MSC SUSTAINABLE FISHERIES CERTIFICATION. SIC Pikeperch fishery in Mälaren and Vänern

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1 MSC SUSTAINABLE FISHERIES CERTIFICATION April 2017 Prepared For: Svenska Insjöfiskarenas AB (SIC AB) Prepared By: Acoura Marine Ltd Authors: Andrew Hough, Geir Hønneland and Sture Hansson

2 Contents Table of tables... 4 Table of Figures Executive Summary Authorship and Peer Reviewers Assessment Team Peer Reviewers RBF Training Description of the Fishery UoA and Proposed Unit of Certifi (UoC) Total Allowable Catch (TAC) and Catch Data Scope of Assessment in Relation to Enhanced Fisheries Scope of Assessment in Relation to Introduced Species Based Fisheries (ISBF) 13 Overview of the fishery Overview of the lakes Fishing Practices Fishery Management Other fisheries relevant to this assessment Principle One: Target Species Background Biology of the target species History of the fishery Stock Status and Reference Points Harvest Strategy Harvest Control Rules and Tools Assessment, Information and Monitoring Principle Two: Ecosystem Background Ecosystem background Primary species Secondary species Endangered, Threatened and Protected Species Habitats Principle Three: Management System Background Jurisdiction Objectives Management system and decision-making procedures Dispute resolution mechanisms Stakeholders and consultation processes Enforcement, sanctions and compliance Page 1 of 160

3 4 Evaluation Procedure Harmonised Fishery Assessment Previous assessments Assessment Methodologies Evaluation Processes and Techniques Site Visits Consultations Evaluation Techniques Traceability Eligibility Date Traceability within the Fishery Eligibility to Enter Further Chains of Custody Eligibility of Inseparable or Practicably Inseparable (IPI) stock(s) to Enter Further Chains of Custody Evaluation Results Principle Level Scores Summary of PI Level Scores Summary of Conditions Recommendations Determination, Formal Conclusion and Agreement References Appendices Appendix 1 Scoring and Rationales Appendix 1.1 Performance Indicator Scores and Rationale Evaluation Table for PI Harvest strategy Evaluation Table for PI Harvest control rules and tools Evaluation Table for PI Information and monitoring Evaluation Table for PI Assessment of stock status Evaluation Table for PI Primary species outcome Evaluation Table for PI Primary species management strategy Evaluation Table for PI Primary species information Evaluation Table for PI Secondary species outcome Evaluation Table for PI Secondary species management strategy Evaluation Table for PI Secondary species information Evaluation Table for PI ETP species outcome Evaluation Table for PI ETP species management strategy Evaluation Table for PI ETP species information Evaluation Table for PI Habitats outcome Evaluation Table for PI Habitats management strategy Evaluation Table for PI Habitats information Page 2 of 160

4 Evaluation Table for PI Ecosystem outcome Evaluation Table for PI Ecosystem management strategy Evaluation Table for PI Ecosystem information Evaluation Table for PI Legal and/or customary framework Evaluation Table for PI Consultation, roles and responsibilities Evaluation Table for PI Long term objectives Evaluation Table for PI Fishery-specific objectives Evaluation Table for PI Decision-making processes Evaluation Table for PI Compliance and enforcement Evaluation Table for PI Monitoring and management performance evaluation 103 Appendix 1.2 Risk Based Framework (RBF) Outputs Appendix Consequence Analysis (CA) for Principle Appendix Productivity-Susceptibility Analysis (PSA) Appendix Consequence Spatial Analysis (CSA) Appendix Scale Intensity Consequence Analysis (SICA) Appendix 1.3 Conditions Appendix 2 Peer Review Reports Peer Review Peer Review Appendix 3 Stakeholder submissions Meeting Record Lake Vänern and Mälaren Pikeperch Fishery Meeting Record Lake Vänern and Mälaren Pikeperch Fishery Appendix 4 Surveillance Frequency Appendix 5 Objections Process Page 3 of 160

