To: DG MARE E2

Comments on the LOT1 selectivity report in connection with the Technical Workshop on selectivity in Baltic cod fisheries, in Brussels on 4 September

As representatives of Coalition Clean Baltic (CCB) and the Fisheries Secretariat (FISH) at the workshop, we would like to put forward our comments on the material presented at the workshop and the draft full study report Collaboration between the scientific community and the fishing sector to minimise discards in Baltic cod fisheries (MARE/2010/11) LOT1 . We have chosen to emphasise some gaps and shortcomings in the analysis and presentations of the project that we believe it is crucial to consider if selectivity in Baltic cod fisheries, as well as the status of the eastern cod stock, is to be improved.

According to the draft report summary, the ”main aim of this study was to find technical solutions, both economically and biological sustainable, to mitigate the discards of cod in the Baltic Sea cod fishery. The aim of the project was divided into three main tasks: • Assessing the present knowledge on discard and causes of discard in the Baltic cod fishery, and exploring temporal and spatial distribution patterns of discard sensitive size classes of cod and fishery effort in the Baltic to avoid discards. • Identifying technical solutions and suggest final technical measures to further mitigate discards in the trawl fishery for Baltic Sea cod. • Evaluating the impact of the proposed technical solutions and technical measures on stock assessment and the impact on the economy of the fisheries concerned”

1. A lack of long-term perspective and reflection on the overarching policy objectives for Baltic cod in the CFP as well as in EU environment legislation (MSFD) – relevant to task 3 above and a matter of policy coherence.

A fundamental shortcoming of both the presentations at the workshop and the draft report is the lack of a more long-term perspective on the potential to reduce the bycatch/discard of cod in the Baltic. There are a couple of aspects of this that we feel are particularly relevant. a) We have in place overarching objectives for the cod stocks that all management measures should aim for, some of them with a clear timetable. In the new basic regulation for the Common Fisheries Policy (CFP), the fundamental objectives include management of stocks above Maximum Sustainable Yield, as well as application of an ecosystem-based approach. But more importantly in this case, the EU Marine Strategy Framework Directive, which is now gradually being implemented by the Member States, contains a number of indicators of good environmental status (GES) relevant for the Baltic cod fishery, and in particular:

“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” (MSFD, 2008).

In order for Member States to implement the Directive and achieve GES, the population age and size distribution have to be taken into consideration when developing technical measures to tackle unwanted bycatch (discard), so that the new measures are not counterproductive.

While it has improved substantially in the past 10 years, the eastern cod stock should still be considered to be in a recovery stage after the historically low abundance in the late 1990s and early 2000s. Neither its size composition nor its spatial distribution is fixed, and both are likely to change over time. However, by maintaining a fishing pattern targeting primarily small, barely sexually mature individuals the likelihood for changing these factors in a positive way – moving us towards GES – is severely reduced.

We regret that the main focus of the LOT1 project has been to strictly adapt the Baltic cod trawling industry to the current status of the eastern cod stock and that a more visionary approach, aiming to fulfil obligations regarding size and spatial distributions, is not really considered b) We appreciate the parts of the project focusing on more adaptive management in terms of where the fishing takes place, such as “moving on practises” and temporary closures, as well as the few modelling scenarios which were run to study how the selectivity of different trawls is affected by different size distributions of the cod stock.

Some efforts were made to look at earlier stock compositions, when estimating the effectiveness of different measures (primarily a lowering of the Minimum Landing Size and a modest increase in the trawl cod end mesh size to 130 mm), but they were insufficient and the fullest results presented were based solely on current stock status and composition.

However, there is still a lack of reflection on the potential impact of different measures suggested in the presentation and the report on key population features in a short, middle and longer time frame. We miss a more detailed assessment of the effects different proposed measures would have on stock abundance, the population structure and age and size at maturity – all of which affects the long term prospects of the stock. Step 2 would be to also look at how the likely changes caused by the measures then would affect the further effectiveness of the chosen measures; more forward projection. To summarise, we would have liked to see included attempts to answer the following questions:

Are proposed measures in line with overarching objectives? What measures would make an attainment of the overarching objectives more likely? How would the short, medium and long-term impacts of the measures on the stock affect the effectiveness of the chosen measures?

2. Ongoing revisions of other management measures not sufficiently considered when making recommendations on measures to reduce discards – relevant to task 2 and 3.

One of the main conclusions presented at the workshop and in the draft report is that if a modified Bacoma trawl with larger meshes in the cod end would be used in combination with a reduction of the current minimum landing size (in future minimum conservation reference size) from 38 to 35 cm, the discard (or unwanted catch, as we like to call it) of cod would be reduced considerably.

While we understand some of the arguments underpinning this conclusion, we do not think this is necessarily the best way forward. A wider range of gear modifications could have been investigated more thoroughly, as well as gear shifts from trawl to other methods. Our main objection, however, is related to the lowering of the legal minimum landing size, which rather than increasing selectivity in the Baltic cod trawl fishery, moves “the goal post” and removes a strong incentive to improve selectivity. It also raises potential issues related to the extensive EU debate on the risk of creating markets for juvenile fish in relation to the reform of the CFP and the implementation of the agreed discard ban, as well as the expressed aim that future minimum conservation references sizes (MCRSs) should be in line with median size at first reproduction – ie allow fish in the stock to reproduce before it is caught.

