fixed values in the Annexes of the MAP 
by values to be advised annually by ICES.4 Like this the plan would not risk being outdated 
whenever ICES updates these values and the basis for establishing  yearly TAC levels is the 
most recent best available science. Furthermore, it was decided that the landing obligation is 
not  applied  to  recreational  fishing.  Finally,  an  amendment  is  currently  under  discussion 
between the co-legislators to reinforce certain management measures for eastern Baltic cod.5  

2.  TAC setting 

The  Baltic  Sea  is  an  atypical  sea  basin  due  to  its  geographical,  physical  and  chemical 
characteristics as a semi-enclosed, shallow (the average depth is 60 meters, and one third of 
the  area  is  less  than  30  meters  deep),  brackish  sea.  It  has  strong  temperature  and  salinity 
gradients. A strong permanent vertical stratification of the water column means deeper waters 
have less oxygen.6 This leads to less diversity in fish species and the fisheries focus on three 
target species of the MAP – cod, herring and sprat. Total landings peeked in the mid-1970s at 
over 1.2 million tonnes/year and continuously decreased thereafter to stabilize since the early 
2000s  at  around  600.000  tonnes/year.  There  are  however  important  differences  between  the 
stocks. There has been a very sharp decline of cod catches (mostly eastern Baltic cod) since 
the mid-1980s from almost 450.000 tonnes/year to about 13.000 tonnes/year in 20197. During 
the same period catches of sprat increased from less than 50.000 tonnes/year to over 500.000 
tonnes/year in the late 1990s, before decreasing again to around 250.000 tonnes/year in recent 
years.  Herring  decreased  from  around  450.000  tonnes/year  during  the  1970s-80s  to  about 
250.000  tonnes/year  in  the  mid-2000s  from  where  it  has  increased  again  to  over  300.000 
tonnes/year.8 

3  

4  

5  

6  
7  
8  

Regulation  (EU)  2018/976  of  the  European  Parliament  and  of  the  Council  of  4  July  2018  amending 
Regulation (EU) 2016/1139 (OJ L 179, 16.7.2018, p. 76). 
Regulation  (EU)  2019/472  of  the  European  Parliament  and  of  the  Council  of  19  March  2019 
establishing  a  multiannual  plan  for  fish  stocks  in  the  Western  Waters  and  adjacent  waters,  and  for 
fisheries exploiting those stocks, amending Regulation (EU) 2016/1139 […] (OJ L 83, 25.3.2019, p. 1). 
Commission proposal COM(2019) 564 of 31 October 2019 for a Regulation of the European Parliament 
and of the Council amending Regulation (EU) 2016/1139 as regards the introduction of capacity limits 
for eastern Baltic cod, data collection and control measures in the Baltic Sea, and, Regulation (EU) No 
508/2014 as regards permanent cessation for fleets fishing for eastern Baltic cod.  
ICES Advice 2019 – Baltic Sea Ecoregion Ecosystem overview, 12 December 2019.  
To be noted that the fishery for eastern Baltic cod was closed as of 24 July 2019. 
ICES Advice 2019 – Baltic Sea Ecoregion Fisheries Overview of 2 September 2019, pp. 6 and 7. 

2 

 
 
                                                 
From the outset it should be noted that some external elements have an impact on the setting 
by  the  EU  of  total  allowable  catches  (TAC)  for  the  Baltic  Sea.  First,  the  advice  from  the 
International  Council  for  the  Exploration  of  the  Sea  (ICES)  for  western  Baltic  herring  also 
covers  a  fishery  outside  of  the  Baltic  Sea,  which  the  EU  shares  with  Norway.  As  the  MAP 
does not bind Norway, ICES, according to its internal rules, does not provide scientific stock 
advice based on the MAP’s rules for western Baltic herring. Second, the stocks of cod, central 
herring, sprat and salmon are shared with the Russian Federation. Distribution keys had been 
agreed under the International Baltic Sea Fishery Commission. However, subsequently to the 
EU enlargement of 2004 this organization ceased to exist at the end of 2006 and with it also 
the agreement on the distribution keys. Since then it has not been possible for the EU and the 
Russian  Federation  to  agree  on  distribution  keys.  The  parties  hold  yearly  meetings,  but  set 
their  annual  TACs  autonomously.  For  setting  its  annual  TACs  the  EU  uses  the  distribution 
keys agreed in the past.  

The  TAC  for  a  stock  with  an  MSY  assessment  is  to  be  set  at  a  level  which  restores  at  the 
latest by 2020 and thereafter maintains a stock’s biomass above levels capable of producing 
MSY. An MSY assessment is only possible if sufficient data is available and if scientists have 
developed  a  concrete  MSY  model  for  the  stock.  The  TAC  for  a  stock  assessed  on  a 
precautionary  basis,  because  of  a  lack  of  data  or  lack  of  scientific  assessment  model,  is  to 
ensure  at  least  a  comparable  degree  of  conservation.  Decisions  are  to  be  based  on  the  best 
available scientific advice. 

Articles 4 and 5 of the MAP provide detailed rules about the TAC setting for stocks with an 
MSY  assessment.  For  these  the  TAC  is  to  be  set  within  a  range  of  values  to  provide 
flexibility,  to  take  account  of  the  latest  scientific  advice,  to  help  implement  the  landing 
obligation and to take into account the characteristics of mixed fisheries. All fishing mortality 
values in the range are to result in MSY in the long term with given fishing patterns and under 
average  environmental  conditions  without  significantly  affecting  the  stock’s  reproduction 
process. The range mustn’t lead to a reduction in long-term yield compared to MSY of more 
than 5% and is  therefore capped so that the probability that the stock’s biomass falls  below 
the limit spawning biomass reference point (so-called “Blim point”) is no more than 5%. This 
places the MSY objective of the EU among the most ambitious in the world, because it has 
built  a  precautionary  buffer  into  the  target.  On  the  other  hand  it  needs  to  be  stressed  that 
scientists agree that even with the best MSY management all stocks cannot be fished at MSY 
at the same time and there will always be some stocks that are not at MSY. 

The  TAC  is  to  be  set  in  the  lower  range,  i.e.  between  the  lowest  point  and  the  FMSY  point 
value. For healthy stocks the TAC may under certain conditions be set in the “upper range”, 
i.e. between the FMSY point and the highest point value. The conditions are: if a higher TAC is 
necessary to  take  account  of mixed fisheries, or to  avoid  serious harm to  a stock caused by 
intra- or inter-species stock dynamics, or to limit TAC variations from on year to another to 
20%. 

3 

 
 
If on the other hand a stock is under pressure and the amount of fish in the sea is at a low level 
(biomass below Btrigger), then remedial measures have to be taken to increase the stock above 
Btrigger. This entails fixing the TAC in the “lower range” taking into account the decrease in 
biomass.  If the amount  of fish in  the sea is  even below the minimum  level  (biomass  below 
Blim), additional measures must be taken to swiftly rebuild the stock. These can include further 
TAC reductions, suspending the targeted fishery and other remedial measures.   

In  2018  the  landings  in  the  Baltic  stemming  from  stocks  covered  by  the  MAP  and  which 
TACs were set at MSY reached 97% of total landings; for 2019 this figure stood at 94%. The 
annual  aggregate  tonnage  corresponding  to  fishing  at  the  FMSY  point  value  increased  from 
about  555.000  tonnes  in  2016  to  above  700.000  tonnes  in  2017,  but  then  declined  to  about 
565.000 tonnes in 2019. The downwards trend continues in 2020 as ICES advised to reduce 
the catches for most stocks. The aggregate tonnage corresponding to fishing at the FMSY point 
value  decreases  to  a  historically  low  470.000  tonnes.  Furthermore,  ICES  estimates  that  the 
biomass of eastern Baltic cod has been below Blim since 2017 and will remain below this level 
in the medium-term even with no fishing at all. The objective for this stock is to rebuild it to 
safe levels. 

3.  Landing obligation 

Before  the  entry  into  force  of  the  MAP,  on  the  basis  of  Article  15(6)  of  the  CFP  Basic 
Regulation9 a high survivability exemption from the landing obligation was granted in 2014 
for a duration of three years for cod and salmon caught by certain passive gears.10 Moreover, 
the  delegated  act  established  the  minimum  conservation  reference  size  for  cod  at  35  cm. 
These  exemptions  were  renewed  in  2017  on the basis  of  joint  recommendations,  and  plaice 
was  added.11  Regarding  plaice,  the  relevant  Member  States  were  to  provide  information  in 
March  2019  about  the  discard  survival  estimates.  A  joint  recommendation  on  high 
survivability of plaice was submitted to the Commission in June 2019. Based on the negative 
STECF assessment12 the Commission did not adopt a delegated act. 

Technical  measures  can  contribute  to  reducing  unwanted  catches  and  therefore  Article  8  of 
the MAP also empowers the Commission to adopt delegated acts. Two joint recommendations 
were submitted for the use of alternative and more selective gears. One led to the adoption of 
a delegated act13. On the other one STECF considered that the underlying scientific evidence 

9  

10  

11  

12  
13  

Regulation (EU) No 1380/2013 of the European Parliament and of the Council of 11 December 2013 on 
the Common Fisheries Policy (OJ L 354, 28.12.2013, p. 22). Hereafter “CFP Basic Regulation”. 
Commission Delegated Regulation (EU) 1396/2014 of 20 October 2014 establishing a discard plan in 
the Baltic Sea (OJ L 370, 30.12.2014, p. 40). 
Commission Delegated Regulation (EU) 2018/211 of 21 November 2017 establishing a discard plan for 
Baltic  salmon  (OJ  L  41,  14.2.2018,  p.  1);  to  be  noted  that  salmon  is  not  covered  by  the  MAP. 
Commission Delegated Regulation (EU) 2018/306 of 18 December 2017 laying down specifications for 
the implementation of the landing obligation as regards cod and plaice in Baltic Sea fisheries (OJ L 60, 
2.3.2018, p. 1). 
STECF 62nd plenary meeting report (PLEN-19-03), item 6.1, p. 56. 
Commission Delegated Regulation (EU) 2018/47 of 30 October 2017 authorising the use of alternative 
T90 trawls in the Baltic Sea fisheries (OJ L 7, 21.1.2018, p. 21). 

4 

 
 
                                                 
was not  sufficient  to  sustain  that the alternative gear would improve selectivity.14 Therefore 
no delegated act was adopted and BaltFish was asked to first provide more evidence on any 
improved selectivity. 

ICES estimates15 that discards of pelagic species are negligible in the Baltic Sea since sprat 
and herring are target species, and related by-catches are mostly landed, especially in the case 
of  targeted  industrial  pelagic  fisheries.  Discards  by  static  coastal  gears  are  minor.  For  the 
other fisheries the officially reported discards have been reduced close to zero since the entry 
into force of the landing obligation. ICES however stresses that illegal discarding continues. 
Overall  ICES  estimates  that  91%  of  the  estimated  discards  in  weight  are  caught  by  active 
gears,  and  while  the  subsequent  mortality  cannot  be  quantified  ICES  estimates  it  to  be 
substantial. Based on observer data only, and hence considered by ICES to be underestimates, 
ICES  indicates  in  its  latest  annual  stock  advice  estimated  discard  rates  in  2018  of  16%  for 
eastern  Baltic  cod,  around  4%  for  western  Baltic  cod,  and  around  30%  for  plaice  and 
flounder.16 Regarding plaice, ICES had previously indicated that under certain circumstances 
discards  could  be  up to  100% of the  catch.17  It  should  be noted that until  now, flatfish  was 
mostly caught as by-catch in targeted cod fisheries.  

4.  Eco-system based approach 

Pursuant  to  Article  2(3)  of  the  CFP  Basic  Regulation,  the  CFP  has  to  implement  the 
ecosystem-based  approach  to  fisheries  management  to  reduce  negative  impacts  of  fishing 
activities  on  the  marine  ecosystem.  Article  3(3)  of  the  MAP  furthermore  provides  that  the 
MAP has to  be coherent with  EU environmental law and in  particular with the objective of 
achieving  good  environmental  status  by  2020  as  set  out  in  the  Marine  Strategy  Framework 
Directive 2008/56/EC (hereafter “MSFD”).18  

Assessing the status of the Baltic Sea ecosystem and the MAP’s contribution is complex. The 
ecosystem  has  been  in  a  difficult  situation  for  decades.  In  1974  the  Convention  on  the 
Protection  of  the  Marine  Environment  of  the  Baltic  Sea  Area, known  as  the  Helsinki 
Convention,  was  signed  by  the  coastal  states.19  In  2007  its  members  adopted  a  Baltic  Sea 
Action Plan to restore the good ecological status of the Baltic marine environment by 2021, 
with  special  attention  to  eutrophication,  biodiversity,  hazardous  substances  and  marine 
activities.  Through  its  concrete  actions  Helcom  supports  the  EU  Member  States  in 
implementing the MSFD.  

14  
15  
16  

17  
18  

19  

STECF 59th plenary meeting report (PLEN-18-03), item 5.7, p. 70. 
ICES Advice 2019 – sr.2019.15 of 27 June 2019. 
ICES Advice 2019 – cod.27.22-24; cod.27.24-32; ple.27.21-23; ple.27.24-32; fle.27.2223; fle.27.2425; 
all of 29 May 2019.    
ICES Advice 2018 – ple.27.24-32 of 31 May 2018. 
Directive  2008/56/EC  of  the  European  Parliament  and  of  the  Council  of  17  June  2008  establishing  a 
framework for the community action in the field of marine environmental policy (OJ 164, 25.6.2008, p. 
19). 
www.helcom.fi. 

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In  order  to  determine  good  environmental  status,  the  MSFD  provides  eleven  qualitative 
descriptors. Furthermore, Article 3(3) of the MAP provides that the MAP aims ensure that the 
conditions  of  descriptor  3  are  fulfilled,  and  to  contribute  to  the  fulfilment  of  other  relevant 
descriptors in proportion to the relative role played by fisheries. Particular attention is paid to 
descriptor  3  because  it  is  directly  linked  to  the  TAC  (and  hence  to  the  MAP).  It  reads  “the 
populations of all commercially exploited fish and shellfish are within safe biological limits, 
exhibiting a population age and size distribution that is indicative of a healthy stock”. Fishing 
activities have an impact on the descriptors relating to biological diversity (1), the food web 
(4), sea-floor integrity (6) and marine litter (10). The contribution to the other descriptors is at 
best indirect and/or not substantial.20 

Besides  the  direct  extraction  of  species,  the  most  important  impact  of  fisheries  on  the 
ecosystem are the direct removal of predators and prey with indirect effects on the food web, 
abrasion  of  the  seabed,  disturbance  of  associated  benthic  communities  and  bycatch  of 
sensitive species. ICES, however, cannot quantify the effects on the ecosystem. 

Regarding  descriptor  3,  ICES  only  assesses  two  of  the  three  criteria  (biomass  and  fishing 
pressure, but  not  age  and size distribution).  In its latest  advice  ICES  estimated that in  2019 
Gulf  of  Riga  herring  was  the  only  target  stock  under  the  MAP  fulfilling  the  two  assessed 
criteria  of  descriptor  3;  sprat  and  central  Baltic  herring  fulfilled  only  the  biomass  criteria. 
Regarding  the  by-catch  stocks  under  the  MAP,  plaice  in  areas  24-32  fulfilled  descriptor  3 
while fishing pressure for plaice in areas 21-23 was too high; the status of flounder, brill and 
turbot  was  unknown.  The  status  of  stocks  not  covered  by  the  MAP  was  good  for  sole  and 
unknown for dab (with a positive assessment of the fishing pressure) and European eel (with a 
negative assessment of the stock size).  

ICES does not assess in detail the status of the other descriptors, but still provides qualitative 
indications. In the context of this report, which is about the implementation of the MAP and 
not of the MSFD in the Baltic Sea, the following aspects should be noted regarding the other 
relevant  descriptors.  Fishing  activities  increase  the  challenge  of  maintaining  biodiversity. 
ICES states for example that size-selective fishing may disrupt fish population stability, and 
fishing  gear  is  a  threat  to  certain  sea  birds  and  critically  endangered  harbour  porpoise.  In 
many  coastal  areas  the increased abundance of freshwater fish and a  concurrent  decrease in 
piscivorous  fish  indicated  a  deteriorating  ecosystem,  though  more  recently  there  have  been 
some signs of improvement. Fisheries have a large impact on the upper trophic levels which 
can cascade down the food web. For example the fisheries-related substantial reduction of the 
eastern Baltic cod stock during the 1980s led to an increase of zooplankton eating sprat which 
in turn led to a decrease of the summer biomass of zooplankton. This provoked a decline in 
the  body  condition  and  growth  of  sprat  and  herring,  which  may  have  led  to  an  increase  of 
phytoplankton  and  hence  worsened  eutrophication.  Bottom  trawlers  physically  destroy  and 

20  

Introduction  of  non-indigenous  species  (2),  human-induced  eutrophication  (5),  hydrographical 
conditions  (7),  level  of  contaminants  in  the  sea  (8),  level  of  contaminants  in  fish  and  seafood  (9), 
introduction of energy including underwater noise (11). 

6 

 
 
                                                 
disturb  seabed  habitats,  whose  diversity  and  biomass  hence  reduce  and  whose  composition 
changes. Secondary effects are the smothering and resuspension of sediments and nutrients, as 
well as food web effects. The impact, however, cannot be quantified due to a lack of studies 
and information on thresholds of environmental impact. Abandoned, lost or discarded fishing 
gear  are  an  unsolved  problem.  Its  impact  on  the  environment  remains  unquantified  but  the 
fishing pressure exerted is  estimated to  range from  20% of its usual net capacity after three 
months to a maximum of 6% after two years. Finally, and although not fisheries-related, the 
presence of slowly degrading contaminants such as dioxins and polychlorinated biphenyls are 
of  special  concern  for  the  fishing  sector;  the  issue  of  trawlers  re-suspending  sediments  in 
which those contaminants deposit and accumulate must be seen in this context. 

Conversely,  the  ecosystem  also  affects  fish  stocks,  but  ICES  cannot  determine  the  relative 
contribution  of  each  environmental  factor  on  the  fishing  mortality  rates.  There  has  been  a 
drastic increase in the extent of areas with too low and even areas with depleted oxygen since 
the  1990s,  likely  due  to  a  lack  of  strong  water  inflows  from  the  North  Sea  and  potentially 
increased  biological  oxygen  consumption  on  the  seafloor.  Moreover,  due  to  large-scale 
atmospheric processes, in the surface waters the average water temperature has increased and 
the average salinity decreased. This has led to considerable changes in spatial distribution of 
fish stocks, and changes in their condition and productivity. 

Furthermore,  parasites  and  invasive  species  also  impacted  fish  stocks.  They  lead  to  a 
decreased  productivity  of  herring  and  sprat  and  a  decreased  productivity  and  less  wide 
distribution of eastern Baltic cod, less predator-prey spatial overlap, and changes in the food 
web  functioning  due  to  invasive  species.  ICES  for  example  posed  the  question  whether  the 
main current bottleneck for eastern Baltic cod growth is the limited abundance of benthic prey 
for juvenile cod due to areas with too little oxygen, rather than a lack of sprat. 

