The Finnish coastal fisheries action groups' letter to Virginijus Sinkevičius, the Commissioner for Environment, Maritime Affairs and Fisheries
In their reply to the Commissioner Virginijus Sinkevičius The Finnish coastal fisheries action groups emphasize the important role of the coastal small-scale fisheries in the Baltic Sea region. The Finnish coastal groups ask EU Parliament's and Commissioner's contribution in abolishing the trade ban on seal products in the European Union.
27 May 2020
To: Mr Virginijus Sinkevičius
Commissioner for Environment, Maritime Affairs and Fisheries
We are grateful for your answer to the Baltic Sea Seal and Cormorant TNC project’s open letter, dated 17 December 2019, regarding seal- and cormorant-caused damages to the Baltic Sea coastal fisheries.
We the representatives of the Finnish coastal fisheries action groups would like to emphasise the character of small-scale coastal fisheries and their important role in the Baltic Sea region.
We noticed that the reasons you cited in your answer for the downward trend of fisheries —such as dependence on cod, changes in operational costs, structural problems, overfishing and weakness in marketing strategies — concern only a part of the EU fleet. These causes are not the main concerns of the Baltic small-scale fisheries, which are threatened more by overgrown grey seal and cormorant populations. It is vital that the EU Commission and the Parliament delve more specifically into the questions and challenges of the Baltic Sea region we presented in our letter.
Baltic Sea coastal small-scale fishing is artisanal by nature. Small, only 5- to 6-meter, vessels use passive gear with very little environmental impact; gillnets, fyke nets and longlines are used in inshore waters. The operating units are almost without exception family-owned and don’t have a chance to hire workers. It is common that one family member fishes and the other works processing the catch and doing direct sales. Coastal fishing does not concentrate on any single species but requires fishing multiple species, depending on season. From an economic perspective, small-scale fisheries are important in preventing depopulation and maintaining the vitality of the coastal areas.
The issue of seal- and cormorant-caused damages on small-scale fisheries has been reported to the European Commission on several occasions. As you highlighted in your answer, “the impacts can be mitigated using measures to prevent or reduce damage caused by these protected species and by compensating the economic losses.” All the measures and policies mentioned are undoubtedly important and necessary, but unfortunately, in the present situation, they are not adequate. Despite all these efforts, we have not succeeded in responding to the crisis. Quite the opposite: coastal small-scale fishing is disappearing from our Baltic coasts.
The crisis that the fishers face every day on the sea ultimately affects consumers. Fish as an essential part of the diet has significant positive value for public health. Coastal small-scale fisheries play an important part in the food security of the Baltic Sea region. Especially now during the coronavirus pandemic, the importance of local food security has risen, highlighting the role of fisheries. The economic compensation paid to fishers suffering from seal- and cormorant-caused damages is not a solution and does not bring fish to consumers’ dining tables.
When the grey seal population was monitored in the Baltic Sea area last year, over 38,100 individuals were counted. This means that the estimated population size is around 47,650–63,535 individuals . The Baltic grey seal population is now almost 5 times bigger than the LRL target that HELCOM has set.
In November 2019, the Natural Resources Institute Finland published a report, “The impacts of seals and cormorants experienced by Baltic Sea commercial fishers”. The report noted that the fishermen share the same experience in the Baltic Region: “The impacts of seals and cormorants are often serious obstacles for the continuation of the fishing livelihood”. As the research concluded: “Steps forward necessitate wide collaboration across sectors both regionally and internationally.” 
As we understand it, the European Commission responsible for Environment, Oceans and Fisheries seeks to promote, to maintain and to secure the development of sustainable fisheries. Appealing to this mission, we ask you and the EU Parliament to help the Baltic fishermen navigate this deepening crisis and ensure the future of the Baltic small-scale coastal fisheries.
We would like to ask your contribution in:
- Abolishing the trade ban on seal products in the European Union
- Acknowledging the importance of the work aiming for a sustainable balance between traditional coastal fishing and sustainable levels of seals and cormorants, including ecological, economic, social and cultural aspects.
- Looking for further possibilities to reduce the grey seal population to a sustainable level. The management plan for Baltic seals (2007) is based on statistics from the year 2005.
- Unifying the interpretation of the Commission guidelines on derogations under Article 9 of the Birds Directive. The Cormorant clause is currently interpreted in different ways by the Baltic Sea Region States, leading to legal uncertainty and incoherence.
In 2015 United Nations member countries agreed on the UN Sustainable Development outcomes and the strategy that guides and promotes implementation during the years 2016–2030. The programme and its objectives apply without distinction to all countries. Primary goal 14, Conserve and sustainably use the oceans, seas and marine resources for sustainable development, concerns ecosystems of seas, marine resources and fishing. All requirements of the sub-objectives of primary goal 14 are also relevant to Baltic small-scale fisheries. Sub-objective 14.b provides access for small-scale fishers to marine resources and markets and this rise the small-scale fisheries as a specific objective. It is clear that the overgrown seal and cormorant population precludes all actions to reach the goal described in sub-objective 14.b. Baltic small-scale coastal fishing is about to disappear.
We need action from the European Commission on this serious situation and your contribution to secure the traditional livelihood of small-scale coastal fisheries in the Baltic Sea.
 Hylkeet, 2019, LUKE: http://www.luke.fi/tietoa-luonnonvaroista/riista/hylkeet/.  The impacts of seals and cormorants experienced by Baltic Sea commercial fishers, 2019, Kristina Svels, Pekka Salmi, Juhani Mellanoura and Jari Niukko: http://jukuri.luke.fi/bitstream/handle/10024/544854/luke_luobio_77_2019.pdf
South Finland FLAG ESKO, Finland
Coastal Bothnian Bay FLAG, Finland
FLAG Archipelago Sea, Finland
FLAG Ostrobothnia, Finland
FLAG Bothnian Sea and Lake Pyhäjärvi, Finland