5 Table of tables Table 1 Lake Mälaren TAC and Catch Data Table 2 Lake Vänern TAC and Catch Data Table 3 Bycatch in lake Mälaren Table 4 Bycatch in lake Vänern Table 5 Development of the trap and transport (T&T) programme Table 6 Rationale for use of RBF Table 7 Scoring elements Table 8 Traceability Factors within the Fishery: Table 9 Lake Mälaren Gill Net Summary of Scores Table 10 Lake Mälaren Fish Trap Summary of Scores Table 11 Lake Vänern: Both Gear Types Summary of scores Table 12 Summary of Conditions Table 13 Principle 1 CA Scoring Template - Target Species Table 14 PSA Rationale Table - Pikeperch Table 15 PSA Rationale Table - Burbot Table 16 PSA Rationale Table - Bream Table 17 PSA Rationale Table - Pike Table 18 PSA Rationale Table - Perch Table 19 PSA Rationale Table - Eel Table 20 CSA Rationale Table Table 21 CSA Rationale Table Table 22 SICA Scoring Template for PI Ecosystem (Reference: CR Table PF19) Table 23 Condition 1: Both Lakes Table 24 Condition 2 Lake Mälaren Fish Trap UoA Table 25 Condition 3: Both Lakes Table 26 For reports using one of the default assessment trees: Table 27 For reports using the Risk-Based Framework: Table 28 For reports assessing enhanced fisheries: Table 29 For reports using one of the default assessment trees: Table 30 For reports using the Risk-Based Framework: Table 31 For reports assessing enhanced fisheries: Table 32 Surveillance level rationale Table 33 Timing of surveillance audit Table 34 Fishery Surveillance Program Page 4 of 160

6 Table of Figures Figure 1 Swedish Lakes Figure 2 Lake Vänern Figure 3 Lake Mälaren Figure 4 Fish traps Figure 5 Areas closed to pikeperch fishing Apr' 25 - May Figure 6 Lake Mälaren pikeperch catches Figure 7 CPUE Pikeperch catch by year in Lake Mälaren Figure 8 CPUE Pikeperch in gillnet test fishing in Lake Mälaren Figure 9 Effort by year in commercial fishery in Lake Mälaren Figure 10 Pikeperch catches in Lake Vänern Figure 11 CPUE Pikeperch on Lake Vänern Figure 12 Length distributions of pikeperch sampled by multimesh gillnets with standardized methods in deep and shallow areas in Lake Vänern, where different net types were used in each habitat. Comment: Pikeperch above the minimum size limit (450 mm) are caught in the fishery-independent sampling relatively more in Fishery independent sampling using these methods is carried out by SLU (Dept. Aquatic Resources) every third year in Lake Vänern Figure 13 Year class strength Lake Mälaren Figure 14 Overview of Lake Mälaren basins Figure 15 Calculated lengths of pikeperch in Lake Mälaren basins Figure 16 Lake Mälaren lake depth Figure 17 Food and habitat of the Lake Vänern fish community Figure 18 Burbot as % of Lake Vänern catch Figure 19 Los for fish traps in Lake Vänern Page 5 of 160

7 1 Executive Summary» This report provides details of the MSC assessment process for the Fishery Name fishery for Svenska Insjöfiskarenas AB (SIC AB). The assessment process began on 21 st July 2016 and was concluded (to be determined at a later date).» A comprehensive programme of stakeholder consultations were carried out as part of this assessment, complemented by a full and thorough review of relevant literature and data sources.» A rigorous assessment of the wide ranging MSC Principles and Criteria was undertaken by the assessment team and a detailed and fully referenced scoring rationale is provided in the assessment tree provided in Appendix 1.1 of this report.» The Target Eligibility Date for this assessment is to be the date of certifi of the fishery. The assessment team for this fishery assessment comprised of Andrew Hough who acted as team leader and primary Principle 2 specialist; Geir Hønneland who was primarily responsible for evaluation of Principle 3 and Sture Hansson who was primarily responsible for evaluation of Principle 1. Paul MacIntyre was the traceability expert advisor. The target species is pikeperch, caught in two separate lakes Malaren and Vanern. In both lakes two gear types are used gill nets and fish traps. The assessment was carried out using MSC CR v2.0. Client strengths» The fisheries operate using traditional, low environmental impact gear gill nets and fish traps. The operation of the fisheries also seeks to minimise mortality of nontarget fish (pikeperch and other species) by their immediate return from capture in fish traps and high selectivity of gill nets.» Scientific support is provided by SLU-Aqua Client weaknesses» There is relatively little direct information on the stock status or environmental effects of the fisheries, and so the risk-based assessment framework (RBF) was used to determine the outcome status of the pikeperch stocks (PI 1.1.1), secondary species (PI 2.2.1), ETP species (2.3.1), habitats (2.4.1) and ecosystem (2.5.1). There are no primary species. Determination» On completion of the assessment and scoring process, the assessment team concluded that each Unit of Assessment (UoA) should be certified to the MSC standard for sustainable and well-managed fisheries. Conditions & Recommendations However, a number of criteria which contribute to the overall assessment score scored less than the unconditional pass mark, and therefore trigger a binding condition to be placed on the fishery, which must be addressed in a specified timeframe (within the 5-year lifespan of the certificate). Full explanation of these conditions is provided in Appendix 1.3 of the report, but in brief, the areas covered by these conditions are:» For all UoAs: Well defined harvest control rules shall be put in place to ensure that the exploitation rate is reduced as the PRI is approached, and are expected to keep Page 6 of 160