Regarding the infection of eastern Baltic cod with liver worms, it remains uncertain whether 
the  high  infection  rate  is  the  cause  or  rather  the  effect  of  the  cod’s  poor  condition.  ICES 
estimates  that  the  population  of  grey  seals  has  reached  good  status  in  most  areas  and  has 
levelled off at around 30.000 individuals. In some areas the grey seal diet is estimated to have 
a  significant  impact  on  the  fish  stocks  but  there  are  no  recent  quantitative  estimations. 
According to Helcom the population of ringed seals is low and its status considered not good; 
the status of harbour seals varies between areas. Finally, bird predation can locally affect fish 
populations but the effect on the stocks is not yet quantified.    

The consulted stakeholders underline the importance of an ecosystem-based management of 
fisheries  and  the  contribution  of  fisheries  to  achieving  good  environmental  status,  while 
pointing out that non-fisheries related factors play an important role as well. Member States 
consider  that  the  situation  of  the  fish  stocks  would  probably  have  been  worse  without  the 
MAP  while  the  Advisory  Council  is  of  the  view  that  the  MAP  has  been  counterproductive 
since it lacks provisions on the concrete implementation of an ecosystem-based management 
of fisheries. 

7 

 
 
5.  Socio-economic developments 

In 2017 the Baltic fleet overall generated profits. However, the fleets of four Member States – 
Denmark, Finland, Germany and Lithuania - suffered net losses in 2017. The revenue (income 
from  landings  and  other  income)  generated  in  2017  was  estimated  at  EUR  226  million,  a 
modest increase of 1% from the previous year. Four Member States accounted for 74% of all 
revenues: Sweden (EUR 54 million), Poland (EUR 47 million), Finland (EUR 35 million) and 
Denmark (EUR 30 million).  

By the end of 201721 small-scale coastal fisheries were responsible for 85% of the days at sea 
and 68% of employment. Yet, the large-scale fleet has been the main actor in the region and 
was responsible for 92% of landed weight and 77% of the landing value. Landed weight has 
been  decreasing  for  years;  landed  value  increased  until  2012  and  has  been  decreasing  since 
mostly because of decreasing prices for and landings of cod.   

Gross Value Added in 2017 was estimated at over EUR 112 million, gross profit at EUR 44.3 
million  and  EUR  9.4  million  in  net  profit.  Overall  the  gross  profit  margin  of  the  region 
decreased  from  23%  in  2016  to  19%  in  2017  with  the  Swedish  fleet  as  the  most  profitable 
(33%  profit  margin),  followed  by  Estonia  (30%),  Finland  (26%),  Latvia  (24%)  and  Poland 
(16%).  

Employment, measured in terms of Full Time Equivalents (FTE), decreased over the last 10 
years. On a more positive note, average wages per FTE in the large-scale fleet increased by 
10% between 2016 and 2017 and was estimated at around EUR 23 527 per year. 

6.  Control 

In  addition  to  the  general  provisions  of  the  Control  Regulation  (EC)  No  1224/200922,  the 
MAP  has  the  following  specific  provisions:  the  requirement  for  masters  of  vessels  of  8m 
length  or  more  to  keep  fishing  logbooks  and  to  submit  prior  notification  before  landing  if 
catches on board exceed certain limits; the obligation to land catches above certain thresholds 
in designated ports; and the derogation from applying the margin of tolerance in the logbook 
for unsorted landings.  

Most stakeholders point out  that the main problems  regarding fisheries  control in  the Baltic 
Sea  concern  issues  not  directly  linked  to  the  MAP,  notably  the  lack  of  effective  means  to 
control and enforce the landing obligation. Scientific data, EFCA reports and the preliminary 
findings of recent audits seem to corroborate a generalised lack of efficient control measures 
by  Member  States.23  To  improve  the  situation,  the  stakeholders  suggest  to  focus  control  on 
gears  that  are  known  for  substantial  by-catch  and  risk  of  discards  and  to  introduce  Closed-

21  
22  

23  

Relevant economic data is only available until 2017. 
Council Regulation (EC) No 1224/2009 of 20 November 2009 establishing a Union control system for 
ensuring compliance with the rules of the common fisheries policy (OJ L 343, 22.12.2009, p. 1). 
Commission  Staff  Working  Document  SWD(2020)112 
Communication on the 2020 Policy Statement COM(2020)248, pp. 32-42. 

final  accompanying  Commission 

8 

 
 
                                                 
Circuit Television and Remote Electronic Monitoring. Stakeholders  also ask to  improve the 
control of vessel engine power and introduce digital catch reporting for all vessels regardless 
of their length  

The  enhanced  reporting  requirements  for  vessels  of  8m  or  more,  and  prior  notification  and 
obligation  to  fill  in  log  books  increased  the  effectiveness  of  controls.  The  consulted 
stakeholders consider that the obligation extending the use of logbooks and prior notifications 
for  vessels  below  8m,  as  well  as  the  obligation  to  land  catches  above  certain  thresholds  in 
designated  ports  have  helped  achieve  CFP  objectives.  The  Baltic  Sea  Advisory  Council 
however believes that the Specific Control and Inspection Programs in combination with Joint 
Deployment Plans are by far more effective. 

As  for  the  derogation  from  the  margin  of  tolerance  for  unsorted  pelagic  landings,  there  are 
strong  indications  that  this  provision  has  resulted  in  substantial  misreporting  of  sprat  and 
herring,  which  might  affect  the  assessments  of  these  stocks.  In  order  to  gain  a  better 
understanding  of  the  misreporting  and  assess  its  magnitude,  the  Commission  launched  a 
specific data call in December 2019 to obtain relevant catch, landing and inspection data from 
the Member States concerned. The analysis of these data is currently ongoing.  

It is worth noting that all issues mentioned above were already raised previously, at numerous 
occasions, including in the public consultation on the evaluation of the Control Regulation.24 
The discussions held in this context however also highlighted the need to address these issues 
at European rather than regional level in order to avoid distorting competition.25 The failure of 
Member  States  to  control  the  obligation  to  land  catches,  as  well  as  the  lack  of  a  fully 
electronic  system  for  catch  reporting,  together  with  poor  control  of  engine  power;  are 
considered  to  affect  compliance  with  the  CFP  seriously.  The  Commission  adopted  in  May 
2018  a  proposal  for  the  revision  of  the  Fishery  Control  System26  and  have  been  part  of  the 
control  strategy set-up together with  the Member States and the European Fisheries Control 
Agency (EFCA). 

7.  Stakeholder consultation 

In the context of this first report on the implementation of the Baltic Sea Multiannual Plan the 
European  Commission  undertook  a  targeted  stakeholder  consultation,  as  it  did  when  it 
prepared the initial legislative proposal on the said Multiannual Plan.27 The consultation was 
based on a questionnaire. The consulted stakeholders were the Baltic Sea Advisory Council, 
the Baltic Sea Fisheries Forum and the respective members of these two organisations.  

24  
25  
26  
27  

COM(2017) 192 final of 24 April 2017. 
SWD(2018) 280 final of 30 May 2018. 
COM(2018) 368 final of 30 May 2018. 
COM(2014) 614 final and SWD(2014) 291 final. 

9 

 
 
                                                 
Outside  the  targeted  stakeholder  consultation,  one  organisation  sent  on  its  own  initiative  a 
contribution to DG MARE which is also reproduced in this document. Also to be noted, that a 
group of NGOs published a report in September 2019 on the Baltic MAP.28 

This  Staff  Working  Document  reproduces  the  content  of  the  replies  as  received  by  the 
Commission. Questions 1 to 5 of the questionnaire referred to the identity of the respondent 
and  are  therefore  not  reproduced  in  this  document.  The  replies  of  the  Baltic  Sea  Advisory 
Council and of the Baltic Sea Fisheries Forum are reproduced first followed by the replies of 
the  other  organisations  of  the  targeted  stakeholder  consultation  in  alphabetical  order.  The 
reply received outside the targeted stakeholder consultation is reproduced last.  

28  

“Fit  for  purpose?  An  assessment  of  the  effectiveness  of  the  Baltic  Sea  multi-annual  plan  (BSMAP)”, 
https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=2&ved=2ahUKEwiiq8amvtPo
AhUCLewKHXP5DewQFjABegQIAhAB&url=https%3A%2F%2Fwww.pewtrusts.org%2F-
%2Fmedia%2Fassets%2F2019%2F09%2Fbaltic-map-review-
final.pdf%3Fla%3Den%26hash%3D2483E5C6E5528ADFFCB5DFE8FBD9A9A32B502FCD&usg=A
OvVaw3lcz5jBRninAUC-dvRGUpt. 

10 

 
 
 
 
                                                 
7.1. Baltic Sea Advisory Council 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP MSY is to be achieved for all relevant stocks by 2020. 8 of the stocks 
covered by the MAP are managed by TACs, of which 7 receive an analytical assessment by 
ICES  (6  target  TAC,  and  one  by-catch  TAC).  Out  of  these  7  TACs  the  TACs  for  3  stocks 
were at MSY in 2016, and for 6 stocks as of 2017. In your opinion 

Q6: Has the existence of a MAP facilitated the process of setting of TACs for the relevant 
stocks?  

Q7:  To  what  extent  has  the  MAP  contributed  to  increasing  the  number  of  TACs  set  at 
MSY?  

Q8: Has the MAP helped in dealing with difficult cases such as Eastern and Western Baltic 
cod, Western herring or other sensitive stocks? 

Q9: free text 

The  BSAC  is  of  the  opinion  that  the  existence  of  a  MAP  has  not  facilitated  the  process  of 
setting  of  TACs  for  the  relevant  stocks.  Several  members  are  of  the  view  that  the  Plan  has 
actually been counterproductive in this process.  

In the BSAC’s opinion, the MAP has not contributed to increasing the number of TACs set at 
MSY and has not helped in dealing with difficult cases such as the eastern and western Baltic 
cod  stocks,  western  herring  and  that  the  provisions  in  the  MAP  have  in  some  cases  been 
counter-productive.   

It is the general view of BSAC members that the MAP has not satisfied anybody.   

The  fisheries  representatives  underline  that  the  framework  provided  by  the  MAP  is  not 
flexible enough to respond to the fluctuations caused by nature and changes in the ecosystem. 
In concrete terms, the ranges of target fishing mortality levels set out in Annex I1 to the Plan 
are too rigid in the light of inconsistent scientific advice on fish stocks and do not allow for a 
more  adaptive  management.  In  their  opinion,  the  inclusion  of  a  socioeconomic  clause  in 
setting  the  TACs  would  provide  for  better  planning  of  the  fishery  in  line  with  the  fishing 
opportunities.    

Some OIG representatives are of the view that the achievement of objectives set in the MAP 
with  regard  to  setting  the  TACs  at  MSY  has  been  seriously  delayed.  The  CFP  Basic 
Regulation  only  allows  for  the  postponement  of  MSY  exploitation  rates  beyond  2015  “if 
achieving them by 2015 would seriously jeopardise the social and economic sustainability of 

1  

Subsequently removed by Regulation 2016/1139. 

11 

 
 
                                                 
the  fishing  fleets  involved”.  In  their  view,  to  date,  no  compelling  socio-economic  evidence 
justifying such delays in the Baltic Sea region has been made publicly available.  

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion  

Q10:  To  what  extent  have  discards  been  eliminated  and  the  landing  obligation  actually 
been implemented?  

Q11: To what extent has the MAP contributed to achieving the current situation, notably 
via discard plans and technical measures?  

Q12: free text 

The BSAC is of the opinion that the implementation of the Landing Obligation has not been 
fully successful. The BSAC is of the opinion that the MAP has not contributed to achieving 
the implementation of the Landing Obligation. For example, it has not provided enough help 
in terms of the developments of alternative gears or facilitating the removal of gears that do 
not  work.  Some  of  the  provisions  of  the  MAP  have  even  been  counterproductive  in  the 
implementation  of  the  Landing  Obligation,  for  instance  the  specific  measures  for  flatfish, 
which have encouraged bad practices in the fishery.    

The  development  of  the  special  exemptions  and  provisions  in  Article  7  has  not  been 
successful and has led to too much micro-management.   

The  BSAC  appreciates  the  attempt  to  create  a  regional  means  for  dealing  with  the  landing 
obligation.  However,  regionalization,  with  BALTFISH  as  the  managing  body,  has  not 
succeeded in doing this.   

One  fisheries  representative  has  experienced  elimination  of  discards  and  successful 
implementation  of  the  landing  obligation,  as  well  as  compliance  with  control  and 
enforcement. They have also experienced strengthened regional co-operation.  

Section 3 – Ecosystem-based approach  

Q13:  To  what  extent  has  the  objective  of  implementing  an  ecosystem-based  approach  to 
fisheries management, and notably of achieving good environmental status by 2020, been 
achieved?  

Q14: To what extent has the MAP contributed to the current situation?  

Q15: free text 

12 

 
 
 
 
The  BSAC  is  of  the  opinion  that  the  MAP  has  actually  been  counterproductive  in 
implementing an ecosystem-based approach to fisheries, whereby environmental factors  and 
interactions are to become a more integral part of managing the fisheries. Moreover, the MAP 
does not take into consideration the importance of species interactions. Despite having a clear 
objective  for  this  in  Article  3.3.,  the  MAP  does not  contain  any  provisions  for  allowing  for 
real  implementation  of  ecosystem-based  management  for  achieving  good  environmental 
status (GES) by 2020. Stating an objective is insufficient and unnecessary if it is not followed 
through.  

Section 4 – Control enforcement  

Q16:  To  what  extent  have  the  specific  provisions  laid  down  in  the  MAP  (Articles  10-14) 
allowed the national competent authorities to ensure compliance with the MAP itself?  

Q17:  Are  there  specific  control  measures  that  contributed  substantially  to  improve 
compliance?  

Q18:  Are  there  specific  control  measures  that  have  instead  not  contributed  to  improve 
compliance?  

Q19:  Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control 
Regulation which would improve compliance with the MAP?  

The BSAC is of the opinion that the specific provisions laid down in the MAP have not at all 
contributed  to  ensure  compliance  with  the  Common  Fisheries  Policy.  The  MAP  is  not  a 
control tool; it simply provides a list of exemptions from the Control Regulation.   

The Joint Deployment Programmes and the Specific Control and Inspection Programmes have 
been more effective than the MAP in dealing with control issues. Adding a layer of provisions 
within the MAP makes for a very complicated management framework.  

Moreover, the absence of a multiannual plan for Baltic salmon has made it necessary to add 
provisions in the current TAC/quota regulation 20192. If other legal acts can facilitate Baltic 
fisheries management, is there a need for a multiannual plan?  

Section 5 – Regional cooperation  

Q20: On  regional  cooperation, to  what  extent has the MAP in your opinion strengthened 
regional cooperation, including with stakeholders?  

2  

Regulation 2018/1628. 

13 

 
 
 
 
  
                                                 
Q21: free text 

The  BSAC  is  of  the  opinion  that  the  MAP  has  not  facilitated  regional  cooperation  and  its 
functioning is not helped by regional cooperation. The MAP was originally conceived to be 
developed and dealt with in a regional context and not to contain too much detail. BALTFISH 
as  a  regional  cooperation  was  created  well  before  the  MAP  came  about.  Formed  under  the 
aegis  of  the  Baltic  Sea  Action  Plan,  with  a  memorandum  of  understanding  from  13th 
December  2013,  BALTFISH  had  a  cooperation  in  place  and  could  have  been  the  testing 
ground  for  developing  Baltic  multiannual  management.  Instead,  presented  with  a  politically 
adopted MAP, BALTFISH has been challenged to deliver. In addition, the continued annual 
exercise  of  negotiating  and  agreeing  fishing  opportunities  is  time  consuming  and  does  not 
leave much time for regional management. For Western Baltic Herring (WBSS) the MAP has 
not  been  accepted  by  Norway,  a  key  coastal  state  for  the  management  of  the  stock.  Thus, 
ICES  does  not  provide scientific advice based on the MAP.  In short, the  MAP is  not  really 
helping regional cooperation; it is getting in the way.    

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion  

Q22:  Has  the  overall  socio-economic  situation  of  the  fisheries  sector  improved  since  the 
entry into force of the MAP?  

Q23:  Do  you  see  a  positive  correlation  between  the  implementation  of  the  MAP  and  the 
socio-economic situation of the fisheries sector?  

Q24: free text 

The BSAC agrees that the MAP lacks socio-economic considerations. So there is no positive 
or  negative  correlation.  There  is  no  reference  in  the  MAP  to  the  socio-economic  impact  of 
commercial and recreational fisheries. The fisheries representatives are of the opinion that this 
is a major failure of the MAP. In their view the MAP should manage fisheries, whilst at the 
same time take into account the fishermen and the impact and consequences of management 
decisions. So its scope and perspective should be widened. The OIG takes note of the socio-
economic  dimension  which  they  feel  is  not  sufficiently  documented  when  the  decisions  on 
fishing opportunities are taken.   

Section 7 – Overall assessment   

Q25: What is your overall assessment of the Baltic MAP?  

Q26: free text 

14 

 
 
 
 
The BSAC is not satisfied with the general performance of the MAP.   

The BSAC appreciates the overall objective of creating a regional management plan  and the 
attempt  to  introduce  a  multi-species  management.  It  is  perhaps  too  early  to  draw  final 
conclusions  on  the  effectiveness  of  the  MAP.  However,  the  MAP  has  many  shortcomings. 
One  of  the  major  shortcomings  is  the  lack  of  defined  measures  to  be  applied  in  emergency 
situations  and,  in  the  view  of  fisheries  representatives,  the  lack  of  socio-economic 
considerations.    

The  fisheries  representatives  note  the  problem  with  the  inconsistency  of  the  ICES  advice 
which  has  caused  the  estimates  of  biomass  to  jump  up  and  down  around  the  suggested 
reference  points.  With  a  rigid  management  plan,  this  translates  immediately  into  similar 
instabilities in TACs and gives an impression of TACs set too high in hindsight, although they 
were set in line with scientific advice at the time they were agreed.  

The  OIG  points  out  that  the  MAP  has  been  harmful  to  the  management  of  Baltic  Sea  fish 
stocks  and  that  its  implementation  has  been  detrimental.  In  their  view,  for  only  one  of  the 
seven  stocks  managed  by  the  MAP  has  the  Plan  been  correctly  implemented  (Gulf  of  Riga 
herring). The unsuccessful implementation of the MAP and the omission to follow the clear 
guidelines laid out in the MAP have had a detrimental effect on the other stocks.   

The OIG underlines that the MAP is not facilitating the implementation of the CFP and the 
Marine Strategy Framework Directive as intended.  

The BSAC agrees that the regional component that is key to the successful functioning of a 
MAP is yet to be delivered. This is a disappointment. The Baltic Sea MAP was the first to be 
adopted.  It  was  held  up  as  a  blueprint  for  future  MAPs.  But  it  has  not  lived  up  to  its 
expectations.   

