Concerning baltic salmon

Concerning Baltic Salmon – illegal, misreported and unreported commercial fishing, kesäkuu 2011 

We are writing to share with you our deep concern with regard to effects of illegal and unreported fishing for salmon in the Baltic Sea. We recognize that misreporting of catches probably occurs in all different types of fisheries, fisheries zones and countries but at the same time we are extremely worried over reports of serious cases of systematic illegal and unreported fishing for Baltic salmon.

The International Council for the Exploration of the Sea (ICES) working group on Baltic Salmon and Trout recently highlights large scale misreporting of salmon as sea trout. ICES reports that ?catch per unit effort in the Polish offshore fishery indicates large scale misreporting of salmon as sea trout and this misreporting constitute a significant amount of the unreported catches?  (ICES Advice 2010). ICES latest statistics show that ?additional Polish catch? for the year 2010 was an estimated 70 511 salmon, this compared to a total reported catch for all nine fishing nations of 167 923 salmon  (ICES CM 2011/ACOM:08). ICES figures show that ?additional Polish catch? is 41 % over and above the reported total catch. Furthermore ICES state that ?the effort in the longline fishery is predicted to increase further, and may result in a further increase in the exploitation of salmon in the Polish offshore fishery because of the misreporting of salmon as trout? (ICES Advice 2010).

We the undersigned represent over 100 000 recreational fishers in Sweden and Finland, 14 regional councils spread over nearly 100 000 km² of northern Sweden and regional government of more than 100 000 km² of northern Finland. Located within our geographical boundaries are seven Baltic salmon rivers that together delivered more than 74% of all commercially caught Baltic salmon in 2010. Two rivers the Torne and Kalix rivers are of key importance producing over 59 % of all commercial landings in the Baltic Sea 2010. We therefore are one of the largest stakeholders in the Baltic salmon resource.

Our region is one of the least populated and isolated areas in Europe and contains several councils with the lowest average household incomes within Sweden and Finland. Utilization of our natural resources such as salmon is vital to maintain our economic competitiveness, create jobs and stop reduction in our population. Therefore we are very concerned when we receive reports of serious misreporting of catches of fish that are eventually destined to return to our region for spawning. The increased exploitation of salmon due to large scale misreporting of catch has a direct effect upon the potential for economic development of our region by hindering tourism based on sport fishing for salmon and small scale commercial fishing.

We now have a situation where ICES scientifically recommended catch for sustainable fishing for Baltic Salmon is only 120 000 salmon, the EU commissions total available catch (TAC) is 250 000 salmon (2011) but actual catch including ?additional polish catch? is estimated by ICES WGBAST to be 320 015 salmon. This means that the quota is being exceeded by several thousand salmon per year, while the salmon quota is already double that which scientists recommend.

From the 8th of April 2011 the EU has established a community control system for ensuring compliance with the common fisheries policy. This allows for the ability for control from net to plate by covering all stages of the supply chain and allows inspectors to detect wrongdoings at any point in the chain. We applaud this new EU policy initiative and believe that implementation could lead to a major decrease in the misreported catch that ICES highlights. ICES state that ?large-scale misreporting of salmon as sea-trout and also unreporting of catches in the Polish sea fishery could be prevented by an improved inspection by the Polish and EU fisheries authorities? (ICES CM 2011/ACOM:08). With the aid of the new regulation it should not be possible as in the current situation for salmon catch to be misreported as another species and thereby allow catches of 400% over and above a single nation?s quota.

We acknowledge and thank EU DG Mare for your work to produce a new management plan for Baltic salmon but we must underline the importance of this being aided by implementation of the new control regulation to create a transparent and reliable control of fisheries. Within our region we already are trying to improve on compliance and control of fisheries by increasing control budgets and more action in control. We therefore urge the European Union to immediately utilize the new compliance regulations to address the above issues of misreported and illegal salmon fishing.

We look forward to implementation of the control regulation and wish to be informed about its effect upon misreported and illegal fishing for Baltic salmon. The Swedish national sport fishing association, Finnish federation for recreational fishing, the regional council of Lapland and the association of local authorities in Norrbotten look forward to working with you in concern of control and regulation of fisheries and we thank you for the work you are currently doing to protect our common resources.

Kind regards,     

Stefan Nyström
Sveriges Sportfiske- och Fiskevårdsförbund

Ilkka Mäkelä
Suomen Vapaa-ajankalastajien Keskusjärjestö

Karl Petersen
Kommunförbundet Norrbotten

Hannes Manninen
Hallituksen puheenjohtaja
Lapin Liitto