8 the stock fluctuating around a target level consistent with (or above) MSY (PI SIa)» For Lake Mälaren Fish Trap UoA only: An objective basis for confidence should be established that measures relating to eel recovery in this UoA will work (PI SIc)» For all UoAs: The fisheries must have in place a mechanism demonstrating occasional external reviews (at a frequency commensurate with the scale and intensity of the fishery). (PI SIb) In addition, the assessment team made a number of recommendations. As these are not the result of a failure to meet the unconditional pass mark, they are non-binding; however in the opinion of the assessment team, they would make a positive contribution to ongoing efforts to ensure the long term sustainability of the fishery. Details of these recommendations are provided below and in Section of this report.» Recommendation 1. The handling of fish from fish traps, to maximise survival when returned to the lake, has been well developed in Lake Hjalmaren. It is recommended that all fishers in Lake Mälaren and Lake Vänern should confirm that handling practices in these lakes follow best practice (for pikeperch and other species).» Recommendation 2. While the likely effects of bycatch in the fishery on cormorant populations are expected to be minimal, particularly in relation to numbers culled annually under license, the total numbers affected by the fishery bycatch (in each lake) combined with the culled numbers, are not fully recorded. To allow effects to be properly managed, it is recommended that in addition to the numbers culled being recorded, the numbers in fishery bycatches should also be recorded and reported.» Recommendation 3. Collection of data on pre-recruits to the fishery (for example from test-fishing) can provide very useful information in managing the fisheries. It is recommended that the client consider improvement (L. Mälaren) or initiation (L. Vänern) of the collection of such data to derive early information about expected recruitment to the fisheries. For interested readers, the report also provides background to the target species and fishery covered by the assessment, the wider impacts of the fishery and the management regime, supported by full details of the assessment team, a full list of references used and details of the stakeholder consultation process. Acoura Marine Ltd. confirm that this fishery is within scope. Page 7 of 160

9 2 Authorship and Peer Reviewers 2.1 Assessment Team All team members listed below have completed all requisite training and signed all relevant forms for assessment team membership on this fishery. Assessment team leader: Andrew Hough Primarily responsible for assessment under Principle 2 Andrew has been active in the development of Marine Stewardship Council certifi since 1997, when involved in the pre-assessment of the Thames herring fishery. He was a founding Director of Moody Marine, led the establishment of Moody Marine fishery certifi systems and has represented Moody Marine at all MSC workshops until He has also worked with MSC on several specific development projects, including those concerned with the certifi of small scale/data deficient fisheries. He has been Lead Assessor (and often also expert team member) on many fishery assessments to date. This has included Groundfish (e.g. cod, haddock, pollock, hoki, hake, flatfish), Pelagics (e.g. tuna species, herring, mackerel, sprat, krill, sardine) and shellfish (molluscs and crustacea); included evaluation of the environmental effects of all main gear types and considered many fishery administrations including the North Atlantic, South Atlantic, Pacific, Southern Ocean and in Europe, North America, Australia and New Zealand, Japan, China, Vietnam and Pacific Islands. He has recently acted solely as an expert team member of Principle 2 inputs of European inshore fisheries and Falkland Islands Toothfish. He has carried out peer reviews for various CABs including fisheries for molluscs, crustacea and freshwater finfish. Other assessments include Chain of Custody assessments for merchants, processors, distributors and retailers. Andrew has also been involved in the development of certifi schemes for individual vessels (Responsible Fishing Scheme) and evaluation of the Marine Aquarium Council standards for trade in ornamental aquarium marine species. Consultancy services have included policy advice to the Association of Sustainable Fisheries, particularly with regard to the implis of MSC standard development, and assistance to fisheries preparing for, or engaged in, MSC assessment. Expert team member: Geir Hønneland Primarily responsible for assessment under Principle 3 Geir Hønneland is Research Director of the Fridtjof Nansen Institute and adjunct professor at the University of Tromsø, Norway. He holds a Ph.D in political science from the University of Oslo, speaks Russian fluently and has followed the developments of Russian fishery politics and the Barents Sea fisheries management for more than two decades. Among his books are Implementing International Environmental Agreements in Russia (Manchester University Press, 2003) (including fisheries agreements), Russian Fisheries Management: The Precautionary Approach in Theory and Practice (Martinus Nijhoff, 2004), and Making Fishery Agreements Work: Post-Agreement Bargaining in the Barents Sea (Edward Elgar, forthcoming 2012). He has also published a number of articles about Russian fisheries management, and the Barents Sea fisheries management more widely, in peer reviewed journals. Geir also has wide range of evaluation experience, e.g. for the FAO relating to the FAO Code of Conduct for Responsible Fisheries. Further, he has produced a country study of Russian fisheries management for the OECD and several consultancies about Russian fisheries management. He was member of the team that performed the first MSC assessment of a Russian Barents Sea fishery in Geir is based near Oslo in Norway. A more comprehensive presentation can be found at the FNi s website: Page 8 of 160