15 

 
 
 
 
7.2. Baltic Sea Fisheries Forum (BaltFish) 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP MSY is to be achieved for all relevant stocks by 2020. 8 of the stocks 
covered by the MAP are managed by TACs, of which 7 receive an analytical assessment by 
ICES  (6  target  TAC,  and  one  by-catch  TAC).  Out  of  these  7  TACs  the  TACs  for  3  stocks 
were at MSY in 2016, and for 6 stocks as of 2017. In your opinion 

Q6: Has the existence of a MAP facilitated the process of setting of TACs for the relevant 
stocks?  

No opinion 

Q7:  To  what  extent  has  the  MAP  contributed  to  increasing  the  number  of  TACs  set  at 
MSY?  

No opinion 

Q8: Has the MAP helped in dealing with difficult cases such as Eastern and Western Baltic 
cod, Western herring or other sensitive stocks? 

No opinion 

Q9: free text 

The fact that the MAP entered into force during summer 2016 means that the setting of the 
fishing  opportunities  for  2017  in  October  2016  was  the  first  time  the  MAP  was  applied. 
Spring 2017 was the first time the MAP served as the basis for the ICES advice for the fishing 
opportunities in the Baltic Sea. This means that there are only a few years that the MAP has 
been  fully  applied  to  establish  fishing  opportunities  in  the  Baltic  Sea.  This  is  a  too  short 
period  of  time  to  evaluate  and  make  conclusions  regarding  the  effectiveness  of  the  MAP. 
Against this background it is not possible to provide simplified answers without opening for 
misunderstanding and misinterpretation. This apply to both above questions as well as for the 
questions  below,  and  that  is  why  BALTFISH  instead  provide  comments  under  number  9 
instead.   

Regarding  question  6  and  7,  the  achievement  of  setting  TAC  for  the  relevant  stocks  can  be 
compared  both  to  the  objectives  in  the  CFP  and  to  the  TAC  process  before  the  MAP  was 
implemented.  The  MSY  ranges/TAC-setting  mechanism  in  the  MAP  has  facilitated  for  the 
MS  setting  TAC  according  to  the  CFP  by  referring  to  the  Fmsy  range,  hence  providing  the 
frame  within  all  set  fishing  opportunities  is  in  line  with  the  MSY  objective  in  the  CFP. 
However, BALTFISH considers one of the main contributing factor to setting TAC according 
to the MSY objectives is an analytical assessment in the ICES advice for the relevant stocks. 
Unfortunately, this has not been the case for all stocks (for example eastern Baltic cod) and 
the lack of such a key component has severely complicated the decision-making process and 

16 

 
 
discussions. Also, predictability of ICES advice is a main factor when it comes to good and 
constructive  negotiating  climate  when  setting  the  TAC  and  quotas.  Hence,  uncertainties 
between years in ICES advice makes the TAC and quota negotiating and communicating the 
TAC setting to the public more difficult. Big fluctuations in TAC levels between years have 
occurred. This is both a direct effect of the establishment in the reformed CFP of MSY as an 
objective as  well as  the results  of the following ICES  benchmarks for several  stocks. These 
big  fluctuations  have  not  provided  fishermen  and  the  processing  industry  with  the  wanted 
stability and have made it difficult for the industry to plan ahead and to have a steady income 
or steady inflow of raw material in the same way as the stability instrument in the previous 
management plan for cod in the Baltic Sea provided.  

8.   The MAP facilitates reaching the objectives of the CFP, however the implementation and 
utilization of the tools in the plan could be further increased. There has also been an increase 
of scientific investigations on the sensitive stocks during recent years.   

MAP does not address the influence of environmental and natural mortality factors, mixing of 
stocks and other aspects, which are beyond the impact of fisheries, but do affect the stocks. 
For  example,  dramatic  increase  of  natural  mortality  for  eastern  cod,  growth  of  seals 
population etc.  

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion  

Q10:  To  what  extent  have  discards  been  eliminated  and  the  landing  obligation  actually 
been implemented?  

No opinion 

Q11: To what extent has the MAP contributed to achieving the current situation, notably 
via discard plans and technical measures?  

No opinion 

Q12: free text 

10. The landing obligation was established by the Basic regulation (and not the MAP) and has 
gradually been implemented in the Baltic Sea between 2014 to be fully implemented as of 1 
January  2017.  The  quota  uplift  that  came  with  the  landing  obligation,  was  not  followed  up 
with  an  update  of  the  control  regulation  or  a  significant  increase  of  control  efforts/tools. 
Despite that the landing obligation in the Baltic Sea is now fully implemented and despite that 
the fishermen are now familiar with the new rules this has led to a continuous discard of for 
instance cod. The discard ratio varies much between the different fisheries. However, that the 
discards  have  not  been  eliminated  is  not  due  to  a  failure  of  the  MAP,  but  a  general 

17 

 
 
 
observation of the implementation of the CFP, the need for an updated control regulation and 
the need for better compliance with the rules by the fishermen. The problem with compliance 
for some fleet segments to comply with the LO is not specifically addressed within the MAP 
but  the  CFP  and  the  control  regulation.    Hence,  adapting  the  new  control  regulation  and 
pushing the adoption is of importance.    

It should also be noted that the first round of discard plans for the Baltic sea were already in 
place before the MAP entered into force 2016. Therefore, it is difficult to correlate the current 
situation  to  the  MAP  as  such  as  it  was  the  Basic  Regulation  which  served  as  the  legal 
background for the first discard plans.  

11. The MAP has opened a “fast track” for developing and allowing more selective gears and 
for  discard  plans  when  high  survivability  can  be  scientifically  documented.  However,  this 
possibility has just recently started to be implemented, as both the development and scientific 
testing of selective gears, as well as scientifically documenting high survivability takes time. 
Hence there is a time lag when it comes to the implementation. Apart from the delegated acts 
containing  discard  plans,  therefore  only  one  delegated  act  on  technical  measures  has  been 
adopted since the MAP entered into force to facilitate the landing obligation. The adoption of 
delegated act in accordance with the MAP is a time and work consuming exercise, but it has, 
when the initial time lag has passed, the potential to be a lot faster process than the alternative 
which is the co-decision procedure.  

Section 3 – Ecosystem-based approach  

Q13:  To  what  extent  has  the  objective  of  implementing  an  ecosystem-based  approach  to 
fisheries management, and notably of achieving good environmental status by 2020, been 
achieved?  

No opinion 

Q14: To what extent has the MAP contributed to the current situation?  

No opinion 

Q15: free text 

The  MSY-objective  contributes  to  the  achievement  of  GES  for  the  fish  stocks  in  the  Baltic 
Sea  and  minimize  negative  impact  of  fishing  activities.  STECF  has  seen  a  positive  trend 
towards  MSY  for  the  stocks.  However,  we  will  not  reach  GES  for  all  stocks  in  2020.  The 
MAP can contribute to the achievement of GES and the status of the fish stocks by setting F 
within the Fmsy range. However, several other factors besides fisheries affect the stocks other 
than F. These factors are not included in the MAP even though it is clear, including from the 
latest  ICES  advice  for  the  eastern  cod  stock,  that  other  factors  apart  from  fishing  activities 
have a great influence on stock development. In addition, TAC can be set according to Fmsy 

18 

 
 
 
if the ICES advice is based on an analytical assessment. It is very difficult to set a “correct” 
TAC if the data is of poor quality.  

Ecosystem  based  management  of  fisheries  is  essential  in  order  to  restore  fish  stocks.  The 
ecosystem-based  approach  has  however  not  yet  materialised  for  the  Baltic  Sea.  The  ICES 
advice  does  not  take  inter-species  interaction  into  account  as  well  as  other  factors.  Other 
factors  as  for  example  lack  of  feeding,  low  benthic  level,  low  salinity  and  oxygen  and  a 
growing number of grey seals are not addressed in a holistic way. The main focus is still the 
annual quantities in terms of TAC/quotas. Some MS has started implementing strategies for 
ecosystem  based  management  of  fisheries.  Some  initiatives  in  this  work  are  already  under 
way, e.g. regulation of fishing activities in MPAs. The aim is to highlight Ecosystem Based 
Management  of  fisheries  more  than  before  in  the  ongoing  up-date  of  the  Programme  of 
measures for the MSFD, which will be published in 2021/2022. But, there are still unsolved 
issues, e.g. harmonization of TAC with environmental objectives defined by MSFD and how 
to  deal  with  questions regarding sea bottom  integrity  and hypoxic areas.  Without  MAP, the 
situation of fish stocks in the Baltic Sea would probably be worse. But, there is more to do be 
done in terms of taking other activities and pressures into consideration as eutrophication and 
climate  change.  BALTFISH  has  taken  initiatives  to  ask  advice  from  ICES  regarding  a 
possible  spatial  management  plan  for  sprat  to  protect  cod.  However,  the  work  of  ICES  and 
collection  of  data  will  take  time.  MAP  could,  apart  from  gear  development,  not  address  the 
recent  rapid  increase  in  the  grey  seal  population  and  their  impact  on  fish  stocks  such  as 
salmon,  cod  etc.  and  the  MAP  cannot  more  than  marginally  mitigate  the  increasing 
fishermen/seal  conflict.  The  MAP  cannot  address  effects  on  the  ecosystem  apart  from 
fisheries.   

Another  factor  is  that  the  Russian  Federation  is  also  fishing  on  these  stocks.  However,  the 
Russian Federation is not regulating its fishing opportunities according to the same objectives 
or the MAP. This affects the stocks in question.  

Section 4 – Control enforcement  

Q16:  To  what  extent  have  the  specific  provisions  laid  down  in  the  MAP  (Articles  10-14) 
allowed the national competent authorities to ensure compliance with the MAP itself?  

No opinion 

Q17:  Are  there  specific  control  measures  that  contributed  substantially  to  improve 
compliance?  

The control provisions contained in the MAP are very few.  

However, some MS considers that Article 11-12 has substantially improved the possibility to 
monitor  and  inspect  smaller  vessels.  The  prior  notification  for  fishing  vessels  of  an  overall 

19 

 
 
 
length  of 8 metres or more retaining on board at least  300 kg of cod or 2 tonnes of pelagic 
stocks and designated ports for fishing vessels that have on board 750 kg of cod and 5 tonnes 
of pelagic species is seen as having improved compliance. In addition, by means of Article 14 
the  planning  and  organization  of  inspection  activities  have  been  improved.  The  landing 
obligation is not controlled by the MAP. The compliance of the LO is an important part of the 
achievement  of  MSY  which  is  an  important  part  of  the  MAP.  Some  MS  appreciates  the 
inclusion of a bulk provision, cf. Article 13. In the meantime, uncertainties with respect to the 
scope and understanding of this Article has since the MAP entered in  to  force  given  rise to 
different  interpretations.  The latest  Commission  interpretation  implies that  the tolerance can 
only  be  applied  for  the  total  unsorted  catch  and  not  in  relation  to  the  single  species  of  the 
catch  with  the  result  that  competent  authorities  have  difficulties  with  enforcement.  A 
horizontal  solution  that  is  possible  for  fishermen  to  comply  with  and  that  is  enforceable  is 
recommended.  Apart  from  this,  in  general  it  is  considered  that  the  measures  in  the  MAP 
contribute to ensure compliance and controllability.   

Some  MS  have  drawn  up  additional  measures  in  National  Plans  of  Control  for  2019.  The 
objective is to strengthen the control and inspection of stocks of pelagic and demersal species 
in  the  Baltic  Sea.  In  order  to  optimize  the  use  of  control  measures,  a  risk  analysis  is  used, 
which  allows  defining  the  preferred  directions  of  control  activities.  The  participation  of 
national inspectors in Baltic inspection campaigns coordinated by the EFCA is another factor 
that increases the effectiveness of inspections. 

Q18:  Are  there  specific  control  measures  that  have  instead  not  contributed  to  improve 
compliance?  

The  derogation  from  Article  14.3  (EU)  1224/2009  (Article  13)  as  applied  in  the  second 
interpretation by the European Commission is considered too lenient and allows for fishermen 
to  report  large  discrepancies  between  herring  and  sprat  in  the  logbook  without  being 
sanctioned.  The  European  Commission’s  first  interpretation  was  working  for  most  Member 
States.  Furthermore,  due  to  the  wording  of  the  legal  provisions,  the  Baltic  Member  States 
have  interpreted  the  margin  of  tolerance  in  the  logbook,  cf.  Article  13,  differently  and  the 
provision  is  currently  not  implemented  in  the  same  way  in  the  Member  States  preventing  a 
level playing field. 

Q19:  Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control 
Regulation which would improve compliance with the MAP?  

Overall,  BALTFISH  prefers  to  have  as  many  of  the  general  control  measures  as  possible 
contained in the Basic Control Regulation to facilitate level playing field in the EU.   

The  inclusion  of  a  legal  basis  for  implementing  provisions  or  guidance  stipulating  how 
sampling should be arranged in the small mesh size fisheries could be contemplated as they 
are missing in the technical conservation measures and therefore making inspections and the 
follow up less homogenous across the different Member States. For the North Sea Regulation 

20 

 
 
(EC)  No  954/87  applies  and  this  could  also  work  for  the  Baltic  Sea  and  could  be  further 
discussed.  

Some  MS  highlighted  that  electronic  reporting  for  all  types  of  activities  (logbook,  landing 
declaration,  transport  document  etc.)  would  increase  effectiveness  and  controllability  of  the 
fisheries  system.  Some  MS  highlighted  that  fully  documented  fisheries  including  CCTV  and 
sensors could be a useful mean to ensure compliance with the landing obligation, ensure data 
quality and hence improve compliance with the MAP. This is currently discussed within the 
framework  of  the  Council  Working  Group  under  the  Commission  proposal  to  amend  the 
Control Regulation, and the views among MS differ.  

Section 5 – Regional cooperation  

Q20: On  regional  cooperation, to  what  extent has the MAP in your opinion strengthened 
regional cooperation, including with stakeholders?  

No opinion 

Q21: free text 

The  BALTFISH  cooperation  was  established  long  before  MAP  entered  into  force  and 
BALTFISH  main  objective  was  sustainable  management  of  all  commercially  exploited 
species and to strengthened regional cooperation around the Baltic Sea. The management and 
the  regional  cooperation  round  the  Baltic  Sea  has  developed  and  is  still  developing  in  a 
positive  direction.  There  are  still  room  for  improvement,  like  for  example  how  joint 
recommendations can be developed in the most efficient way and with the quality needed for 
the  Joint  recommendation  later  could  be  adopted  as  a  delegated  act  by  the  Commission. 
Overall, it is going in the right direction.   

The  MAP  establishes  the  legal  basis  for  the  Commission  to  adopt  regulations  in  terms  of 
Delegated  Acts  with  regard  to  the  landing  obligation  as  well  as  to  technical  measures.  The 
thinking  behind  this  decision  making  procedure  is  to  find  regional  solutions  to  regional 
conditions  which  also  means  that  initiatives  in  these  fields  should  originate  in  a  regional 
context.   

The  regional  cooperation  operates  beyond  formal  structures  and  it  seems  that  adoption  of 
delegated act in accordance with the MAP is a time, work and resource consuming exercise. 
Operating in a regional context should to a greater extent be facilitated by the Commission in 
order to conclude recommendations (and the intended delegated acts) successfully and within 
a reasonable timeframe.  

There  is  room  for  improvement,  and  also  room  for  more  focused  work  on  JR  (coordinated 
with  STEC  meetings  and  CION  deadlines).  The  lack  of  formal  structures,  including  clear 

21 

 
 
  
timeframes etc. are some of the main reasons that the MAP has proven inadequate to advance 
regionalisation.    

The MAP per se has not been the driving force behind the regional cooperation.    

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion  

Q22:  Has  the  overall  socio-economic  situation  of  the  fisheries  sector  improved  since  the 
entry into force of the MAP?  

No opinion 

Q23:  Do  you  see  a  positive  correlation  between  the  implementation  of  the  MAP  and  the 
socio-economic situation of the fisheries sector?  

No opinion 

Q24: free text 

The current stock situation in the Baltic Sea with several very important stocks (both eastern 
cod  and  western  herring)  in  an  extremely  bad  condition,  have  a  large  impact  on  the  socio-
economic situation for the fisheries sectors around the Baltic Sea. The ICES advice for above 
mentioned  stocks  for  2020  and  the  measures  that  will  follow  may  result  in  an  even  worse 
situation for the fisheries sector and the coastal communities in future years. Given the stock 
situation,  it  is  however  difficult  to  see  that  the  MAP  as  such  could  have  contributed  to  a 
positive socio-economic development under these circumstances.    

However,  the  plan  has  under  certain  circumstances  allowed  for  utilizing  FmsyUpper  for 
socioeconomically  reasons,  and  some  MS  has  used  Article  17  of  the  MAP  as  the  basis  to 
support  their  fleet.  This  might  have  dampened  the  economic  effects  of  some  fishermen. 
BALTFISH sees that the possibility to in certain cases use FmsyUpper, but still reach MSY a 
useful tool in this MAP.  

However, given the many factors, which have an influence on the stock development, it is not 
possible  to  quantify  the  effect  of  a  single  management  element.  We  believe  it  is  the  stock 
situation as such which has the greatest socioeconomic impact. However, we also believe that 
the MAP has strengthened the awareness of the stock situation and to a certain extent given a 
clear  signal  for  the  scope  of  manoeuvre.  The  MAP  in  its  nature  does  not  adequately 
incorporate the ecosystem approach.   

22 

 
 
 
 
 
Section 7 – Overall assessment   

Q25: What is your overall assessment of the Baltic MAP?  

No opinion 

Q26: free text 

In  general,  it  is  too  early  to  evaluate  the  effect  of  the  MAP  with  respect  to  many  of  the 
parameters contained in the questionnaire. The MAP only came into force in July 2016, and 
bearing in mind that the advice given for 2017 was not based on the MAP, we only have 2018 
and 2019 as reference years for the stock situation where ICES applied the MAP as the basis 
for  its  advice.  BALTFISH  believes  that  the  MAP  contains  the  potentials  to  become  a  more 
important instrument for fisheries management. Again, the MAP has been in force for a very 
short  period  of  time,  which  makes  it  difficult  to  assess  the  effects  on  fish  stocks,  the 
socioeconomic impact and the ecosystem approach.  

The  MAP  has  been  helpful  when  setting  TAC  when  there  is  an  analytical  assessment.  It  is 
also an appropriate legal base for regional cooperation and development within the framework 
of the CFP. It contains all the elements for adapting technical measures (e.g. developing more 
selective gear) and other provisions linked to the LO, safeguards of sensitive stocks, and TAC 
regulating  mechanisms.  Thus, BALTFISH sees the plan as  a useful tool, which  contains  all 
the elements needed in reaching the objectives in Article 3 of the MAP.   

