NGOs request legal scrutiny of Ministers decision to continue fishing on Baltic herring stocks in decline

CCB • January 16, 2024

Did the fisheries Ministers act in accordance with the law when setting Baltic fishing quotas for this year? We, Coalition Clean Baltic (CCB), seriously question this and will tomorrow  ask the EU Council to review its decisions to continue removing large quantities of herring even when stocks are far below safe levels. It is time to get legal clarity of what considerations must be taken when fisheries Ministers sit in all night sessions and decide on issues of detrimental importance to the ecosystem.

16 January 2024 - In light of the very poor status on the Baltic Sea and its fish stocks, CCB is requesting an internal review from the Council to seek explanation of how the past October AGRIFISH Council decisions are valid and meet the legal requirements in place.


“The continued decline of our stocks caused by the Ministries continuously acting like it’s business as usual has to stop. It’s time we demand legal action of the flagrant disregard for the law and the environment”, says Nils Höglund, CCB Fisheries Policy Officer.


The legal situation regarding human activities at sea is admittedly fragmented and seemingly unclear in regards to legal interpretation. However, it is clear that there are safeguards in place to prevent the setting Total Allowable Catches (TACs) too high or even to allow any fishing at all when the situation is serious. These safeguards have now been breached and in doing so, the Ministers have also made it nearly impossible to reach any of the environmental targets their own governments have supported just a few months ago [1] .


“Setting fishing quotas cannot be done in isolation from requirements set by EU environmental legislation or international agreements [2], nor from the ecosystem, which needs to sustain itself. Coastal fishermen, NGOs and citizens alike ask themselves if the Ministers have lost all reason when they allow continued fishing of a stock after stock disappearing from the coast. We certainly ask if it’s even legal to make such decisions.” continued Nils Höglund.


What considerations must be taken by the AGRIFISH Council of Ministers when deciding on fishing opportunities annually? This is the core of the request for internal review that CCB is submitting. Specifically, CCB wants clarity into how the rules should be interpreted, considering in particular the herring stocks in the central Baltic Sea. This stock was indicated by ICES advice [3] to be below safe levels, and also noted that the stock will likely not grow above the lowest reference level in the year 2025 even with zero fishing in 2024.


The right to request an internal review of the Council's decision is given to NGOs such as CCB via the EU Aarhus regulation (Regulation (EC) No 1367/2006). This is a rule CCB has not utilized earlier. It is a crucial scrutiny right given to civil society and private citizens to be able to question the legality of public decision making.


ENDS


Background

The AGRIFISH Council in October disregarded the Commission proposal and instead opted to keep a targeted herring fishing open and allow a large sprat fishery with known bycatch of herring, and also big issues with misreporting herring as sprat, to continue. CCB thinks this decision is illegal and seeks clarity as to what considerations should be taken and what the correct interpretation of all the rules in place implies for Council decisions on fishing opportunities.


In doing so, CCB considers it clear that the Council decided to ignore the safeguards and limits and they ignored the poor state of the Baltic Sea, the food web dynamics and clear warnings that genetically distinct sub-populations of also herring are at risk. There is no viable justification for not acting in time and the margin of discretion the Council may have to set any TAC is very low.


CCB makes the case that the Council did not act on all the information available and they did not act with caution as stipulated by the precautionary approach in the Treaty on the Functioning of the European Union (TFEU), Common Fishery Policy (CFP) etc. even when information is missing, yet risks to the stocks are known.


Notes

Coalition Clean Baltic (CCB) - Is a politically independent, non-profit association, which unites 23 NGOs, with over 1 500 000 members in all countries around the Baltic Sea. The main goal of CCB is to promote the protection and improvement of the Baltic Sea environment and its natural resources for present and future generations. More info at: www.ccb.se


[1] EU regulation 2016/1139 (as amended) establishing a multiannual plan for the stocks of cod, herring and sprat in the Baltic Sea. See specifically article 4.6 and article 5 outlines actions to be taken when stocks fall below safe levels.


[2] The key questions are related to the rules in the Baltic Sea multi annual management plan for herring, sprat and cod, to the rules in the Common Fisheries Policy (CFP) and the environmental objectives in primarily the Marine Strategy Framework Directive (MSFD). Also important is the link to the Birds and Habitat Directive as well as international treaties and regional agreements.