10 Expert team member: Sture Hansson Primarily responsible for assessment under Principle 1 Prof. Hansson has 40 years of experience in aquatic ecology, primarily in fish and fisheries ecology. His research have had a focus on Baltic Sea ecology and addressed questions related both to coastal/archipelago issues and the open sea. On the applied side, he has worked with problems related to effects of fishing activities, eutrophi, discharges from pulp and paper industries, oil pollution and dredging operations. Prof. Hansson is exceptionally knowledgeable in pikeperch. Most recently he run a 5 years biomanipulation project with the objective to increase a local pikeperch population to such an extent that a trophic cascade should be generated, resulting in increased water clarity. He is regularly appointed expert member of the Swedish Land and Environment Courts. Expert advisor: Paul MacIntyre Paul started working in the Aquaculture sector in 1975, managing salmon farms and processing factories for a large multi-national before transferring in 1990 to aquaculture audit and inspection. During the last 25 years Paul has carried out over 3,000 audits and inspections of aquaculture and fish processing operations across the UK salmon and trout industry and internationally in the cod, tilapia and shrimp aquaculture sectors. Paul's primary interest is salmonids however his role as Aquaculture Director with Acoura Marine has involved him in the development and trial audit of a number of new aquaculture and agricultural standards. Paul is a qualified Lead Assessor and approved to audit BRC, MSC / ASC Chain of Custody, GlobalGAP, Organic Aquaculture, Freedom Food, Label Rouge, Best Aquaculture Practices, ASC Salmon and Friend of the Sea. Paul also audits to UK and French retailer standards Peer Reviewers Peer reviewers used for this report were Julian Addison and Martin Louis Van Brakel. A summary CV for each is available in the Assessment downloads section of the fishery s entry on the MSC website. Julian Addison Julian Addison is an independent fisheries consultant with 30 years experience of stock assessment and provision of management advice on shellfish fisheries, and a background of scientific research on shellfish biology and population dynamics and inshore fisheries. Until December 2010 he worked at the Centre for Environment, Fisheries and Aquaculture Science (Cefas) in Lowestoft, England where he was Senior Shellfish Advisor to Government policy makers, which involved working closely with marine managers, legislators and stakeholders, Government Statutory Nature Conservation Organisations and environmental NGOs. He has also worked as a visiting scientist at DFO in Halifax, Nova Scotia and at NMFS in Woods Hole, Massachusetts where he experienced shellfish management approaches in North America. For four years he was a member of the Scientific Committee and the UK delegation to the International Whaling Commission providing scientific advice to the UK Commissioner. He has worked extensively with ICES and most recently was Chair of the Working Group on the Biology and Life History of Crabs, a member of the Working Group on Crangon Fisheries and Life History and a member of the Steering Group on Ecosystems Function. He has extensive experience of the MSC certifi process primarily as a P1 team member but also as a P2 team member and team leader, undertaking MSC full assessments for the Newfoundland and Labrador snow crab fishery, the Ireland and Northern Ireland bottom grown mussel fisheries, both the Estonia and Faroe Islands Barents Sea cold water prawn fisheries, the Nephrops fishery in the Skagerrak and Kattegat, separate assessments for the Swedish, Danish and Norwegian Skagerrak and Norwegian Deep cold water prawn fishery, the Eastern Canada offshore Page 9 of 160