23 

 
 
 
 
 
7.3. Association of Fisheries Protection (Germany) 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP MSY is to be achieved for all relevant stocks by 2020. 8 of the stocks 
covered by the MAP are managed by TACs, of which 7 receive an analytical assessment by 
ICES  (6  target  TAC,  and  one  by-catch  TAC).  Out  of  these  7  TACs  the  TACs  for  3  stocks 
were at MSY in 2016, and for 6 stocks as of 2017. In your opinion 

Q6: Has the existence of a MAP facilitated the process of setting of TACs for the relevant 
stocks?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q7:  To  what  extent  has  the  MAP  contributed  to  increasing  the  number  of  TACs  set  at 
MSY?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q8: Has the MAP helped in dealing with difficult cases such as Eastern and Western Baltic 
cod, Western herring or other sensitive stocks? 

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q9: free text 

The  effectiveness  to  set  TACs  in  connection  with  MSY  was  undermined  by  too  many 
unreported  discards  in  the  trawl  fishery.  Unfortunately  due  to  pressure  from  the  industrial 
fisheries, some spawning closures were not properly implemented and the effects could not be 
checked by scientists, because on a lack of time to do so.  

24 

 
 
Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion  

Q10:  To  what  extent  have  discards  been  eliminated  and  the  landing  obligation  actually 
been implemented?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q11: To what extent has the MAP contributed to achieving the current situation, notably 
via discard plans and technical measures?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q12: free text 

The difference between  reported and  actual discards in  the trawl fishery is  a disaster. (True 
figures:  20-30  %,  against  reported  0,2-0,7%)  This  situation  is  wellknown  and  nothing  has 
been done over the last 4 years to try and change that situation. Technical measures like the 
decreasing of the mesh size from 120mm to 110 mm was counterproductive to the health of 
the cod stock.  

Section 3 – Ecosystem-based approach  

Q13:  To  what  extent  has  the  objective  of  implementing  an  ecosystem-based  approach  to 
fisheries management, and notably of achieving good environmental status by 2020, been 
achieved?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  

25 

 
 
 
•  No opinion  

Q14: To what extent has the MAP contributed to the current situation?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q15: free text 

The fishing pressure is still far too high in particular on spawning concentrations of cod. The 
landing obligation is only theoretically in force.  

Section 4 – Control enforcement  

Q16:  To  what  extent  have  the  specific  provisions  laid  down  in  the  MAP  (Articles  10-14) 
allowed the national competent authorities to ensure compliance with the MAP itself?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q17:  Are  there  specific  control  measures  that  contributed  substantially  to  improve 
compliance?  

Mostly the inspection at sea would be announced by radio in prior. So the situation they found 
aboard is not the situation. 

Q18:  Are  there  specific  control  measures  that  have  instead  not  contributed  to  improve 
compliance?  

See above. 

Q19:  Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control 
Regulation which would improve compliance with the MAP?  

Sure!  Implement genuine control measures on the real  engine power in  the trawl fishery by 
energy balance.  

26 

 
 
 
Section 5 – Regional cooperation  

Q20: On  regional  cooperation, to  what  extent has the MAP in your opinion strengthened 
regional cooperation, including with stakeholders?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q21: free text 

Because of the majority of the “Fish Industry” in the ACs. So the advising is mostly one-sidet.    

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion  

Q22:  Has  the  overall  socio-economic  situation  of  the  fisheries  sector  improved  since  the 
entry into force of the MAP?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q23:  Do  you  see  a  positive  correlation  between  the  implementation  of  the  MAP  and  the 
socio-economic situation of the fisheries sector?  

•  Significantly 
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive/significantly negative  
•  No opinion  

Q24: free text 

See points above.   

27 

 
 
 
Section 7 – Overall assessment   

Q25: What is your overall assessment of the Baltic MAP?  

•  Very beneficial  
•  Beneficial  
•  Neutral  
•  Negative  
•  Very negative  
•  No opinion  

Q26: free text 

Because the situation does not change better during the last 25 years. (please see below)  

28 

 
 
  
  
 
 
Success  analysis  of  the  GFP  from  the  point  of  view  of  the  Fisheries  Protection 
Association whose members only fish with passive gears.  

(response  to:  Com  Questionnaire  received  by  mail  from  9th  of  May  2019  by  Wolfgang 
Albrecht, chairmen of Ass. of Fisheries Protection )  

Whereas  fisheries  in  the  past,  especially  with  towed  gears,  used  to  be  seasonally  and 
locally limited, today there is a constant fishing on all catchment areas wherever the fish 
is found to be economically viable.   

The fishing intensity of passive fishing gear for sure has also increased. However due the 
better  selectivity  of  the  fishing  gear,  it  was  not  able  to  burden  the  Stock  in  such  a 
decisive way. In fisheries with towed gear, however, the situation is completely different.  

No  more  excuses  please!  Urgent  need  for  action  to  stabilize  the  cod stock  in  the Baltic 
Sea and rescue the eastern cod stock!  

Closed spawning season for cod in the Baltic Sea, a means of securing the stock?  

The  members  of  Fisheries  Protection  Association  Schleswig-Holstein  is  extremely  worried 
about the state of cod stocks in the Baltic Sea and the eastern cod stock in particular and sees 
an urgent need for action. The demonstration of Polish small-scale fishermen that took place 
in Warsaw on 27 February shows that we are not alone in expressing these concerns.  

We welcome the written request  of the DG Mare from  27.2. 2019 (Annex) to  the BSAC to 
deal  with  the  problem  and  make  proposals  for  remedial  action.  I  would  like  to  add  the 
following statement to the response given by the BSAC of 22.3.2019 (attached).  

Review   

General Summary 

The  intensification  of  trawling  on  cod  spawning  concentrations  from  1980  onwards,  in 
particular  in  zones  25-32,  combined  with  an  increase  in  fishing  effort  by  stationing  factory 
vessels at BORNHOLM, the use of twin trawls and heavy rock hopper gear combined with an 
increase in  engine power in  trawling  has led to  a significant  increase in  catches which, it is 
now to be noted, could not be safely compensated by the natural reproductive capacity of the 
stock. After a peak in the amount of landing in 1984 of 420,000 tonnes of cod, which still had 
at least 30% unrecorded discards, landings in the following years continued to decline. From 
our point of view, this  clearly shows overfishing of the stock with the well-known negative 
consequences in the form of repeated cod crises, which the "industry" does not want to admit, 
but which cannot be dissuaded away.   

The following graphic provides a good overview according to figures from the ICES   

29 

 
 
 
 
 The  suspension  of  the  fishery  closure  during  the  spawning  period  for  the  year  2019  in  the 
area 22-24 due to the demands from the "industry", which they deemed unnecessary because 
of the presence of the strong 2016 year class, is from our view as counterproductive. There is 
certainly  evidence  of  beneficial  effects  of  fishery  closure  during  spawning  times. 
(Attachment)  Here  was  a  unique  opportunity  to  deepen  these  findings  and  to  scientifically 
investigate the effects of a temporary closure during spawning time.  

However, this requires a period of at least 5 years. Unfortunately, this did not happen.   

Situation analysis   

The  cod  stock,  which  for  the  above  mentioned  reasons  is  on  an  average  at  a  too  low  level, 
which also has no healthy age group composition - and this applies equally to all stocks - is 
now  additionally  exposed  to  environmental  influences  over  which  the  fishery  has  no 
influence, such as:   

•  At  times  too  low  Salinity  of  the  water  (inflows  from  the  North  Sea)  with  strong 

negative impacts on reproduction   

•  Lack of oxygen, and the resulting lack of food (small crabs) for juvenile cod.   
•  Weak  food  supply  due  to  removals  by  pelagic  trawl  fisheries  for  herring,  sprat  and 

sand eel  

•  High water temperatures due to climate change   
•  Strongly increasing seal population and associated parasites (liver worms) causing cod 

growth disorders (anorexia).   

However, that does not mean that there is no need for action when it comes to fishing effort - 
on the contrary.   

30 

 
 
  
Complementary action proposal   

Together  with  LIFE,  the  Europe-wide  organization  representing  small-scale  fishers, 
comprising  31  small-scale  low  impact  fishing  organizations  from  15  Member  States  of  the 
EU, representing the interests of more than 10,000 members, I would also ask  you for their 
support on behalf of the members of the Fisheries Protection Implementation of the following 
measures:   

•  The  creation  of  a  biological  rest  for  the  cod  in  areas  25-26  by  the  extension  of  the 

spawning period from 1 May to 30 September, this year.  

•  The complete closure of these areas during this period for fishing with active fishing 

gear.  
shifting these fishing activities to fishing areas further north.   

• 
•  The reintroduction of the fisheries closure during the spawning season from 1 January 
to 30 March in areas 22-24 for fishing with towed gears beyond the 20 m depth line.  

•  Abolition of rock hopper fishing for the protection of rocky grounds and reefs.  

•  Limiting engine power in trawling to 221 kW in the exclusive economic zones of the 

Member States (minimum 12 nm from the coastline)  
•  Review of engine performance through energy balance  
•  Shortening the permitted net lengths in passive fisheries by 50% during the spawning 

• 

period of the cod.  
cessation of fishing for flatfish with towed gear during the spawning season on the one 
hand  not  to  disturb  the  spawning  concentrations  of  the  cod,  on  the  other  hand  to  an 
increase in quality of the landed flatfish.  

31 

 
 
 
  
These fish have a miserable quality, and will scare off the customers who have never bought 
such  fish  out  of  ignorance.  In  addition,  it  is  economic  nonsense  to  fish  for  fish  full  of  roe. 
However, delaying flatfish fisheries until the summer months starting in July guarantees top 
quality products that can be traded at good prices.   

•  Compensation  of  hardship  through  temporary  financial  support  of  the  vehicles 

concerned from the EMFF.   

And research into the effects of active fishing during the spawning season of the cod on the 
reproduction  rates,  taking  into  account  the  results  of  existing  studies.  To  prevent  a 
Newfoundland  Scenario,  it  is  time  to  act  now.  For  restrictions,  the  polluter  pays  principle 
must be taken into account. A possible total cessation of fishing for the eastern stock leads to 
a  shift  of  fisheries  to  the  western  Baltic  Sea.  Computing  acrobatics  has  always  generated 
corresponding  quota  shares,  which  means  that  the  next  crisis  is  inevitable.  That  is  why  we 
prefer  action  from  fisheries  practice,  and  make  concrete  proposals  to  improve  the  situation 
with respect to such nicely worded documents without any real substance, which have so far 
not been particularly effective.  Yours sincerely  

(Wolfgang Albrecht, Chairmen)  

(To avoid misunderstandings please find the original text in Germen below)  

32 

 
 
 
  
  
  
  
  
  
  
 
 
Dringender Handlungsbedarf für eine Stabilisierung des Dorschbestandes in der Ostsee 
und die  

Rettung  des  östlichen  Dorschbestandes 
gemeinsamen Fischereipolitik!  

im  Rahmen  einer  Neuausrichtung  der 

Laichschonzeiten für Dorsch in der Ostsee, ein Mittel zur Bestandssicherung ?  

Nicht  erst  im  Jahre  2019  blickt  der  Fischereischutzverband  Schleswig-Holstein  mit  großer 
Sorge auf den Dorschbestand in  der Ostsee. Ausgegebener  Veranlassung speziell  durch den 
östlichen  Dorschbestand  dessen  Situation  dringenden  Handlungsbedarf  erfordert,  um  einen 
totalen  

Zusammenbruch  zu  verhindern.  Dass  wir  mit  dieser  Sorge  nicht  allein  dastehen  zeigt  die 
Demonstration der polnischen Kleinfischer in Warschau vom 27.2.2019   

Wir  begrüßen  die  schriftliche  Aufforderung  der  DG  Mare  vom  27.2.  2019  (Anlage)  an  den 
BSAC  sich  mit  dem  Problem  auseinanderzusetzen  und  Vorschläge  zur  Abhilfe  zu 
unterbreiten.  Der  Antwort    des  BSAC  vom  22.3.2019  (Anlage)  erlaube  ich  mir  zur 
Konkretisierung von Maßnahmen nachfolgende Stellungnahme hinzuzufügen.    

Allgemeine Zusammenfassung 

Rückblick  

Wurde  die  Fischerei  vor  allem  mit  gezogenen  Fanggeräten  früher  saisonal  und  örtlich 
begrenzt  betrieben, so ist heute von einer ständigen auf alle Fanggebiete ausgedehnten 
Befischung  auszugehen  wo 
in  einer  wirtschaftlich 
erfolgversprechenden Menge zeigt.  

sich  der  Fisch 

immer 

Auch in der stillen Fischerei hat die Fangintensität zugenommen. Dies konnte aber auf 
Grund der dort herrschenden besseren Selektivität der Fanggeräte, den Bestand nicht in 
entscheidender Weise negativ beeinflussen. In der Fischerei mit gezogenen Fanggeräten 
stellt sich die Situation dagegen völlig anders dar.  

Die  Intensivierung  der  Schleppnetzfischerei  auf  die  Laichkonzentrationen  des  Dorsches  ab 
1980 insbesondere in den Gebieten 25-32 verbunden mit einer Erhöhung des Fangaufwandes 
durch  die  Stationierung  von  Fabrikschiffen  bei  BORNHOLM,  die  Verwendung  von  Twin 
Trawls und schweren  

Rollergeschirren, der entscheidenden Verbesserung der elektronischen Ortungsmöglichkeiten 
von Fischen, verbunden mit einer Erhöhung der Motorleistungen in der Schleppnetzfischerei 
haben    zu  einer  erheblichen  Steigerung  der  Fangmengen  geführt,  die,  wie  man  jetzt  zur 
Kenntnis  zu  nehmen  hat,  nicht  sicher  durch  die  natürliche  Reproduktionsfähigkeit  des 
Bestandes  ausgeglichen  werden  konnten.  Der  Durchschnitt  der  Anlandemengen  lag  vorher 

33 

 
 
  
 
über eine lange Zeitspanne bei ca. 170.000 Tonnen. Nach einer Spitze der Anlandemenge im 
Jahre  1984  von  420.000  Tonnen  Dorsch  der  noch  mindestens  30%  nicht  registrierte 
Rückwürfe hinzuzurechnen sind, sanken die  

Anlandungen in den Folgejahren kontinuierlich ab. Dies zeigt aus unserer Sicht ganz deutlich 
eine  

Übernutzung  des  Bestandes  mit  den  bekannten  negativen  Folgen  in  Gestalt  wiederholter 
Dorschkrisen. Die vorstehenden Fakten, die die „Industrie“ zwar nicht wahrhaben will, lassen 
sich aber nicht seriös wegdiskutieren. Die Zeiten: „Höher, schneller , weiter sind auch in der 
Fischerei endgültig vorüber.  

Einen  guten  Überblick  schafft  die  nachfolgende  Grafik  nach  Zahlen  des  ICES  zur 
Verdeutlichung der Situation.   

Die Aussetzung der ungeliebten Laichschonzeit für das Jahr 2019 im Gebiet 22-24 aufgrund 
der  Forderungen  aus  der  „Industrie“,    die  wegen  des  Vorhandenseins    des  einen  starken 
Jahrganges 2016 als unnötig hingestellt wurde, ist aus unserer Sicht als kontraproduktiv zu 
bezeichnen.  Anzeichen  für  eine  positive  Wirkung    von  Laichschonzeiten  sind  durchaus 
vorhanden. Hier bestand die einmalige Chance diese Erkenntnisse weiter zu vertiefen und die 
Wirkung  von  zeitlichen  Laichschonzeiten  wissenschaftlich  zu  untersuchen.  Hierzu  ist 

34 

 
 
  
allerdings  ein  Zeitraum  von  mindestens  5  Jahren  erforderlich.  Dazu  kam  es  aufgrund  der 
Intervention aus der Schleppnetzfischerei leider nicht.  

Situationsanalyse  

Der aus vorgenannten Gründen auf einem durchschnittlich zu niedrigem Level befindliche  

Dorschbestand, der auch keine gesunde Altersklassen Zusammensetzung aufweist  – und das 
gilt für alle Bestände gleichermaßen, ist nun zusätzlich Umwelteinflüssen ausgesetzt, auf die 
die Fischerei keinen Einfluss hat, wie:  

•  Zeitweise zu geringer Salzgehalt des Wassers (Einströme aus der Nordsee) mit starken 

Reproduktionseinbrüchen.  

•  Sauerstoffmangel, und das dadurch fehlende Nahrungsangebot an Kleinkrebsen für die 

juvenilen Dorsche.  

•  Schwaches  Nahrungsangebot 

durch 

die 

Entnahmen 

der 

pelagischen 

Schleppnetzfischerei auf Hering, Sprotte und Sandaal   
•  Hohe Wassertemperaturenaufgrund des Klimawandels  
•  Einer stark zunehmenden Seehundpopulation   

und  der  damit  einhergehenden  Belastung  durch  von  Seehunden  verbreiteten  Parasiten, 
(Leberwürmern) welche zu Wachstumsstörungen (Magersucht) beim Dorsch führt.  

Nahrungsmangel    durch  die  industrielle  Befischung  von  Sprotten  und  Sandaalen 
verstärkt  den  negativen  Effekt  zusätzlich.  Das  bedeutet  allerdings  nicht,  dass  sich  die 
Fischerei beruhigt zurücklehnen kann und das beim Fangaufwand durch die Fischerei 
kein Handlungsbedarf besteht - ganz im Gegenteil.  

Aufgrund  der  bisher  nicht  messbar  eingetretenen  Verbesserung  und  vor  allem  einer 
dringend  nötigen  Stabilisierung  der  Bestandssituation  beim  Dorsch  ergibt  sich  aus 
unserer Sicht nachfolgender ergänzender Aktionsvorschlag.  

Gemeinsam mit LIFE der europaweiten Vertretung der Kleinfischerei, der 31 Organisationen 
der  Kleinfischerei  mit  passiven  Fanggeräten  aus  15  Mitgliedsstaaten  der  EU  angehören  und 
ich  die 
damit  die 
Entscheidungsträger  auch  im  Namen  der  Mitglieder  des  Fischereischutzverbandes  um 
Unterstützung für die Durchführung von folgenden Maßnahmen:  

Interessen  von  mehr  als  10.000  Mitgliedern  vertreten,  bitte 

•  Noch in diesem Jahr  die Schaffung einer biologischen Ruhepause für den Dorsch in 
den  Gebieten  25-26  durch  die  Ausdehnung  der  Laichschonzeit  vom  1.  Mai  bis  30. 
September.  Die  komplette  Schließung  dieser  Gebiete  während  dieser  Zeit  für  die 
Fischerei mit aktiven Fanggeräten.  

•  Verlagerung dieser Fischereiaktivitäten in weiter nördlich gelegene Fanggebiete.  

35 

 
 
 
•  Die  Wiedereinführung  der  ausgesetzten  Laichschonzeit  vom  1.  Januar  bis  zum 
30.März in den Gebieten 22-24 für die Fischerei mit gezogenen Fanggeräten jenseits 
der 20 m Tiefenlinie.  

•  Abschaffung der Rollerfischerei zum Schutz von Steingründen und Riffen.  