[3] ICES advice for fishing opportunities in the Baltic Sea in 2024:
https://www.ccb.se/scientific-advice-states-that-baltic-sea-herring-stocks-are-below-safe-levels-ngos-stop-while-there-is-still-time

CCB & other NGOs and small scale fishermen´s reaction on ICES advice for fishing opportunities in the Baltic Sea in 2024:
https://www.ccb.se/scientific-advice-states-that-baltic-sea-herring-stocks-are-below-safe-levels-ngos-stop-while-there-is-still-time
 


Contacts

Nils Höglund (English, Swedish)
nils.hoglund@ccb.se

+4
6708679249


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Coalition Clean Baltic – CCB is a politically independent network, uniting 28 environmental non-profit organizations, as well as partners and experts from 11 countries surrounding the Baltic Sea. The main goal of CCB is to promote the protection and improvement of the environment and natural resources of the Baltic Sea region by encouraging new and constructive approaches and engaging people to become part of the solution instead of part of the problem. CCB Secretariat is based in Uppsala, Sweden. About the Role Coalition Clean Baltic (CCB) is seeking a Marine Policy Officer (parental leave cover) to join its International Secretariat and contribute substantively to regional and EU-level marine advocacy, with a particular focus on the Baltic Sea. The Marine Policy Officer will support the implementation of EU and international marine environmental policy frameworks — notably the EU Marine Strategy Framework Directive (MSFD), the EU Maritime Spatial Planning Directive (MSPD) and the HELCOM Baltic Sea Action Plan (BSAP) . All work is grounded in the promotion of ecosystem-based management. The role includes close collaboration with the rest of the Secretariat team as well as CCB member organisations to deliver policy initiatives, advocacy actions, and strategic programme objectives. The Marine Policy Officer will also support the International Secretariat in fundraising, with a focus on the EU LIFE operational grant application. Key Responsibilities Policy & Advocacy Support the implementation of CCB’s strategic plan on marine biodiversity policy. Contribute to marine policy advocacy at EU and at Baltic Sea regional levels (e.g. HELCOM, EU Commission expert groups). Provide input to the implementation and revision of the Marine Strategy Framework Directive. Collect evidence and views to provide NGO inputs to the forthcoming EU Ocean Act and related initiatives. Support the implementation of the Helsinki Convention and Baltic Sea Action Plan. Engage in the revision processes related to the Marine Spatial Planning Directive (MSPD). Programme & Grant Delivery Provide critical support in fundraising, i.e. project proposal development, especially for securing core grant funding (e.g. for the EU LIFE Programme and potentially Horizon programme). Contribute to CCB´s project management, implementation and reporting activities for various projects. Coordination & Monitoring Closely coordinate marine biodiversity policy work with CCB member organisations. Monitor global, EU, and regional marine policy developments. Liaise with partner NGOs and civil society organisations. Communications & Policy Products Draft position papers, policy briefings, consultation inputs and technical reports on relevant files. Support communications and outreach on marine policy issues. Help organise workshops, conferences, and stakeholder events. Represent CCB in policy dialogues, expert groups, and stakeholder forums at the EU and Baltic Sea level. Cross-organisational Support within the Secretariat and its members Contribute to other CCB thematic working areas as required. Profile We are seeking a policy professional who is: Solutions-oriented and adaptable Experienced in advocacy or campaigning Collaborative and team-driven Passionate about marine conservation Organised, diplomatic, and stakeholder-confident Required Qualifications & Experience Demonstrable professional experience in marine or environmental policy. Working knowledge of key EU frameworks, particularly the EU Marine Strategy Framework Directive (MSFD). Knowledge of Helcom BSAP is an asset. Postgraduate qualification in marine science, ecology, conservation, water management, or related discipline with substantial marine focus. Eligibility to work and travel within the EU (citizenship or valid permit) with residency in Sweden. Excellent written and spoken English. CCB also welcomes applicants from broader environmental policy/law backgrounds who can demonstrate relevant knowledge. Desirable Skills Experience within the NGO or civil society sector preferred. Advocacy or campaigning experience within the EU, the Baltic Sea or international environmental policy processes. Working knowledge of a Baltic Sea region language (e.g. Swedish, Danish, Finnish, German, Polish, Latvian, Lithuanian, Estonian).
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