11 lobster fishery and the Limfjord mussel and cockle fisheries. He has also undertaken MSC pre-assessments, numerous annual surveillance audits and has carried out peer reviews of MSC assessments in both Europe and North America of lobster, cold water prawn, razorfish, cockle and scallop fisheries. Other recent work includes a review of the stock assessment model for blue crabs in Chesapeake Bay, USA, and an assessment of three Alaskan crab fisheries under the FAO-based Responsible Fisheries Management scheme. Martin van Brakel Martin is a scientist at the WorldFish Center Bangladesh & South Asia office. He holds an MSc in Agriculture and natural environment, with fisheries and aquatic ecology as main subjects, and PhD in aquaculture. Martin has more than 20 years of experience in fisheries research and development, starting his career as analyst on feeding ecology of the Ethiopian Lake Tana species flock of endemic cyprinids (Barbus spp.) and training assistant on the International Course on Data Handling for Tropical Fisheries Management, Wageningen, the Netherlands. From 1997 till 2001 he worked for the UN Food and Agriculture Organization, providing technical assistance to small-scale coastal artisanal and commercial fisheries in Cape Verde, subsequently assessing small scale capture fisheries and aquaculture potential in Latin America. From 2004 till early 2007 he was Course Director of the MSc program Aquatic Resource Development by Distance Learning, jointly operated in Bangladesh by the University of Stirling, UK, and Bangladesh Agricultural University (BAU). From 2007 till 2009 he worked at the WorldFish Center as co-leader of the aquatic ecosystems and fisheries theme, Challenge Programme on Water and Food (CPWF), and project scientist on community-based fish culture in irrigation systems and seasonal floodplains. He led a regional case study on Mekong inland fisheries and aquaculture for the UK Government Office for Science, Foresight project: The Future of Food & Farming. Currently he works on the Enhanced Coastal Fisheries in Bangladesh (ECOFISHBD) project, aiming to enhance resilience of the Meghna River ecosystem and communities reliant on coastal fisheries through the establishment of effective comanagement in Hilsa shad (Tenualosa ilisha) fisheries RBF Training Andrew Hough has been fully trained in the use of the MSC s Risk Based Framework (RBF). Page 10 of 160

12 3 Description of the Fishery UoA and Proposed Units of Certifi (UoC) (ALL REPORTS EXCEPT PCR) Acoura Marine Ltd confirm that the fishery is within scope of the MSC certifi sought following the assessment as defined below. Species: Stock: Geographical area: Harvest method: Client Group: Other Eligible Fishers: Species: Stock: Geographical area: Harvest method: Client Group: Other Eligible Fishers: Species: Stock: Geographical area: Harvest method: Client Group: Other Eligible Fishers: Species: Stock: Geographical area: Harvest method: Client Group: Pikeperch Sander lucioperca Lake Vӓnern Pikeperch Lake Vӓnern Gillnets (110 mm mesh) Svenska Insjöfiskarenas AB (SIC AB) The members of SIC are able to share the certificate if they want and if they re fishing Pikeperch. SIC (and the certifi) is open to join for any fisherman who is not a member yet, but becomes one. A member of SIC is not able to join the certifi if he/she doesn t use the pikeperch fishery. Pikeperch Sander lucioperca Lake Vӓnern Pikeperch Lake Vӓnern Fish traps Svenska Insjöfiskarenas AB (SIC AB) The members of SIC are able to share the certificate if they want and if they re fishing Pikeperch. SIC (and the certifi) is open to join for any fisherman who is not a member yet, but becomes one. A member of SIC is not able to join the certifi if he/she doesn t use the pikeperch fishery. Pikeperch Sander lucioperca Lake Mӓlaren Pikeperch Lake Mӓlaren Gillnets (120 mm) Svenska Insjöfiskarenas AB (SIC AB) The members of SIC are able to share the certificate if they want and if they re fishing Pikeperch. SIC (and the certifi) is open to join for any fisherman who is not a member yet, but becomes one. A member of SIC is not able to join the certifi if he/she doesn t use the pikeperch fishery. Pikeperch Sander lucioperca Lake Mӓlaren Pikeperch Lake Mӓlaren Fish traps Svenska Insjöfiskarenas AB (SIC AB) Page 11 of 160