•  Begrenzung  der  Motorleistung  in  der  Schleppnetzfischerei  auf  221  KW  in  den 
ausschließlichen  Wirtschaftszonen  der  Mitgliedsstaaten  (Minimum  12  sm  von  der 
Küstenlinie)  

•  Überprüfung  und  Kontrolle  der  Motorleistungen  in  der  Schleppnetzfischerei  durch 

Energiebilanz  

•  Verkürzung der erlaubten Netzlängen in der passiven Fischerei um 50 % während der 

Laichschonzeit des Dorsches.  

•  Einstellung  der  Fischerei  mit  gezogenen  Fanggeräten  auf  Plattfische  während  der 
Laichzeit  einerseits  um  die  Laichkonzentrationen  des  Dorsches  nicht  zu  stören, 
andererseits zu einer Qualitätssteigerung der angelandeten Plattfische.  

Diese Fische weisen eine miserable Qualität auf, vergraulen die Kunden, die jemals aus  

36 

 
 
  
 
  
   
 
Unwissenheit  solchen  Fisch  gekauft  haben.  Außerdem  ist  es  ökonomischer  Unsinn  Fische 
voller  

Rogen gezielt zu fangen. Durch eine Verlegung der Plattfisch Fischerei in die Sommermonate 
ab  Juli  lassen  sich  dagegen  Spitzenqualitäten  garantieren,  die  zu  guten  Preisen  gehandelt 
werden können.  

•  Kompensation  von  Härten  durch  eine  zeitweilige  finanzielle  Unterstützung  der 

betroffenen Fahrzeuge aus Mitteln des EMFF.  

und  die  Erforschung  der  Störwirkungen  durch  die  aktive  Fischerei  während  der 
Laichzeit des Dorsches auf die Reproduktionsraten unter Einbeziehung der Ergebnisse 
bereits vorhandener Studien.  

führt  zu  einer  Verlagerung  der  Fischerei 

Um ein „Neufundland Scenario in den Gebiete 25 – 26 zu verhindern ist es an der Zeit 
jetzt  sofort  zu  handeln.  Hierzu  ist  bei  Restriktionen  das  Verursacherprinzip  zu 
berücksichtigen  und  anzuwenden.  Ein  möglicher  totaler  Fangstopp  für  den  östlichen 
Bestand 
in  die  westliche  Ostsee. 
Rechenakrobatik  generierte  bisher  immer  entsprechende  Quotenanteile  wodurch  auch 
hier  die  nächste  Krise  vorprogrammiert 
ist  die  gesamte 
Dorschfischerei in der Ostsee zu überdenken, immer wiederkehrende Krisensituationen 
mit  all  ihren  wirtschaftlichen  Nachteilen  zu  vermeiden.  Deshalb  sollten  aus  der 
Fischereipraxis kommende Abhilfe Maßnahmen zur Anwendung kommen, die natürlich, wie 
alle Maßnahmen einer  

ist.  Darüber  hinaus 

Erfolgskontrolle zu unterziehen sind. Wir machen konkrete Vorschläge zur Verbesserung der 
Situation  gegenüber  solchen  in  schöne  Worte  gefassten  Dokumenten  ohne  wirkliche 
Substanz, die sich auch bisher nicht durch besondere Wirksamkeit ausgezeichnet haben.  

Mit freundlichen Grüßen  

Wolfgang Albrecht, erster Vorsitzender Fischereischutzverband Schleswig-Holstein.   

37 

 
 
  
  
   
 
7.4. Clean Coalition Baltic 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP MSY is to be achieved for all relevant stocks by 2020. 8 of the stocks 
covered by the MAP are managed by TACs, of which 7 receive an analytical assessment by 
ICES  (6  target  TAC,  and  one  by-catch  TAC).  Out  of  these  7  TACs  the  TACs  for  3  stocks 
were at MSY in 2016, and for 6 stocks as of 2017. In your opinion 

Q6: Has the existence of a MAP facilitated the process of setting of TACs for the relevant 
stocks?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q7:  To  what  extent  has  the  MAP  contributed  to  increasing  the  number  of  TACs  set  at 
MSY?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q8: Has the MAP helped in dealing with difficult cases such as Eastern and Western Baltic 
cod, Western herring or other sensitive stocks? 

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q9: free text 

The  MAP,  through  the  regionalisation  process  in  Baltfish,  help  the  process  of  setting  a 
regional agreement on TAC have only happened once.  

38 

 
 
 
MAP  has  not  help  in  dealing  with  difficult  cases  such  as  Eastern  and  Western  Baltic  cod, 
Western herring or other sensitive stocks. The specified ranges is more or less what has been 
used and they have created confusion more than clarity on what F is called for etc. 

Concretely, the MAP has not helped in setting TAC following ICS advice and for EBC that 
advice  has  been  neglected  by  the  council  more  or  less  constantly  since  2013,  and  in  some 
cases not helped by the EC very poor TAC proposals.  

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion  

Q10:  To  what  extent  have  discards  been  eliminated  and  the  landing  obligation  actually 
been implemented?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q11: To what extent has the MAP contributed to achieving the current situation, notably 
via discard plans and technical measures?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q12: free text 

Discarding is significant in several fisheries, in particular for eastern cod and plaice.  

For  eastern  cod  discarding  is  “up  to  50-70%  according  to  information  from  the  fishing 
industry instead of the 10-20% estimated by ICES” (ICES WKCONGA 2018 p.36). In actual 
cod numbers, it is over 10 million fish. STECF, when evaluating LO, has noted that more or 
less  nothing  has  changed.  In  the  2018  ICES  advice  for  plaice,  estimated  discards  were 
“approximately 38.6%” and this is likely underestimated. 

Discards  have  also  persisted  in  the  western  cod  fishery  with  negligible  landings  of  Below 
Minimum Size fish but it less of an issue compared to EBC and plaice. 

39 

 
 
 
However, the MAP itself is not the only thing at fault here. The trawl gears in use have not 
and  are  not  in  any  way  fit  for  purpose  and  limiting  technical  rules  is  a major  problem.  Not 
only  are  current  gear  unfit  for  purpose,  they  should  actually  have  been  banned  instead  of 
pushed forward as the only usable gears. 

The  persistent  and  high  levels  of  illegal  discarding  clearly  indicate  that  control  and 
enforcement  has  thus  far  been  insufficient  in  enabling  the  implementation  of  the  landing 
obligation. The MAP has clearly not helped in this regard.  

Section 3 – Ecosystem-based approach  

Q13:  To  what  extent  has  the  objective  of  implementing  an  ecosystem-based  approach  to 
fisheries management, and notably of achieving good environmental status by 2020, been 
achieved?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q14: To what extent has the MAP contributed to the current situation?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q15: free text 

MAP does not support to take inter species interactions into account. For example there is no 
MAP provision which would support decision makers to follow the repeated ICES advice to 
redirect  sprat  fishery  to  northern  areas  of  the  Baltic  Sea  (to  SDs  27,28)  in  order  to  secure 
enough  of  food  for  Baltic  cod  in  its  area  of  distribution.  CCB  notes  as  counterproductive 
because the MAP has rather been in the way of the GES objective and finding ways to handle 
evidence/advice in relevant way. ICES ecosystem and fisheries overviews give lots of insights 
but all the MAP has done is keep focus on TAC for single species. 

Besides Article 3.3. (Objectives) itself the MAP does not have any provision allowing for real 
implementation of the EBM or achievement of good environmental status (GES) by 2020.  

40 

 
 
 
Section 4 – Control enforcement  

Q16:  To  what  extent  have  the  specific  provisions  laid  down  in  the  MAP  (Articles  10-14) 
allowed the national competent authorities to ensure compliance with the MAP itself?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q17:  Are  there  specific  control  measures  that  contributed  substantially  to  improve 
compliance?  

Since discarding goes on, and everyone knows about it, clearly control is not working OR the 
LO  is  not  being  enforced.  Chasing  mesh  size  millimetres  instead  of  illegal  discarding  is 
clearly missing the point and is a failed prioritisation. 

It is not the MAP that changed the control but rather inputs via JDP and SCIPS, both would 
have taken place without the MAP also. Recently introduced limitations on the salmon fishery 
outside coastal area is an example of a measure that has come to pass without any plan at all 
since salmon is not at all part of the MAP. 

Q18:  Are  there  specific  control  measures  that  have  instead  not  contributed  to  improve 
compliance?  

Q19:  Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control 
Regulation which would improve compliance with the MAP?  

CCTV, REM, actual enforcement of LO.  

Section 5 – Regional cooperation  

Q20: On  regional  cooperation, to  what  extent has the MAP in your opinion strengthened 
regional cooperation, including with stakeholders?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

41 

 
 
 
Q21: free text 

The  entire  basis  of  very  “empty”  MAPs  all  over  EU  was/is  that  it  should  be  populated  by 
regional needs, but regionalisation has not delivered as intended. The capacity of the national 
administrations is simply not there and there is very limited time of the year to handle all the 
needed  efforts.  The  TAC  circus  is  one  reason  it  is  not  working  because  this  eats  up  all 
resources.    

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion  

Q22:  Has  the  overall  socio-economic  situation  of  the  fisheries  sector  improved  since  the 
entry into force of the MAP?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q23:  Do  you  see  a  positive  correlation  between  the  implementation  of  the  MAP  and  the 
socio-economic situation of the fisheries sector?  

•  Significantly 
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q24: free text 

Since  Baltic  MAP  is  in  place  two  important  Baltic  stocks  has  clearly  collapsed  (Western 
Baltic herring and Eastern Baltic cod) and third one (Western Baltic cod) is close to collapse. 
One  could  argue  that  the  decision  to  not  set  a  zero  TAC  on  WH  stock  was  only  with 
considerations to socio-economic factors and thus such considerations has indeed been taken. 
However, CCB finds it hard to conclude that is really linked to the MAP at all. 

There  has  been  no  real  connection  between  the  MAP  and  CFP  article  17  which  introduces 
criteria for the allocation of fishing opportunities including criteria of an environmental, social 
and economic nature. In accordance with CFP art. 17 the MAP should support introduction of 

42 

 
 
 
preferential access to fish resources for those fishermen who fish in sustainable way, who use 
selective fishing gears and who have long history of fishing in compliance with the law. 

Section 7 – Overall assessment   

Q25: What is your overall assessment of the Baltic MAP?  

•  Very beneficial  
•  Beneficial  
•  Neutral  
•  Negative  
•  Very negative  
•  No opinion  

Q26: free text 

The  MAP  is  not  helping  implementation  on  the  CFP  and  MSFD  as  intended,  and  the 
regionalisation component that is key to the entire MAP is yet to deliver.  

Targets  for  fishing  mortality  include  ranges  above  the  FMSY  point  value  and  the  range 
concept is creating confusion about objectives   

At least two of the three exceptions allowing overfishing to take place (i.e. the using of upper 
range) provide vague conditions for the application of the exceptions, and it is far from clear 
how these will be interpreted (Baltic MAP Art. 4.4) 

Article 5.3 allows suspending the targeted fishery if a stock falls below Blim levels, but does 
not require any concrete action within a specific timeframe and this is not acceptable. 

43 

 
 
   
  
 
7.5. Confederation of Fishermen and Fish Processors of West Lithuania 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP MSY is to be achieved for all relevant stocks by 2020. 8 of the stocks 
covered by the MAP are managed by TACs, of which 7 receive an analytical assessment by 
ICES  (6  target  TAC,  and  one  by-catch  TAC).  Out  of  these  7  TACs  the  TACs  for  3  stocks 
were at MSY in 2016, and for 6 stocks as of 2017. In your opinion 

Q6: Has the existence of a MAP facilitated the process of setting of TACs for the relevant 
stocks?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q7:  To  what  extent  has  the  MAP  contributed  to  increasing  the  number  of  TACs  set  at 
MSY?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q8: Has the MAP helped in dealing with difficult cases such as Eastern and Western Baltic 
cod, Western herring or other sensitive stocks? 

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q9: free text 

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion  

44 

 
 
 
Q10:  To  what  extent  have  discards  been  eliminated  and  the  landing  obligation  actually 
been implemented?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q11: To what extent has the MAP contributed to achieving the current situation, notably 
via discard plans and technical measures?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q12: free text 

Section 3 – Ecosystem-based approach  

Q13:  To  what  extent  has  the  objective  of  implementing  an  ecosystem-based  approach  to 
fisheries management, and notably of achieving good environmental status by 2020, been 
achieved?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q14: To what extent has the MAP contributed to the current situation?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

45 

 
 
 
Q15: free text 

Section 4 – Control enforcement  

Q16:  To  what  extent  have  the  specific  provisions  laid  down  in  the  MAP  (Articles  10-14) 
allowed the national competent authorities to ensure compliance with the MAP itself?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q17:  Are  there  specific  control  measures  that  contributed  substantially  to  improve 
compliance?  

Q18:  Are  there  specific  control  measures  that  have  instead  not  contributed  to  improve 
compliance?  

Q19:  Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control 
Regulation which would improve compliance with the MAP?  

Section 5 – Regional cooperation  

Q20: On  regional  cooperation, to  what  extent has the MAP in your opinion strengthened 
regional cooperation, including with stakeholders?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q21: free text 

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion  

46 

 
 
 
 
 
Q22:  Has  the  overall  socio-economic  situation  of  the  fisheries  sector  improved  since  the 
entry into force of the MAP?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q23:  Do  you  see  a  positive  correlation  between  the  implementation  of  the  MAP  and  the 
socio-economic situation of the fisheries sector?  

•  Significantly 
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q24: free text 

Section 7 – Overall assessment   

Q25: What is your overall assessment of the Baltic MAP?  

•  Very beneficial  
•  Beneficial  
•  Neutral  
•  Negative  
•  Very negative  
•  No opinion  

Q26: free text 

47 

 
 
  
 
 
7.6. Danish Fishermen Producer Organisation 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP MSY is to be achieved for all relevant stocks by 2020. 8 of the stocks 
covered by the MAP are managed by TACs, of which 7 receive an analytical assessment by 
ICES  (6  target  TAC,  and  one  by-catch  TAC).  Out  of  these  7  TACs  the  TACs  for  3  stocks 
were at MSY in 2016, and for 6 stocks as of 2017. In your opinion 

Q6: Has the existence of a MAP facilitated the process of setting of TACs for the relevant 
stocks?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q7:  To  what  extent  has  the  MAP  contributed  to  increasing  the  number  of  TACs  set  at 
MSY?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q8: Has the MAP helped in dealing with difficult cases such as Eastern and Western Baltic 
cod, Western herring or other sensitive stocks? 

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q9: free text 

The plan is far to rigid and makes it impossible to balance the biological and socioeconomic 
elements.  It  may  have  made  the  process  of  settng  TACs  easier  for  managers,  but  it  has 
certainly not made it better. 

48 

 
 
 
Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion  

Q10:  To  what  extent  have  discards  been  eliminated  and  the  landing  obligation  actually 
been implemented?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q11: To what extent has the MAP contributed to achieving the current situation, notably 
via discard plans and technical measures?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q12: free text 

By  working  on  the  "one  size  fits  all"  approach,  it  has  alienated  fishers  towards  the 
discard ban where it makes sense. 

Section 3 – Ecosystem-based approach  

Q13:  To  what  extent  has  the  objective  of  implementing  an  ecosystem-based  approach  to 
fisheries management, and notably of achieving good environmental status by 2020, been 
achieved?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q14: To what extent has the MAP contributed to the current situation?  

•  Significantly  

49 

 
 
 
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q15: free text 

Section 4 – Control enforcement  

Q16:  To  what  extent  have  the  specific  provisions  laid  down  in  the  MAP  (Articles  10-14) 
allowed the national competent authorities to ensure compliance with the MAP itself?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q17:  Are  there  specific  control  measures  that  contributed  substantially  to  improve 
compliance?  

Q18:  Are  there  specific  control  measures  that  have  instead  not  contributed  to  improve 
compliance?  

Q19:  Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control 
Regulation which would improve compliance with the MAP?  

Section 5 – Regional cooperation  

Q20: On  regional  cooperation, to  what  extent has the MAP in your opinion strengthened 
regional cooperation, including with stakeholders?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q21: free text 

50 

 
 
 
 
By  providing  the  basis  for  BALTFISH  it  has  helped  taking  a  step  in  the  right 
direction, but there is ample room for improvement. 

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion  

Q22:  Has  the  overall  socio-economic  situation  of  the  fisheries  sector  improved  since  the 
entry into force of the MAP?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q23:  Do  you  see  a  positive  correlation  between  the  implementation  of  the  MAP  and  the 
socio-economic situation of the fisheries sector?  

•  Significantly 
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q24: free text 

 See comments under 9. 

Section 7 – Overall assessment   

Q25: What is your overall assessment of the Baltic MAP?  

•  Very beneficial  
•  Beneficial  
•  Neutral  
•  Negative  
•  Very negative  
•  No opinion  

Q26: free text 

51 

 
 
 
 
It is a fish protection plan, not a fisheries management plan. A better plan would take more 
account  of  the  fact  that  it  sets  the  stage  for  people's  lives,  food  production  and  local 
Communities - in balance with a healthy environment. There is too little acknowledgement of 
the mismatch. 

52 

 
 
 
7.7. Darlowska Group of Fish Producers and Ship Owners 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP MSY is to be achieved for all relevant stocks by 2020. 8 of the stocks 
covered by the MAP are managed by TACs, of which 7 receive an analytical assessment by 
ICES  (6  target  TAC,  and  one  by-catch  TAC).  Out  of  these  7  TACs  the  TACs  for  3  stocks 
were at MSY in 2016, and for 6 stocks as of 2017. In your opinion 

Q6: Has the existence of a MAP facilitated the process of setting of TACs for the relevant 
stocks?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q7:  To  what  extent  has  the  MAP  contributed  to  increasing  the  number  of  TACs  set  at 
MSY?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q8: Has the MAP helped in dealing with difficult cases such as Eastern and Western Baltic 
cod, Western herring or other sensitive stocks? 

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q9: free text 

In  our  opinion  the  regulations  which  are  in  MAP  are  not  respected  in  many  cases  by 
fishermen.  

We think that we do not need written law if it can’t be enforced in real life. 

53 

 
 
 
Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion  

Q10:  To  what  extent  have  discards  been  eliminated  and  the  landing  obligation  actually 
been implemented?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q11: To what extent has the MAP contributed to achieving the current situation, notably 
via discard plans and technical measures?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q12: free text 

The landing obligation and discard plans do not work on The Baltic Sea. In our opinion the 
bycatch is larger but unreported now than earlier. 

Section 3 – Ecosystem-based approach  

Q13:  To  what  extent  has  the  objective  of  implementing  an  ecosystem-based  approach  to 
fisheries management, and notably of achieving good environmental status by 2020, been 
achieved?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q14: To what extent has the MAP contributed to the current situation?  

•  Significantly  

54 

 
 
 
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q15: free text 

MAP doesn’t work on the Baltic Sea. 

Section 4 – Control enforcement  

Q16:  To  what  extent  have  the  specific  provisions  laid  down  in  the  MAP  (Articles  10-14) 
allowed the national competent authorities to ensure compliance with the MAP itself?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q17:  Are  there  specific  control  measures  that  contributed  substantially  to  improve 
compliance?  

We do not no. 

