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EU Commissioner Franz Fischler

Dear Franz Fischler

The EU Commission has presented a proposal for a prohibition of driftnets in the Baltic Sea, and a suggestion that all gillnets should have acoustic alarm devices mounted in order to prevent unintended by-catch of porpoises and dolphins in the Baltic Sea

We have on this occasion produced a memorandum, which has been sent to the Danish authorities, the EU parliament, and to international organisations.

The memorandum gives a review of the situation in the Baltic Sea and claims that the driftnets applied there with considerable likeliness do not catch porpoise, and that if these nets should catch a porpoise, it would be possible to free it in time and release it alive. At the same time, we raise doubt about the reasonableness of the suggestion that all nets in the Baltic Sea and in the ICES areas III B and III C should have acoustic alarm devices mounted. We fear that the premises of the proposal will lead to a situation, where all net-fishing in the mentioned areas will be prohibited.

Finally, we also raise doubt about the premise, which says that there is only 100 porpoises left in the Baltic Sea, and that such a small stock requires so vast measures, like the ones suggested. Much indication exists that if there is indeed such a small stock of porpoise in the Baltic Sea today, then there must be other causes of this than by-catches in fishery.

Concluding, we recommend that a thorough investigation of the conditions is conducted, before the drastic measures mentioned will be applied. Items of such an investigation are: How many porpoises are there in the Baltic Sea, where are they more specifically, and which types of tackle have been documented to cause by-catches? This investigation could form the background of the recommendations, which ICES are to give in 2002 – namely to change the pattern in fishing on the places, where problems with by-catches exist. We might add to this that where by-catches will be proven to be a problem, fishermen can then be obliged to mount acoustic alarm devices on their nets.

We believe it to create more damage than benefit to mount acoustic alarm devises on tools, which are verifiably not able to catch porpoise, just as it creates more damage than benefit to mount acoustic alarm devises on tools in areas, where it is a proven beyond reasonable doubt that no porpoises exist.

We hope that you, in this case, will support a defence of the gillnet-fishing, which is gentle and environmentally sustainable in all parameters, by demanding reliable documentation, before the passing of a proposal such as this.

With kind regards, on behalf of the Danish Society For a Living Sea.

Yours truely

Chairman, Kurt Bertelsen Christensen

Ferring Strand 3.9.2003

Appendix:

 - Memorandum