STECF have raised skepticism on two issues in the BALTFISH discard ban plan for the Baltic Sea; namely, that exemptions for seal damaged fish will make the ban difficult to control and that it is more appropriate to use de minimis rule also for seal damaged fish. These concerns have earlier been called for by FISH, and other NGOs active in the region, in our communication with BALTFISH.
In late July, the Scientific, Technical and Economic Committee for Fisheries (STECF) published their review on the discard ban plan proposal from BALTFISH, together with plans from some other regions that they have received so far. STECF functions as an advisory committee for the European Commission in fisheries management and basically support the BALTFISH discard ban plan. However, they raise some important concerns about some elements of the proposal. Especially these relate to the danger of having exemptions for seal damaged fish in the plan. STECF notes that having such exemptions will make the enforcement of the ban more difficult to control (it will be difficult to evaluate if discarded catch actually is seal damaged or not) and stresses that all catches have to be documented. Although STECF consider the de minimis exemption not to be fully justified to be used for seal damages catch (and furthermore comment that is not clear how it in that case would be counted) they suggest that if might be appropriate to use the de minimis rule in this case anyway โ at least a short-term perspective.
Furthermore and in line with the BALTFISH proposal, STECF thinks that it is acceptable to exempt salmon and cod caught in some static cage gears (traps, fykenets etc.) since mortality of discarded fish using these techniques is considered to be low, that is,ย if caught fish are handled correctly. However, they advices that more work is needed on survivability of these species after having been trapped and released using these gears, especially in different environmental conditions.
STECF also notes that they think that it is biologically sound to reduce the minimal conservation reference size (MCRS) for cod from 38 to 35 cm, although they comment that the current market restriction of not handling individuals below a certain weight might be a driver for fishermen to continue discarding lean cod (even though they are โฅ 35 cm).
For more reading, see document below ย (you find the Baltic Sea section on pages 20-21).