Q18:  Are  there  specific  control  measures  that  have  instead  not  contributed  to  improve 
compliance?  

Yes in our opinion we need to change a lot especially control in the sea. 

Q19:  Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control 
Regulation which would improve compliance with the MAP?  

In our opinion we should focus not only on target species such as cod, sprat and herring, but 
on fishing gear that causes by-catches and discards. 

Section 5 – Regional cooperation  

Q20: On  regional  cooperation, to  what  extent has the MAP in your opinion strengthened 
regional cooperation, including with stakeholders?  

•  Significantly  
•  A little 

55 

 
 
 
 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q21: free text 

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion  

Q22:  Has  the  overall  socio-economic  situation  of  the  fisheries  sector  improved  since  the 
entry into force of the MAP?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q23:  Do  you  see  a  positive  correlation  between  the  implementation  of  the  MAP  and  the 
socio-economic situation of the fisheries sector?  

•  Significantly 
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q24: free text 

Section 7 – Overall assessment   

Q25: What is your overall assessment of the Baltic MAP?  

•  Very beneficial  
•  Beneficial  
•  Neutral  
•  Negative  
•  Very negative  
•  No opinion  

56 

 
 
 
 
Q26: free text 

57 

 
 
7.8. Latvian Fisheries Association 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP MSY is to be achieved for all relevant stocks by 2020. 8 of the stocks 
covered by the MAP are managed by TACs, of which 7 receive an analytical assessment by 
ICES  (6  target  TAC,  and  one  by-catch  TAC).  Out  of  these  7  TACs  the  TACs  for  3  stocks 
were at MSY in 2016, and for 6 stocks as of 2017. In your opinion 

Q6: Has the existence of a MAP facilitated the process of setting of TACs for the relevant 
stocks?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q7:  To  what  extent  has  the  MAP  contributed  to  increasing  the  number  of  TACs  set  at 
MSY?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q8: Has the MAP helped in dealing with difficult cases such as Eastern and Western Baltic 
cod, Western herring or other sensitive stocks? 

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q9: free text 

Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion  

58 

 
 
 
Q10:  To  what  extent  have  discards  been  eliminated  and  the  landing  obligation  actually 
been implemented?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q11: To what extent has the MAP contributed to achieving the current situation, notably 
via discard plans and technical measures?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q12: free text 

Section 3 – Ecosystem-based approach  

Q13:  To  what  extent  has  the  objective  of  implementing  an  ecosystem-based  approach  to 
fisheries management, and notably of achieving good environmental status by 2020, been 
achieved?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q14: To what extent has the MAP contributed to the current situation?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

59 

 
 
 
Q15: free text 

Section 4 – Control enforcement  

Q16:  To  what  extent  have  the  specific  provisions  laid  down  in  the  MAP  (Articles  10-14) 
allowed the national competent authorities to ensure compliance with the MAP itself?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q17:  Are  there  specific  control  measures  that  contributed  substantially  to  improve 
compliance?  

Control measures take place at sea, in port, in warehouses and on the road. 

Q18:  Are  there  specific  control  measures  that  have  instead  not  contributed  to  improve 
compliance?  

NOT 

Q19:  Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control 
Regulation which would improve compliance with the MAP?  

NOT MISSING 

Section 5 – Regional cooperation  

Q20: On  regional  cooperation, to  what  extent has the MAP in your opinion strengthened 
regional cooperation, including with stakeholders?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q21: free text 

60 

 
 
 
 
 
Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion  

Q22:  Has  the  overall  socio-economic  situation  of  the  fisheries  sector  improved  since  the 
entry into force of the MAP?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q23:  Do  you  see  a  positive  correlation  between  the  implementation  of  the  MAP  and  the 
socio-economic situation of the fisheries sector?  

•  Significantly 
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q24: free text 

Section 7 – Overall assessment   

Q25: What is your overall assessment of the Baltic MAP?  

•  Very beneficial  
•  Beneficial  
•  Neutral  
•  Negative  
•  Very negative  
•  No opinion  

Q26: free text 

61 

 
 
 
 
 
7.9. The Fisheries Secretariat 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP MSY is to be achieved for all relevant stocks by 2020. 8 of the stocks 
covered by the MAP are managed by TACs, of which 7 receive an analytical assessment by 
ICES  (6  target  TAC,  and  one  by-catch  TAC).  Out  of  these  7  TACs  the  TACs  for  3  stocks 
were at MSY in 2016, and for 6 stocks as of 2017. In your opinion 

Q6: Has the existence of a MAP facilitated the process of setting of TACs for the relevant 
stocks?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q7:  To  what  extent  has  the  MAP  contributed  to  increasing  the  number  of  TACs  set  at 
MSY?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q8: Has the MAP helped in dealing with difficult cases such as Eastern and Western Baltic 
cod, Western herring or other sensitive stocks? 

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q9: free text 

Q.1:  Has  the  existence  of  a  MAP  facilitated  the  process  of  setting  of  TACs  for  the 
relevant stocks? 

62 

 
 
It is problematic that the MAP allows TACs to be set above Fmsy when biomass is evaluated 
just above MSY Btrigger according to the latest scientific advice, which coincides with when 
there is highest uncertainty over the state of the stock. 

Moreover, TACs have been set above Fmsy when projected SSB will be above MSY Btrigger 
in the coming year, rather than only taking place if/when this biomass level has been realised. 

The advice setting under the MAP is particularly sensitive to annual revisions in the scientific 
advice. There are regular annual revisions of SSB and F, thereby leading to the MAP lacking 
the adequate precaution necessary for an ecosystem as sensitive to productivity as the Baltic 
Sea. 

F  ranges  between  0  –  Fmsy,  as  proposed  by  the  European  Parliament,  would  have 
significantly improved the effectiveness of the MAP. 

Q.2: To what extent has the MAP contributed to increasing the number of TACs set at 
MSY? 

Only one of the seven stocks under the management plan have been fished below Fmsy, Gulf 
of Riga herring. 

Only three of the seven stocks are above Bpa and Bmsy, however, for Central Baltic herring 
and Sprat this is based on strong recruitment from 2014 and biomass is expected to decline as 
this group ages unless a new strong year class enters the fishery. 

The MAP has contributed to improved management of Gulf of Riga herring. TACs have been 
set below Fmsy and biomass has increased to above Bmsy. 

Q.3:  Has  the  MAP  helped  in  dealing  with  difficult  cases  such  as  Eastern  and  Western 
Baltic cod, Western herring or other sensitive stocks? 

All  three  of  these  stocks  have  been  benchmarked  by  ICES  recently.  The  two  cod  stocks  in 
February 2019 and western herring in 2018.  

For  Eastern  cod  and  Western  herring  the  biomass  is  depleted,  below  Blim,  with  impaired 
recruitment.  The  stocks  are  not  able  to  replenish  themselves.  Recruitment  has  likely  been 
impaired. The scientific advice is to close both fisheries.  

For Western cod the MAP has enabled TAC decisions with high levels of risk. This has led to 
the above average 2016 year class not fulfilling its growth potential. Additional management 
measures, such as a spawning closure, as specified in the MAP when SSB is below Blim have 
not been successfully implemented while the MAP has been in force. 

The MAP cannot be said to have derived environmental or socioeconomic benefits from any 
of these stocks.  

63 

 
 
 
Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion  

Q10:  To  what  extent  have  discards  been  eliminated  and  the  landing  obligation  actually 
been implemented?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q11: To what extent has the MAP contributed to achieving the current situation, notably 
via discard plans and technical measures?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q12: free text 

Discarding is significant in several fisheries, in particular for eastern cod and plaice.  

For  eastern  cod  discarding  is  “up  to  50-70%  according  to  information  from  the  fishing 
industry instead of the 10-20% estimated by ICES” (ICES WKCONGA 2018 p.36). 

ICES have consistently stated that they consider their discard estimates to be an underestimate 
and  have  highlighted  problems  with  observer  access  onboard  vessels.  They  have  also 
identified  illegal  gear  modifications  which  ensure  higher  catches  of  juvenile  fish  to  be  a 
presence in the fishery throughout the duration of the MAP. 

Note  that  these  discard  estimates  are  by  weight  and  that  the  percentage  of  individuals 
discarded is significantly higher. 

In  the  2018  ICES  advice  for  plaice,  estimated  discards  were  “approximately  38.6%”.  “The 
discarded fraction can cover all length classes and comprise as much as 100% of the catch”.  

Discards  have  also  persisted  in  the  western  cod  fishery  with  negligible  landings  of  Below 
Minimum Size fish. 

It  is  clear  that  discards  have  not  been  eradicated  and  the  landing  obligation  has  not  been 
successfully implemented.  

64 

 
 
The MAP has been a counterproductive factor contributing to discards because it has allowed 
for  fishing  above  Fmsy  and  has  not  provided  technical  measures  for  protecting  a  data  poor 
stock such as eastern cod. 

The MAP lacks effective tools for suspending or removing actors within the fishery that are 
engaged in illegal discarding.  

Section 3 – Ecosystem-based approach  

Q13:  To  what  extent  has  the  objective  of  implementing  an  ecosystem-based  approach  to 
fisheries management, and notably of achieving good environmental status by 2020, been 
achieved?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q14: To what extent has the MAP contributed to the current situation?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q15: free text 

The MAP has allowed for overfishing, TACs above Fmsy, for pelagic stocks such as Central 
Baltic herring and sprat. This has contributed to the lack of prey availability for eastern cod 
and their subsequent poor condition and reduced resilience to parasites.  

Reducing pelagic fishing pressure in the main eastern cod distribution area, where a lack of 
prey  availability  has  been  a  factor  in  the  poor  condition  of  the  cod,  has  been  a 
recommendation  from  ICES  throughout  the  duration  of  the  MAP  and  has  not  been 
implemented.  

65 

 
 
 
 
 
 
Section 4 – Control enforcement  

Q16:  To  what  extent  have  the  specific  provisions  laid  down  in  the  MAP  (Articles  10-14) 
allowed the national competent authorities to ensure compliance with the MAP itself?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q17:  Are  there  specific  control  measures  that  contributed  substantially  to  improve 
compliance?  

Q18:  Are  there  specific  control  measures  that  have  instead  not  contributed  to  improve 
compliance?  

Q19:  Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control 
Regulation which would improve compliance with the MAP?  

Introducing a TAC for flounder is a specific control measure that would improve compliance 
with the MAP. 

At present flounder is an unrestricted fishery with bycatch of cod. 

Allowing fishing on flounder, or other flatfish such as plaice, will lead to cod bycatch and cod 
discards, thereby reducing compliance with the control measures within the MAP, specifically 
with regard to the landing obligation being implemented for cod and plaice.  

Section 5 – Regional cooperation  

Q20: On  regional  cooperation, to  what  extent has the MAP in your opinion strengthened 
regional cooperation, including with stakeholders?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

66 

 
 
 
 
 
Q21: free text 

BALTFISH  together  with  EFCA  and  BSAC  organised  a  joint  meeting  on  the  landing 
obligation in the Baltic Sea in 2017, over two years after the discard ban had been in place for 
Baltic cod. 

This  meeting  followed  on  from  the  highgrading  ban,  introduced  in  2010.  As  well  as  the 
“eradicating 
flagship 
discards  in  the  Baltic  Sea”  as  part  of  the  Strategy  for  the  Baltic  Sea  Region,  that  was 
concluded under Danish leadership at the end of 2011. 

(https://www.keep.eu/project/15567/eradicating-discards) 

project 

Despite  two  legal  commitments  as  well  as  European  subsidies  for  control  and  enforcement 
regional cooperation has not succeeded with policy implementation.  

In fact, compliance with the landing obligation has declined since BALTFISH organised the 
joint workshop with EFCA and BSAC. By volume discards are now estimated as over 16% 
for eastern cod with the number rising to 30% in terms of individual fish. 

Further, the BALTFISH High Level Group lacks representation from the Other Interest Group 
from the BSAC. We note that there was no stakeholder consensus with regard to allowing the 
BSAC Chair to attend High Level Group meetings and no mandate is agreed by stakeholders 
in advance of meetings. 

The MAP lacks clarity on the relationship between stakeholder and advisory bodies, including 
BALTFISH.  The  revision  of  the  MAP  provides  an  opportunity  to  strengthen  regional 
cooperation  through  more  formal  and  specific  guidelines,  in  particular  with  regard  to  the 
regional management body.    

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion  

Q22:  Has  the  overall  socio-economic  situation  of  the  fisheries  sector  improved  since  the 
entry into force of the MAP?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q23:  Do  you  see  a  positive  correlation  between  the  implementation  of  the  MAP  and  the 
socio-economic situation of the fisheries sector?  

•  Significantly 

67 

 
 
 
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q24: free text 

The  large  F  ranges,  in  particular  for  the  western  cod  stock  have  been  detrimental  to  the 
fishery. They have allowed for TAC variability.  

For the Gulf of Riga herring, implementing the rules laid out in the MAP and fishing below 
Fmsy have contributed to the improved socio-economic situation of the fishery. 

Overfishing  of  sprat  and  Central  Baltic  herring,  in  line  with  the  conditions  laid  out  in  the 
MAP, have contributed to the lack of growth in biomass and current dependence on older age 
classes  in  the  fisheries.  This  has partly led  to  the current  situation of sharp TAC reductions 
and associated socioeconomic problems in the coming years. 

Voss  et  al.  2014  “Regional  trade-offs  from  multi-species  maximum  sustainable  yield 
(MMSY) management options” demonstrates that the highest economic benefits from fishing 
in  the  Baltic  Sea  are  derived  when  the  eastern  Baltic  cod  stock  has  a  large  spawning  stock 
biomass, at least above Bpa. In a pelagic dominated system with low cod biomass expected 
profits  are  less  than  half  as  large.  Moreover,  cod  focused  fisheries  management  has  further 
socioeconomic  benefits  as  it  provides  more  local  employment,  in  particular  through  the 
passive gear fishing segment.  

If  the  MAP  restricted  pelagic  fishing  to  a  maximum  of  0.5*FMSY  there  would  likely  be 
significant benefits to the socioeconomic situation of the fisheries sector. All stocks cannot be 
managed at FMSY at the same time and an ecosystem managed to ensure high cod biomass 
allows for higher profitability and higher employment. 

There  has  been  no  real  connection  between  the  MAP  and  CFP  article  17  which  introduces 
criteria for the allocation of fishing opportunities including criteria of an environmental, social 
and economic nature. In accordance with CFP art. 17 the MAP should support introduction of 
preferential access to fish resources for those fishermen who fish in sustainable way, who use 
selective fishing gears and who have long history of fishing in compliance with the law. 

Section 7 – Overall assessment   

Q25: What is your overall assessment of the Baltic MAP?  

•  Very beneficial  
•  Beneficial  
•  Neutral  

68 

 
 
   
•  Negative  
•  Very negative  
•  No opinion  

Q26: free text 

It is not that the MAP in itself has been harmful to the management of Baltic Sea fish stocks 
but that implementation has been detrimental. 

Only for one of the seven stocks managed by the MAP has the Plan been implemented, Gulf 
of  Riga  herring.  Coincidentally  or  not  this  is  also  the  only  stock  for  which  biomass  and 
fishing quotas are increasing.  

The unsuccessful implementation of the MAP and following the clear guidelines laid out in 
the Plan has had a detrimental effect on the other stocks.  

Article 3 of the  Baltic  MAP lists the objectives of the Plan. Article 3.1  of the Plan states it 
“shall  aim  to  ensure  the  exploitation  of  living  marine  biological  resources  restores  and 
maintains populations of harvested species above levels which can produce MSY.” 

Only for Gulf of Riga herring has the plan helped to achieve this objective.  

The central Baltic herring and sprat stocks are also presently estimated to have MSY biomass 
levels however this is due to the 2014 year classes in both cases. 

Article  3.2  states  “the  plan  shall  contribute  to  the  elimination  of  discards  by  avoiding  and 
reducing, as far as possible, unwanted catches.” 

The MAP has not achieved this objective and in fact discards are estimated to have increased. 
Moreover,  they  may  be  as  high  as  50-70%  for  the  ecosystem  keystone  top  predator  stock, 
eastern cod. Further, discards are estimated to have increased in the most recent assessment. A 
clear indication that Article 3.2 has not been successfully implemented. 

Article  3.3  states  “the  plan  shall  implement  the  ecosystem-based  approach  to  fisheries 
management….In  particular  the  plan  shall  aim  to  ensure  that  the  conditions  described  in 
description 3” of the MSFD are fulfilled. 

The  age  and  size  distribution  of  both  cod  stocks  as  well  as  key  stocks  like  central  Baltic 
herring and sprat are understood to be in worse shape that when the MAP was adopted. All of 
these stocks have damaged age and/or size structures to which fishing and the TACs decided 
have  contributed  to,  along  with  the  breakdown  of  the  cod  food  chain.  The  TAC  setting 
procedure has not taken into account implementation of the MSFD, hence the boom and bust 
approach to quota management has continued. 

Article  3.4  states  that  “measures  under  the  plan  shall  be  taken  in  accordance  with  the  best 
available scientific advice”. 

69 

 
 
It  is  to  be  noted  that  the  scientific  advice  requested  by  the  Commission  from  ICES  has  not 
been adequate to ensure the Objectives of the MAP could be fulfilled. 

It can be concluded that none of the four Objectives in the MAP have been achieved. 

70 

 
 
  
 
7.10. 

World Wildlife Fund 

Section 1 – Progress made towards sustainable fishing levels 

According to the MAP MSY is to be achieved for all relevant stocks by 2020. 8 of the stocks 
covered by the MAP are managed by TACs, of which 7 receive an analytical assessment by 
ICES  (6  target  TAC,  and  one  by-catch  TAC).  Out  of  these  7  TACs  the  TACs  for  3  stocks 
were at MSY in 2016, and for 6 stocks as of 2017. In your opinion 

Q6: Has the existence of a MAP facilitated the process of setting of TACs for the relevant 
stocks?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q7:  To  what  extent  has  the  MAP  contributed  to  increasing  the  number  of  TACs  set  at 
MSY?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q8: Has the MAP helped in dealing with difficult cases such as Eastern and Western Baltic 
cod, Western herring or other sensitive stocks? 

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q9: free text 

CFP and MAP both require an end to overfishing by 2015 where possible and by 2020 at the 
latest  (CFP  art.  2.2.  “the  maximum  sustainable  yield  exploitation  rate  shall  be  achieved  by 
2015  where  possible  and,  on  a  progressive,  incremental  basis  at  the  latest  by  2020  for  all 
stocks”). 

71 

 
 
The MAP did not facilitate the process of setting TACs: 

1) In October 2016 (when the MAP was already in place) only 5 out of 8 TACs covered by 
the MAP has been agreed by Fisheries Council in accordance with scientific advice and MAP 
and  CFP  requirements.  The  CFP  only  allows  the  postponement  of  MSY  exploitation  rates 
beyond 2015 “if achieving them by 2015 would seriously jeopardise the social and economic 
sustainability  of  the  fishing  fleets  involved”.  To  date,  no  compelling  socio-economic 
evidence justifying such delays in the Baltic Sea region has been made publicly available. 