We strongly believe that a reduction of the minimum landing size (MCRS) – in the context of other management measures currently under discussion – would constitute a considerable risk to the overall development of the eastern cod stock. As part of implementing the discard ban, a “bonus TAC” has been suggested, compensating fishermen for having to retain and land undersized fish by adding the estimated current discard to the proposed/agreed TAC, leading to an overall increase of the TAC.

A lowering of the MCRS together with a “bonus TAC” will not effectively protect larger fish as some argue, but will eventually mean that more small fish is landed while larger individuals are caught to the same extent as today (a modest improvement in catch composition could be expected from the increase in mesh size); a scenario that would maintain the stunted population size of the eastern Baltic cod. Depending on the market response, this may be further exacerbated by low prices for smaller cod, encouraging continued [illegal] discarding and increased effort to use the additional quota (bonus TAC) to catch more large individuals.

Furthermore, taking a more long-term perspective, we have to consider the latest ICES advice for the eastern Baltic cod stock, which includes a revision of the estimated fishing mortality at Maximum Sustainable Yield (FMSY) from FMSY = 0.30 to a range of FMSY = 0.46–0.55. Once the current cod management plan is replaced with the future multi-annual multispecies management plan for the central Baltic stocks (cod, herring and sprat), this new FMSY may be applied and would greatly increase the fishing pressure on the eastern Baltic cod. All this considered, we strongly advice against reducing the minimum landing size (MCRS).

3. A failure to sufficiently include all types of “discard” and gear alternatives in the analysis – relevant to task 1.

All types of discard, also [unintentional] underwater or unaccounted discard, should be included when analysing the selectivity in the Baltic cod fisheries. Specific estimates for and comparisons of different types of trawls and grids, as well as the selectivity of other used, or potential, gears should have been calculated and incorporated into the report. Much better data on the survival of underwater losses/escapees from the catch is necessary.

Cod is regarded as relatively resistant to physical damage. However, eastern Baltic cod is considered to be exposed to constant stress due to the low salinity of the Baltic Sea and might therefore be more vulnerable to physical stress, such as passing through meshes in a trawl. There are indications that cod are negatively affected in areas exposed to extensive trawling.

In the vicinity of the island of Bornholm, Mellergaard and Bagge (1998) observed a high occurrence of skin ulcerations on cod of 24–28 cm length, which is the size range most likely to escape. Most skin ulcers occurred bilaterally on the trunk which, according to the authors, strongly indicated trawl-induced damages and they also suggested that a large proportion of the damaged fish were likely to die of secondary infections during warmer conditions in summer. The mortality of mostly undersized fish that escape from trawls, so-called unaccounted discard, is little known but may be considerable depending on the species. Surronen et al. (2005) show that the mortality of cods passing through the trawl can vary between insignificant to 15 %, depending on i.e. temperature. Although these numbers are only indicative, the unaccounted underwater mortality can be significant considering that the total biomass of cods passing the trawl is estimated to be significantly larger (e.g 214 kg cod must have entered the trawl for a catch of 100 kg according to the report) and, if counting individuals, a multiple number of individuals passing the trawl compared with those who are actually caught.

However, this unaccounted discard is only studied for cods that have escaped during the actual towing phase. The survival of the large fraction of individuals that escape during the haul-back process, especially in side trawlers, has not been investigated at all in the Baltic Sea. There are reasons to believe that the mortality among these individuals is considerable since the survival rate is dependent on the time that the fish has been trapped in the trawl; most individuals actually escape through the trawl late in the fishing event, and a considerable part escape during hauling of the net (Herrmann et al. , 2013) and, in general, the survival rate is lower for exhausted individuals. Furthermore, when escapements take place at the surface, the fish are more likely to have experienced physiological damages due to the rapid and drastic change in water pressure (Tschernij & Holst, 1999). Thus, if the survival is low, this overlooked factor might constitute a significant and unaccounted discard of undersized cod.

In his presentation on 4 September, Daniel Stepputtis showed how flatfish and undersized cod escaped through the Freswind grid, and we found that estimates and comparisons of mortality of escapees were missing in the report for different trawls and selective modification in trawls. Also the selectivity of other gears, e.g. gillnet and longlines, as well as for gears potentially to be used in the Baltic cod fishery, should be compared to all types of discard in the trawling fishery.

Sincerely

Gustaf Almqvist, Fisheries Policy Officer Coalition Clean Baltic Östra Ågatan SE – 753 22 Uppsala Phone: +46 739 400092 Email: [email protected]

Niki Sporrong, Director Fiskesekretariatet (FISH) Prästgatan 9 111 29 Stockholm Phone: +46 8 250790 Email: [email protected]

References: Herrmann, B., Mieske, B., Stepputtis, D., Krag, L. A., Madsen, N. and T. Noack (2013). Modelling towing and haul-back escape patterns during the fishing process: a case study for cod, plaice, and flounder in the demersal Baltic Sea cod fishery. ICES Journal of Marine Science , 70: 850– 863.

Mellergaard, S. and O. Bagge (1998). Fishing gear-induced skin ulcerations in Baltic cod, Gadus morhua L. Journal of Fish Diseases 21: 205–213. doi: 10.1046/j.1365 2761.1998.00095.x

MSFD, 2008. 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). Official Journal of the European Union, L 164/19-39.

Suuronen, P., Lehtonen, E. and P. Jounela (2005). Escape mortality of trawl caught Baltic cod (Gadus morhua ) – the effect of water temperature, fish size and codend catch. Fisheries Research 71: 151–163.

Tschernij, V. and R. Holst (1999) Evidence of factors at vessel-level affecting cod end selectivity in Baltic cod demersal fishery. ICES CM 1999/R:02