LIFE responds to the public consultation on the European Commission’s proposal to modify the Multiannual Plan (MAP) for the Baltic Sea.

A feedback period was opened between December and January 2024 to provide comments on the European Commission’s proposal to amend the Baltic MAP. LIFE together with many other organisations provided comments and shared their opinion on  the proposal put forward by the Commission. The document and all responses, mostly in disagreement with the Commission’s proposal, can be found here. 

In its proposal the Commission explains that Article 4.6 of the Baltic MAP can lead to situations where it is inconsistent due to other rules of the MAPs governing the fixing of fishing opportunities and have potentially severe socioeconomic implications. On the one hand, the 5% rule may mean that fishing opportunities cannot be set and the targeted fishery must be suspended. On the other hand, the safeguard provisions in the MAPs require the adoption of remedial measures to bring the stock above Btrigger, based on a case-by-case assessment on the appropriateness for choosing such measure, in accordance with the criteria set out in the MAPs. Moreover, the MAPs refer to the possibility, and not the obligation, to suspend the targeted fishery.  Therefore, the Commission proposes to delete the MAP Article 4.6 (fishing opportunities shall in any event be fixed in such a way as to ensure that there is less than a 5 % probability of the spawning stock biomass falling below Blim). The Commission proposal also states that in 2023, the Commission discussed the 5% rule with stakeholders, notably the Baltic Sea Advisory Council and BALTFISH: “The majority of stakeholders expressed their deep concerns about the consistency of the 5% rule with the other rules of the MAPs governing the fixing of fishing opportunities and its potentially severe socio-economic implications”.

LIFE’s response can be found below:

“The Commission proposal is disappointing. The question of what to do once stocks are under MSY Btrigger and Blim is unresolved and the proposed amendment leaves us in a worse position than before. The proposal undermines the socio economic viability of the fishing industry, in particular the small-scale fleet segment, by removing a key fish stock recovery mechanism. There are clearly issues with the 95% rule, which are highlighted in unselective mixed fisheries. If fisheries are selective and do not require bycatch quotas then it is less of an issue. Ensuring fish stocks are above Blim is essential for the viability and sustainability of fishing companies, and Article 4.6 therefore has positive benefits. A key issue is the scientific calculations upon which Blim, Fmsy, and the associated reference points are based on. We note with concern and disappointment that the ICES does not use BMSY as the baseline for assessing which level of fishing mortality corresponds with MSY. This is a key problem and one of the reasons why so many stocks in the Baltic have fallen below reference levels. The key is to ensure that stock biomass is at healthy levels (above BMSY). The MAP has failed to achieve it but the amendment will likely worsen the situation. It certainly does nothing to ensure that the socio economic possibilities for the fishery are improved. As such Article 4.6, the Baltic MAP and other management plans should be amended to specify that BMSY is the target reference point and subsequent fishing mortality reference points are derived from this.”