1)  In 2017 6 out of 8 TACs covered by the MAP has been agreed by Fisheries Council in 
accordance  with  scientific  advice  and  MAP  and  CFP  requirements.  Despite  MAP 
available  since  July  2016,  the  October  2017  Fisheries  Council  negotiations  lasted 
during entire night until early morning hours (around 6.00 am) raising questions about 
the  process  and  extent  to  which  very  well  known  MAP  provisions  and  requirements 
has been followed. 

2)  In  2018  (despite  the  2020  deadline  for  ending  overfishing  fast  approaching)  the 
progress  has  been  reversed  and  only  5  out  of 8  TACs  covered  by  the  MAP  has 
been agreed by Fisheries Council in  accordance with scientific advice and MAP 
and  CFP  requirements.  The  three  TACs  agreed  above  scientific  advice  and  MAP 
and  CFP  requirements  are:  Western  Baltic  herring,  Eastern  Baltic  cod  and  central 
Baltic  herring.  For  central  Baltic  herring  the  Council  agreed  on  a  TAC  based  on  F 
MSY-upper figure – despite the well known negative consequences of using F upper-
2,  
ranges 
http://www.ices.dk/sites/pub/Publication%20Reports/Advice/2015/Special_Requests/
EU_FMSY_ranges_for_selected_NS_and_BS_stocks.pdf)  WWF 
to 
oppose using F MSY-upper ranges as fishing above F-MSY point value will not 
restore  and  maintain  fish  stocks  above  biomass  levels  capable  of  producing 
maximum sustainable yield – as it is required by the CFP (and reiterated by the 
MAP itself). 

continues 

Request 

Special 

advice, 

ICES 

page 

(see 

MAP and setting the TACs at MSY: 

1)  The  MAP  is  conflicting  with  CFP  Article  2.2  as  targets  for  fishing  mortality  in  the 
MAP include ranges above the FMSY point value. Until the Baltic MAP was agreed, 
fishing mortality rates above this level were considered overfishing as defined by the 
limits in the CFP.  

2)  WWF  strongly  opposes  continued  overfishing  above  the  FMSY  point  value  fishing 
rates.  This  is  also  in  line  with  advice  from  the  International  Council  for  the 
Exploration  of  the  Sea  (ICES)  (ICES  Special  Request  Advice  2015:  EU  request  to 
ICES to provide FMSY ranges for selected North Sea and Baltic Sea stocks.): 

“In a single-species context fishing above FMSY implies reduced stock biomass and this may 
be substantial where Fupper is much higher than FMSY. So in utilizing FMSY ranges there 

72 

 
 
are  more  4  advantages  to  fishing  between  FMSY  and  Flower  than  between  FMSY  and 
Fupper. With higher fishing mortalities the following occurs:  

o A need for increased fishing effort;  

o Higher dependence of stock and yield on recruiting year classes and increased variability 
on catch opportunities;  

o The size of the fish in the stock and the catch will be smaller on average;  

o Greater probability of SSB being less than MSY Btrigger;  

o  A  lower  probability  of  density-dependent  effects  such  as  reduced  growth  or  increased 
cannibalism.  

For  some  mixed  fisheries  it  may  be  difficult  to  reconcile  the  Fs  on  different  stocks.  An 
approach  for  maximizing  long-term  yield  could  be  to  attempt  to  reconcile  F  on  a  mixed 
fishery using Fs between Flower and FMSY.” 

MAP  did  not  help  in  dealing  with  difficult  cases  such  as  Eastern  and  Western  Baltic  cod, 
Western herring or other sensitive stocks: 

1)  On Western Baltic herring case the MAP was counterproductive as in  October 2018 
old  version  of  the  MAP  contained  invalid  figures  and  reference  points  in  the 
MAP annexes which created confusions among the decision makers. (NGOs have 
been  addressing  this  possible  problem  in  the  previous  years.  Recently  established 
Western  Waters  MAP  introduced  amendments  to  Baltic  MAP  thanks  to  which  the 
latest scientific advice on fishing mortality and reference points can be used).  

Additional  difficulty  is  that  the  MAP  is  not  adopted  by  Norway  and,  thus,  not 
used  as  basis  of  the  ICES  advice  for  Western  Baltic  herring  which  is  a  shared 
stock. 

2)  On  Eastern  Baltic  cod  case  –  the  MAP  failed  in  securing  provisions  which  would 
effectively demand decision makers to safeguard stocks without analitical assessment 
and  those  which  are  in  critical  state.  For  the  stocks  which  do  not  have  MSY 
reference points defined (like Eastern Baltic cod) Article 9(2) of the CFP requires 
at  least  a  comparable  degree  of  conservation  as  to  those  stocks  with  MSY 
assessments.  

In  practice  the  Council  did  not  even  follow  ICES  advice  based  on  precautionary 
approach for Eastern Baltic cod – exceeding the scientific advice for EB cod TAC each 
year as of 2013.  

73 

 
 
 
 
 
 
Section 2 – Discards and landing obligation  

On discards and the landing obligation, in your opinion  

Q10:  To  what  extent  have  discards  been  eliminated  and  the  landing  obligation  actually 
been implemented?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q11: To what extent has the MAP contributed to achieving the current situation, notably 
via discard plans and technical measures?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q12: free text 

Discarding is significant in several fisheries, in particular for eastern cod and plaice.  

For  eastern  cod  discarding  is  “up  to  50-70%  according  to  information  from  the  fishing 
industry instead of the 10-20% estimated by ICES” (ICES WKCONGA 2018 p.36). 

ICES have consistently stated that they consider their discard estimates to be an underestimate 
and  have  highlighted  problems  with  observer  access  onboard  vessels.  They  have  also 
identified  illegal  gear  modifications  which  ensure  higher  catches  of  juvenile  fish  to  be  a 
presence in the fishery throughout the duration of the MAP. 

Note  that  these  discard  estimates  are  by  weight  and  that  the  percentage  of  individuals 
discarded is significantly higher. 

In the 2018 ICES advice for plaice, estimated discards were “approximately 38.6%”.   

Discards  have  also  persisted  in  the  western  cod  fishery  with  negligible  landings  of  Below 
Minimum Size fish. 

It  is  clear  that  discards  have  not  been  eradicated  and  the  landing  obligation  has  not  been 
successfully implemented.  

74 

 
 
The MAP has been a counterproductive factor contributing to discards because it has allowed 
for  fishing  above  Fmsy  and  has  not  provided  technical  measures  for  protecting  a  data  poor 
stock such as eastern cod. 

The  persistent  and  high  levels  of  illegal  discarding  clearly  indicate  that  control  and 
enforcement  has  thus  far  been  insufficient  in  enabling  the  implementation  of  the  landing 
obligation.  

Section 3 – Ecosystem-based approach  

Q13:  To  what  extent  has  the  objective  of  implementing  an  ecosystem-based  approach  to 
fisheries management, and notably of achieving good environmental status by 2020, been 
achieved?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q14: To what extent has the MAP contributed to the current situation?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q15: free text 

MAP Article 3.3 states that: 

 “The plan shall implement the ecosystem-based approach to fisheries management in order to 
ensure that negative impacts  of fishing activities on the marine ecosystem  are minimised.  It 
shall  be  coherent  with  Union  environmental  legislation,  in  particular  with  the  objective  of 
achieving  good  environmental  status  by  2020  as  set  out  in  Article  1(1)  of  Directive 
2008/56/EC. (…)”  

and the definition of the ecosystem-based approach to fisheries management (EBFM) in the 
CFP basic regulation is as follows  

Article.4(9):  '  the  ecosystem-based  approach  to  fisheries  management  means  an  integrated 
approach  to  managing  fisheries  within  ecologically  meaningful  boundaries  which  seeks  to 

75 

 
 
 
manage  the  use  of  natural  resources,  taking  account  of  fishing  and  other  human  activities, 
while  preserving  both  the  biological  wealth  and  the  biological  processes  necessary  to 
safeguard  the  composition,  structure  and  functioning  of  the  habitats  of  the  ecosystem 
affected,  by  taking  into  account  the  knowledge  and  uncertainties  regarding  biotic, 
abiotic and human components of ecosystems; 

MAP  did  not  secured  provisions  which  would  allow  to  take  inter  species  interactions  into 
account.  For  example  there  is  no  MAP  provision  which  would  support  decision  makers  to 
follow the repeated ICES advice to redirect sprat fishery to northern areas of the Baltic Sea (to 
SDs 27,28) in order to secure enough of food for Baltic cod in its area of distribution.  

Besides Article 3.3. (Objectives) itself the MAP does not have any provision allowing for real 
implementation  of the EBMF or achievement  of good environmental  status  (GES) by 2020. 
For example MAP does not contain any provisions related to minimising by-catch of marine 
mammals and birds (and other fish species than those commercially exploited). The MAP is 
also not covering the problem of negative effects of bottom trawling and other active gears on 
marine habitats.  

Section 4 – Control enforcement  

Q16:  To  what  extent  have  the  specific  provisions  laid  down  in  the  MAP  (Articles  10-14) 
allowed the national competent authorities to ensure compliance with the MAP itself?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q17:  Are  there  specific  control  measures  that  contributed  substantially  to  improve 
compliance?  

Q18:  Are  there  specific  control  measures  that  have  instead  not  contributed  to  improve 
compliance?  

Q19:  Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control 
Regulation which would improve compliance with the MAP?  

Section 5 – Regional cooperation  

Q20: On  regional  cooperation, to  what  extent has the MAP in your opinion strengthened 
regional cooperation, including with stakeholders?  

76 

 
 
 
 
•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q21: free text 

There was little of the MAP influence on cooperation with stakeholders. MAP was intensively 
discussed  during  first  phase  of  its  development  (during  European  Parliament  and  Council 
work  in  2014-2015  as  well  as  during  the  trialogue  negotiations).  MAP  was  discussed  inter-
regionally  as  it  was  the  very  first  MAP  developed  under  CFP.  Fisheries  stakeholders  from 
other regions have been involved in a discussion because this MAP was expected to serve as a 
blue-print for other regions as well. On a Baltic - regional level however there was too little of 
initiatives related to the MAP (no big conferences, events) to allow for increased stakeholders 
involvement in this topic. 

In addition the Commission’s consultations on Baltic MAP were not public consultations but 
only consultations with main stakeholders (BSAC and BALTFISH).    

Section 6 – Socio-economic impact  

Regarding the socio-economic impact of the MAP, in your opinion  

Q22:  Has  the  overall  socio-economic  situation  of  the  fisheries  sector  improved  since  the 
entry into force of the MAP?  

•  Significantly  
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

Q23:  Do  you  see  a  positive  correlation  between  the  implementation  of  the  MAP  and  the 
socio-economic situation of the fisheries sector?  

•  Significantly 
•  A little 
•  Not much  
•  Not at all  
•  Counterproductive  
•  No opinion  

77 

 
 
 
Q24: free text 

-  Since  Baltic  MAP  is  in  place  two  important  Baltic  stocks  has  clearly  collapsed 
(Western Baltic herring and Eastern Baltic cod) and third one (Western Baltic cod) is 
close  to  collapse.  Baltic  MAP  did  not  secure  ambitious  provisions  for  the  stocks  in 
pure  shape  or  for  those  without  analytical  assessment  by  ICES.  In  particular  MAP 
does not have provisions on clear harvest control rules which should be used when the 
stock is below critical reference points.  

-  There is no correlation between the MAP and CFP article 17 which introduces criteria 
for the allocation of fishing opportunities including criteria of an environmental, social 
and  economic  nature.  In  accordance  with  CFP  art.  17  the  MAP  should  support 
introduction  of  preferential  access  to  fish  resources  for  those  fishermen  who  fish  in 
sustainable way, who use selective fishing gears and who have long history of fishing 
in compliance with the law. 

Section 7 – Overall assessment   

Q25: What is your overall assessment of the Baltic MAP?  

•  Very beneficial  
•  Beneficial  
•  Neutral  
•  Negative  
•  Very negative  
•  No opinion  

Q26: free text 

The MAP is not in line with CFP objectives (Article 2.2) 

- Targets for fishing mortality include ranges above the FMSY point value.   

-  While  the  objective  of  the  Baltic  MAP  is  to  restore  and  maintain  species  above  BMSY 
levels,  fishing mortality  rates that would allow that aim to  be achieved (F<FMSY) are only 
unambiguously  required  if the stock biomass is  below MSY Btrigger levels,  which is lower 
than BMSY. Stocks above MSY Btrigger levels can (under vague conditions) be fished above 
the FMSY point value fishing rates (Baltic MAP Art.  4), which would impede reaching the 
objective  of  progressively  restoring  and  maintaining  populations  of  fish  stocks  above  the 
desired >BMSY levels.  

-  At  least  two  of  the  three  exceptions  allowing  overfishing  to  take  place  (i.e.  the  choice  of 
fishing opportunities based on the upper range) provide vague conditions for the application 
of the exceptions, and it is far from clear how these will be interpreted (Baltic MAP Art. 4.4):  

78 

 
 
   
1 “When necessary to achieve the Baltic MAP objectives in mixed fisheries”:  

-  It  is  not  clear  why  overfishing  would  be  needed  to  achieve  the  Baltic  MAP  objectives  as 
defined in Baltic MAP Article 3. For example, the elimination of discards shall be achieved 
through the landing obligation and discard plans. Tools to facilitate the elimination of discards 
are for instance quota flexibility, swaps and increased selectivity.  

2 “When necessary to avoid serious harm to a stock caused by intra- or inter-species stock 
dynamics”.  -  The  Baltic  MAP  does  not  define  “Serious  harm  to  a  stock”.  In  an  ecosystem 
most stocks have inter-species dynamics, and all stocks have intra-species dynamics.  

-  From  the  two  options for  fishing  mortality  ranges  included  in  ICES  advice  (ICES  Special 
Request  Advice 2015:  EU request  to  ICES  to  provide FMSY ranges for  selected North Sea 
and Baltic Sea stocks. ), the Baltic MAP includes the one with less restrictive upper values. 
ICES computed these ranges for a plan that included a “harvest control rule” in line with the 
ICES advisory rule1, i.e. predefined measures that will be taken once biomass trigger points 
are transgressed. Yet, the agreed Baltic MAP lacks such harvest control rules. Article 5.2 only 
stipulates “to take into account the decrease in biomass”.  

- Article 5.3 allows suspending the targeted fishery if a stock falls below Blim levels, but does 
not require any concrete action within a specific timeframe. 

79 

 
 
  
7.11. 

The PEW Charitable Trusts 

The Pew Charitable Trusts has analysed the Baltic MAP provisions when they were agreed in 
20161,  and  conducted  detailed  analyses  of  the  implementation  of  the  Baltic  MAP  when  it 
comes to the setting of fishing opportunities every year since then. For detailed information, 
please consult our website.2 

Note: The questions directly extracted from the European Commission’s questionnaire are in 
bold italic typeface.  

1. Progress made towards sustainable fishing levels  

The  objectives  of  the  Baltic  Sea  Multiannual  Plan  (MAP)3,  described  in  its  Article  3,  are 
fourfold:  

•  To  contribute  to  the  achievement  of  the  objectives  listed  in  Article  2  of  the  Common 
Fisheries Policy (CFP)4, in particular the objective to restore and maintain populations 
of harvested species above levels which can produce MSY;  

• To contribute to the elimination of discards by avoiding and reducing unwanted catches, 

and by implementing the landing obligation;  

• To implement the ecosystem-based approach to fisheries management and contribute to 
the  achievement  of  Good  Environmental  Status  as  set  out  in  the  Marine  Strategy 
Framework Directive (MSFD)5;  

• To take measures in accordance with the best available scientific advice.  

Has  the  existence  of  a  MAP  facilitated  the  process  of  setting  of  TACs  for  the  relevant 
stocks?  

Not at all.  

To what extent has the MAP contributed to increasing the number of TACs set at MSY?  

Not at all.  

1  

2  

3  

4  

5  

https://www.pewtrusts.org/-
/media/assets/2016/06/balticseafisheriesanalysisofthepoliticallyagreedmultiannualplan2017.pdf?la=en&
hash=F5ED95946410C9B1223225E62D0B36068C2BAFCB. 
https://www.pewtrusts.org/en/projects/ending-overfishing-in-northwestern-europe/priorities/fishing-
limits. 
REGULATION (EU) 2016/1139 OF THE EUROPEAN PARLIAMENT  AND OF THE COUNCIL of 
6 July 2016 establishing a multiannual plan for the stocks of cod, herring and sprat in the Baltic Sea and 
the  fisheries exploiting those  stocks, amending  Council Regulation (EC) No 2187/2005 and repealing 
Council Regulation (EC) No 1098/2007. 
Regulation (EU) No 1380/2013 of the European Parliament and of the Council of 11 December 2013 on 
the Common Fisheries Policy. 
Directive  2008/56/EC  of  the  European  Parliament  and  of  the  Council  of  17  June  2008  establishing  a 
framework  for  community  action  in  the  field  of  marine  environmental  policy  (Marine  Strategy 
Framework Directive). 

80 

 
 
 
  
 
                                                 
Has  the  MAP  helped  in  dealing  with  difficult  cases  such  as  Eastern  and  Western  Baltic 
cod, Western herring or other sensitive stocks?  

Counterproductive.  

Multi-annual plans have been designed as a tool to implement the CFP on a regional level and 
to  provide  long  term  management  of  fisheries  resources.  Article  10.1  of  the  CFP  basic 
regulation provides details on the compulsory contents of the multi-annual plans, with Article 
10.1 (b) specifying that MAPs shall include “objectives that are consistent with the objectives 
set out in Article 2 and with the relevant provisions of Articles 6 and 9 [of the CFP]”; Article 
furthermore  10.1  stipulates  that  MAPs  shall  include  (e)  “conservation  reference  points 
consistent with the objectives set out in Article 2 [of the CFP]”.  

The  Baltic  MAP  objectives  set  out  in  Article  3  reiterate  the  aim  to  contribute  to  the 
achievement  of  the  objectives  in  Article  2  of  the  CFP  basic  regulation.  As  such,  the  Baltic 
MAP  should  contribute  to  ensuring  that  “the  maximum  sustainable  yield  exploitation  rate 
shall  be  achieved  by  2015  where  possible  and,  on  a  progressive,  incremental  basis  at  the 
latest by 2020 for all stocks”.  

Despite these clear and reiterated objectives, the MAP did not facilitate the process of setting 
annual  Total  Allowable  Catches  (TACs)  that  would  contribute  to  ending  overfishing  and 
restoring fish populations to healthy levels capable of supporting high yields.  

In  October  2016,  when  Baltic  TACs  were  for  the  first  time  set  under  the  provisions  of  the 
MAP, Council agreed to only five out of eight TACs for 2017 not exceeding scientific advice 
and  in  accordance  with  the  MAP  and  CFP  requirements.  The  CFP  only  allows  the 
postponement  of  MSY  exploitation  rates  beyond  2015  “if  achieving  them  by  2015  would 
seriously jeopardise the social and economic sustainability of the fishing fleets involved”. To 
date, no compelling socio-economic evidence justifying such delays in the Baltic Sea region 
has been made publicly available.  

In October 2017, six out of eight TACs for 2018 were set by Council not exceeding scientific 
advice and in accordance with the MAP and CFP requirements. Despite the existence of the 
MAP, the Council negotiations lasted the entire night until the early morning hours (around 
6.00 am), raising questions about the extent to which the rules of the MAP were sufficiently 
unambiguous, and the extent to which Council felt itself bound by those rules.  

In October 2018, progress was reversed. Despite the CFP’s requirement to progressively and 
incrementally end overfishing as the 2020 deadline approaches, only five out of eight TACs 
for 2019 were set by Council not exceeding scientific advice and in accordance with the MAP 
and CFP requirements. Following the proposal from the European Commission, Council set 
the TACs for western Baltic herring and eastern Baltic cod above the maximum scientifically 
advised levels. For central Baltic herring the Council agreed on a TAC based on the F
value – despite the well-known risks of fishing above the F

level.6 

MSY upper 

MSY 

It is therefore clear that, in these three instances, the existence of the MAP has not contributed 
to increasing the number of stocks managed in a way that would contribute to achieving the 
MAP’s  and  the  CFP’s  objectives.  The  MAP  has  also  not  contributed  to  more  stable  or 

6  

See ICES Special Request advice, page 2 

81 

 
 
                                                 
predictable decisions, nor has it eliminated the short-term and transactional nature of decision-
making on fishing limits.  

Furthermore,  it  is  clear  that  the  MAP’s  provisions  and  their  implementation  have  been 
inadequate and insufficient to restore and maintain vulnerable fish populations above biomass 
levels capable of producing maximum sustainable yield:  

•  Western  Baltic  herring:  in  October  2018  the  Council  decided  to  exceed  the  scientific 
advice for western Baltic herring by setting a TAC of 9,001 tonnes, when ICES advice 
was for zero catch (the Commission proposal, a TAC of 6,404 tonnes, also exceeded 
the  scientific  advice  for  zero  catches).  The  Council’s  decision  was  facilitated  by 
outdated reference points inscribed in the MAP’s annexes, which enabled ministers to 
set  the TAC following those reference points rather than the best  available scientific 
advice.7 
The biomass of western Baltic herring has remained below the limit reference 
)  since  the  introduction  of  the  MAP,  and  fishing  mortality  has  remained 
point  (B
throughout the same period.  
above F

lim

MSY 

• Eastern Baltic cod: the Council has set the TAC for eastern Baltic cod above scientific 
advice  since  2013,  and  the  adoption  of  the  MAP  has  not  changed  this  trend.  The 
Commission  and  the  Council  systematically  choose  to  allow  excessive  fishing 
pressure on the stock despite its critical state. While the eastern Baltic cod stock does 
not  have advice based on the MSY approach, the MAP specifies that in  these cases, 
“measures under the plan shall be taken in accordance with the best available scientific 
advice”  (Article  3(4)).  Moreover,  the  Baltic  Sea  MAP  specifies  that  for  stocks  for 
which  reference  points  are  not  available,  the  precautionary  approach  should  apply 
(Recital  17).  The  ICES  scientific  advice  was  clear  and  no  justification  has  been 
provided  for  setting  the  TAC  above  the  precautionary  approach  advice.  Finally, 
Article  9(2)  of  the  CFP  requires  that  where  targets  relating  to  MSY  cannot  be 
determined due to insufficient data, MAPs shall provide for measures ensuring at least 
a comparable degree of conservation as to those stocks with MSY assessments. This 
degree  of  conservation  has  not  been  awarded  to  eastern  Baltic  cod,  which  is  now 
below the limit reference point for biomass. ICES advice is for zero catches in 2020.  

lim

• Western Baltic cod: mortality on the stock has exceeded Fstock biomass falls below the 
limit  reference  point  (B
.  ICES  advice  for  2020  indicates  that  the  stock  remains 
between the limit and the precautionary biomass reference points  – and therefore far 
levels  since  the  entry  into 
from  levels  above  those  capable  of  producing  MSY. 
force of the MAP. Even when the stock biomass was clearly below the limit reference 
point,  Council  set  fishing  limits  exceeding  scientifically  advised  levels  and  failed  to 
adequately  implement  Article  5(3)  of  the  MAP,  which  states  that  once  ),  further 
remedial measures must be taken to ensure the rapid return of the stock to levels above 
those capable of producing MSY; such remedial measures may include suspending the 
targeted fishery and the adequate reduction in fishing opportunities. 

MSY 

7  

Recent amendments to the Baltic MAP, introduced during the negotiation of the Western Waters MAP, 
should prevent such issues in future. 

82 

 
 
 
 
                                                 
2. Discards and landing obligation  

To  what  extent  have  discards  been  eliminated  and  the  landing  obligation  actually  been 
implemented?  

Counterproductive.  

To  what  extent  has  the  MAP  contributed  to  achieving  the  current  situation,  notably  via 
discard plans and technical measures?  

Counterproductive.  

Discarding  remains  significant  in  several  fisheries,  and  in  some  cases  has  increased,  in 
particular when targeting Eastern Baltic cod and plaice.  

For Eastern Baltic cod discarding is “up to 50-70% according to information from the fishing 
industry instead of the 10-20% estimated by ICES”.8 
The 2019 ICES advice for plaice states 
that “discarding still takes place despite the fact that the landing obligation has been in place 
since  2017.  The  estimated  discard  amount  of  720  tonnes  in  2018  (approximately  30.5%)  is 
based  on  observer  data.  ICES  understands  that  this  is  not  in  accordance  with  the  current 
regulations”.9 

Discards have also persisted in the western Baltic cod fishery, with negligible landings of fish 
below the minimum conservation reference size.  

ICES has consistently stated that it considers its discard estimates to be an underestimate and 
has highlighted problems with observer access on board vessels. It has also identified illegal 
gear  modifications  which  ensure  higher  catches  of  juvenile  fish  to  be  present  in  Baltic 
fisheries.  

MSY 

The MAP has been a counterproductive factor contributing to discards because it has allowed 
for  fishing  above  F
and  has  not  provided  technical  measures  for  protecting  vulnerable 
stocks  such  as  eastern  Baltic  cod.  Rather  than  adopting  measures  to  effectively  avoid 
bycatches,  enhance  selectivity  and  ensure  control  and  enforcement,  Council  has  sought 
flexibilities to set setting fishing limits too high as a means to avoid choking scenarios. This 
cannot be justified as a contribution to implementing the landing obligation, as it contradicts 
the CFP’s overarching objective to end overfishing.  

The persistent and high levels of illegal discarding and the lack of reduction unwanted catches 
clearly  indicate  that  control  and  enforcement  has  thus  far  been  insufficient  in  enabling  the 
implementation of the landing obligation.  

8  
9  

ICES WKCONGA 2018 p.36 
http://ices.dk/sites/pub/Publication%20Reports/Advice/2019/2019/ple.27.24-32.pdf 

83 

 
 
 
 
 
 
 
 
                                                 
3. Ecosystem-based approach  

To what extent has the objective of implementing an ecosystem-based approach to fisheries 
management, and notably of achieving good environmental status by 2020, been achieved?  

Not at all.  

To what extent has the MAP contributed to the current situation?  

Counterproductive.  

Article  3(3)  of  the  MAP  stipulates  that  “The  plan  shall  implement  the  ecosystem-based 
approach  to  fisheries  management  in  order  to  ensure  that  negative  impacts  of  fishing 
activities  on  the  marine  ecosystem  are  minimised.  It  shall  be  coherent  with  Union 
environmental  legislation,  in  particular  with  the  objective  of  achieving  good  environmental 
status by 2020 as set out in Article 1(1) of Directive 2008/56/EC”.  

The definition of the ecosystem-based approach to fisheries management in Article 4(9) of the 
CFP basic regulation is as follows: “the ecosystem-based approach to fisheries management 
means  an  integrated  approach  to  managing  fisheries  within  ecologically  meaningful 
boundaries which seeks to manage the use of natural resources, taking account of fishing and 
other  human  activities,  while  preserving  both  the  biological  wealth  and  the  biological 
processes necessary to safeguard the composition, structure and functioning of the habitats of 
the  ecosystem  affected,  by  taking  into  account  the  knowledge  and  uncertainties  regarding 
biotic, abiotic and human components of ecosystems”.  

Other  than  the  reference  in  Article  3(3),  the  MAP  contains  no  provisions  allowing  for  real 
implementation  of  the  ecosystem  approach  or  achievement  of  good  environmental  status 
(GES) as required by the Maritime Strategy Framework Directive by 2020. For example, the 
MAP does not contain any provisions related to minimising bycatch of marine mammals and 
birds  (and  other  fish  species  than  those  commercially  exploited).  The  MAP  also  does  not 
address the negative effects of bottom trawling and other active gears on marine habitats, nor 
does  it  contain  provisions  to  take  inter  species  interactions  into  account,  which  would 
constitute  the  very  first  and  most  basic  step  in  implementing  an  ecosystem  approach.  For 
example, there is  no MAP  provision that would directly enable Council to  follow the  ICES 
advice to redirect the sprat fishery to northern areas of the Baltic Sea (to SDs 27,28) in order 
to secure enough food for Baltic cod in its area of distribution.  

4. Control and enforcement  

Are  there  specific  control  measure(s)  missing  in  the  MAP  or  in  the  Control  Regulation 
which would improve compliance with the MAP?  

A  control  system  based  on  Remote  Electronic  Monitoring  would  significantly  facilitate  the 
effective  implementation  of  the  agreed  TACs  and  of  the  landing  obligation,  as  it  would 
demonstrate whether total catches stay within the legally imposed limits and whether (illegal) 
discarding continues to occur.  

84 

 
 
 
 
 
The MAP also lacks linkage to the CFP’s Article 17 according to which preferential access to 
fish resources may be given for those fishermen who have a low impact on the environment, 
and who have a history of fishing in compliance with the law.  

5. Regional cooperation  

On  regional  cooperation,  to  what  extent  has  the  MAP  in  your  opinion  strengthened 
regional cooperation, including with stakeholders?  

Not much.  

The MAP has had little influence when it comes to cooperation with stakeholders.  

During the first phase of its development the MAP was intensively discussed (as part of the 
co-decision process between the European Parliament and the Council in 2014-2015, as well 
as during the trilogue negotiations which concluded in  2016). The MAP was  also  discussed 
inter-regionally,  with  fisheries  stakeholders  from  across  the  EU,  because  this  MAP  was 
expected to serve as a blue-print for other regions. However, on a Baltic - regional level there 
were too few initiatives related to the development or implementation of the MAP (there were 
no big conferences or events, for instance) to allow for increased stakeholder involvement in 
this topic.  

It is worth noting that BALTFISH existed prior to the MAP, and the introduction of the MAP 
itself  did  not  seem  to  have  either  a  positive  nor  a  negative  impact  on  the  frequency  of 
meetings, amount of joint recommendations or intensity of the regional work. Similarly, the 
MAP did not improve Baltic stakeholders’ meetings and processes in the Baltic Sea Advisory 
Council.  

The relatively low engagement of stakeholders is also patent in the Commission consultation 
on  the  evaluation  of  the  Baltic  Sea  MAP,  which  was  not  open  to  all  stakeholders  but  only 
targeted two key bodies (BALTFISH and the Baltic Sea Advisory Council).  

6. Socio-economic impact  

Has  the  overall  socio-economic  situation  of  the  fisheries  sector  improved  since  the  entry 
into force of the MAP?  

Not at all.  

Do  you  see  a  positive  correlation  between  the  implementation  of  the  MAP  and  the  socio-
economic situation of the fisheries sector?  

Not at all.  

Since  the  Baltic  MAP  came  into  force  two  important  Baltic  stocks  have  clearly  collapsed 
(western  Baltic  herring  and  eastern  Baltic  cod)  and  a  third  (western  Baltic  cod)  is  close  to 
collapse.  The  Baltic  MAP’s  provisions  have  proved  insufficient  to  protect  and  restore 

85 

 
 
 
 
 
 
vulnerable stocks, and in particular stocks lacking analytical assessment by ICES. Moreover, 
the  MAP  includes  no  provisions  to  support  the  introduction  of  preferential  access  to  fish 
resources for those fishermen who have a low impact on the environment, who use selective 
fishing gears and who have a history of fishing in compliance with the law.  

The depleted situation of these stocks and the corresponding reduction in fishing opportunities 
has  had  a  negative  impact  on  the  socio-economic  sustainability  of  the  sector  in  the  region, 
with more appeals being made to access public aid (for instance, in the form of subsidies for 
temporary cessation).  

7. Overall assessment  

What is your overall assessment of the Baltic MAP?  

Negative.  

The Baltic MAP has not been successful in delivering on its objectives nor on the aims of the 
CFP  for  the  fish  populations  and  fisheries  it  covers.  Not  only  has  it  proved  unsuccessful  in 
restoring stock biomass, eliminating discards and minimizing the negative impacts of fishing 
on  Baltic  ecosystems,  but  the  content  of  the  MAP  made  it  very  unlikely  that  it  could  ever 
achieve its stated aims, primarily due to weaknesses in its provisions and a lack of ambition.  

From the proposal made by the European Commission through the inter-institutional process 
to agree the MAP, the content of the plan was driven by political pressure to downgrade the 
ambition, to maintain status  quo fishing practices and to  provide flexibility to  fish at  higher 
rates  than  F
.  This  ensured  the  level  of  ambition  was  low,  preventing  the  inclusion  of 
measures to restore fish stocks and to achieve wider environmental improvements.  

MSY

Agreement  of  this  weak  plan  was  followed  by  under-implementation  of  even  these 
unambitious  requirements,  further  degrading  management  of  Baltic  Sea  fisheries.  The  data 
show that the Baltic MAP has allowed overfishing of Baltic stocks to continue, with the most 
telling case being that of the eastern Baltic cod stock which, year-on-year, has seen TACs set 
above  scientific  advice  (and  by  as  much  as  double  in  one  instance).  While  the  biomass  of 
these  stocks  suffered  inevitable  depletion  as  a  result,  the  MAP  also  failed  to  deliver  other 
important  fisheries  management  measures,  such  as  the  development  of  effective  bycatch 
avoidance techniques, that might have helped mitigate these impacts.  

Since  the  introduction  of  the  MAP  there  has  been  no  clear  progress  towards  the  MSY 
objective  for  all  stocks.  Decision-making  is  not  simpler,  more  stable  or  more  predictable. 
Many of the stocks covered by the MAP continue to decline, and the bad state of fisheries is 
reflected  in  a  poor  economic  performance,  with  several  communities  and  member  states 
repeatedly  asking  for  subsidies  for  temporary  cessation.  The  environmental,  social  and 
economic  sustainability  aimed  for  by  the  CFP  has  clearly  not  been  delivered  through  the 
provisions of this MAP. 

86 

 
 
 
 
 
ANNEX 

87 

1 In 2018 the TAC was increased during the year to 95.566 tonnes 

Fmsy pointFmsy upperFmsy pointFmsy upperGulf of Bothnia herring (HER/30/31)1103.254120.872103.254120.872160.490131.828No140.998165.586140.998140.998157.047104.164YesWestern herring (HER/3BC+24)224.79730.99224.79726.27427.07324.894Yes28.40135.08228.40128.40130.57726.683YesCentral herring (HER/3D-R30)3 4 177.505221.850177.505177.505194.984160.006Yes191.129238.189191.129191.129205.967175.944YesGulf of Riga herring (HER/03D.RG)430.62334.91230.62334.91536.69634.892No27.42931.12127.42931.07432.87831.709YesEastern Baltic cod (COD/3DX32.)3 5 641.14341.14347.01426.288na24.92730.85735.55821.482naWestern Baltic cod (COD/3BC+24)6 7 8 910.36310.36310.36312.72013.81810.903No1.5883.8351.5885.5976.9785.775NoPlaice (PLE/3BCD-C)104.0344.0344.0342.406Yes7.8627.8628.1813.089YesSprat (SPR/3BCD-C)3184.336190.630184.336202.320210.348206.178No282.349292.240282.349260.993265.108251.212YesTotal556.287576.055619.783694.457597.395704.683704.683696.911742.294620.05821.34524.92720162017COM proposalinitial TACadapted TACLandingsTAC at MSYCOM proposalinitial TACadapted TACLandingsTAC at MSYICES adviceICES advice4.0647.862Fmsy pointFmsy upperFmsy pointFmsy upperFmsy pointFmsy upperGulf of Bothnia herring (HER/30/31)170.61791.45270.61784.559111.27197.480Yes88.70388.70388.70388.70399.83088.645Yes65.018na65.10865.108naWestern herring (HER/3BC+24)217.30917.30912.98717.30920.18318.531Yes6.4049.00110.5869.619No2.6513.150NoCentral herring (HER/3D-R30)3 4 238.229295.937238.229229.355243.557219.537Yes136.464170.360170.360170.360192.016174.263Yes153.384190.107153.384153.384YesGulf of Riga herring (HER/03D.RG)428.99933.27528.99928.99930.16829.418Yes31.04435.34931.04431.04431.79431.281Yes34.44539.15734.44534.445YesEastern Baltic cod (COD/3DX32.)3 5 622.27528.38831.94412.706na24.11224.11227.3065.777na2.0002.000naWestern Baltic cod (COD/3BC+24)6 7 8 96.066na5.5975.5975.5975.681Yes13.26722.2387.3409.5159.3437.485Yes5.1058.8663.0653.806YesPlaice (PLE/3BCD-C)106.2727.0767.8474.630No10.12210.12210.8365.669Yes6.8946.894YesSprat (SPR/3BCD-C)3262.310271.308262.310262.310275.142263.999Yes270.772280.121270.772270.772284.830270.811Yes203.027210.147203.027210.147YesTotal651.867647.286663.593725.709651.982565.559608.857613.629666.541593.550467.873470.574478.9346.89400adapted TACICES adviceLandingsinitial TACTAC at MSY2020LandingsTAC at MSYCOM proposalinitial TACTAC at MSYCOM proposal20182019COM proposalinitial TACICES adviceICES adviceadapted TAC06.27210.12222.06515.187 
 
 
 
 
 
2 The figure indicated as ICES advice is 50% of the figure given by ICES in its advice for SD 20-24 

3 The figures indicated as ICES advice are reduced by the Russian share (9.5% for central herring, 5% for cod, and 10.08% for sprat) 

4 The figure indicated as ICES advice takes account of the mixing between central herring and Golf of Riga herring 

5 The TAC proposal for 2017 and 2020 was made after the adoption of the formal Commission proposal 

6 For 2016-2018 the figures indicated as ICES advice take into account the occurrence of the two cod stocks in subdivision 24 

7 The figure indicated as ICES advice relates to commercial catches only 

8 For 2016 the figure takes into account additional recreational catches of 1028t 

9 The TAC proposal for 2016 and 2017 was made after the adoption of the formal Commission proposal 

10 The figure indicated as ICES advice is a combination of the ICES advice for subdivisions 24-32 and a certain share for subdivisions 21-23 indicated in the ICES advice 

88