13 Other Eligible Fishers: The members of SIC are able to share the certificate if they want and if they re fishing Pikeperch. SIC (and the certifi) is open to join for any fisherman who is not a member yet, but becomes one. A member of SIC is not able to join the certifi if he/she doesn t use the pikeperch fishery. The proposed Units Of Certifi for this fishery is as below: Species: Stock: Geographical area: Harvest method: Client Group: Pikeperch Sander lucioperca Lake Vӓnern Pikeperch Lake Vӓnern Gillnets Svenska Insjöfiskarenas AB (SIC AB) Species: Stock: Geographical area: Harvest method: Client Group: Pikeperch Sander lucioperca Lake Vӓnern Pikeperch Lake Vӓnern Fish traps Svenska Insjöfiskarenas AB (SIC AB) Species: Stock: Geographical area: Harvest method: Client Group: Species: Stock: Geographical area: Harvest method: Client Group: Pikeperch Sander lucioperca Lake Mӓlaren Pikeperch Lake Mӓlaren Gillnets Svenska Insjöfiskarenas AB (SIC AB) Pikeperch Sander lucioperca Lake Mӓlaren Pikeperch Lake Mӓlaren Fish traps Svenska Insjöfiskarenas AB (SIC AB) This Units of Assessment were used as they are compliant with client wishes for assessment coverage and in full conformity with MSC criteria. Page 12 of 160

14 Total Allowable Catch (TAC) and Catch Data Table 1 Lake Mälaren TAC and Catch Data TAC UoA share of TAC UoC share of total TAC Total green weight catch by UoC The fishery does not operate to a TAC. Instead, input controls are in place. As all commercial fishers are within the UoA, catches from the lake equate to catches in the UoA. Year (most 2015 Amount Fish Trap: kg recent) Year (second most recent) Gill-Net: kg 2014 Amount Fish Trap: kg Gill-Net: kg Table 2 Lake Vänern TAC and Catch Data TAC UoA share of TAC UoC share of total TAC Total green weight catch by UoC The fishery does not operate to a TAC. Instead, input controls are in place. As all commercial fishers are within the UoA, catches from the lake equate to catches in the UoA. Year (most 2015 Amount Fish Trap: kg recent) Year (second most recent) Gill-Net: kg 2014 Amount Fish Trap: kg Gill-Net: kg Scope of Assessment in Relation to Enhanced Fisheries No enhancement takes place in relation to pikeperch in either lake. Scope of Assessment in Relation to Introduced Species Based Fisheries (ISBF) Pikeperch is native to both lakes Page 13 of 160

15 Overview of the fishery Overview of the lakes The lo of the Lakes Vänern and Mälaren in southern Sweden are shown in figure 1 (it should be noted that the pikeperch fishery in Lake Hjalmaren has previously been certified). 30 Os lo Hjälmaren 29 Vänern Figure 1 Swedish Lakes Page 14 of 160

16 Lake Vänern Lake Vänern is the largest lake in Sweden and in western Europe, with an area of 5650 km² area, a length of 140 km and width of 75 km; the average depth is 27 m and the maximum depth 106 m. Figure 2 Lake Vänern Page 15 of 160

17 Lake Mälaren Lake Mälaren has a surface area of 1072 km², maximum length of 120 km and width of 65 km; the average depth is 13 m and maximum depth 76 m. Figure 3 Lake Mälaren Fishing Practices The fish traps used in both lakes are not standardised, but vary in size, construction and mesh size. The fish trap will cover the water column to a depth of up to 25m, which would typically be between m from the shore. A common rule is, however, that the fish house (the part of gear where the fish are trapped and that is taken up to the surface and emptied by the fishermen, as a cod-end) must be at a depth less than 5 m. This is to avoid excessive swim bladder expansion, which would otherwise cause buoyancy problems in discarded fish and lead to increased mortality, e.g. through predation by gulls. With the regulated shallow depth of the fish house, and swift catch sorting procedures, observable mortalities of discarded fish is very low (pers. obs. by the MSC evaluation team and by scientists from SLU). Catches of undersized pikeperch (<45 cm) varies depending on the mesh size in the trap. As an illustration of low mortality of discarded fish, tagged undersized pikeperch have been recaptured repeatedly (>10 times, one individual 39 times, Nyberg et al. 1996) in these traps. Page 16 of 160

18 Figure 4 Fish traps The gill nets used are standardised with regard to mesh size (120 mm stretched mesh in L. Mälaren and 110 mm in L. Vänern). With these nets, catches of undersized (<45 cm) pikeperch are small. Other fish species typically caught in gill nets include pike (Esox lucius), occasional large perch (Perca fluviatilis) and bream (Abramis brama). Perch and pike are landed and sold for human consumption, while the bream in L. Vänern are used as bait in crayfish traps (these fish are considered as commercial species). With the current mesh regulation, the discard of undersized pikeperch in the gill net fishery, is very small. Nets are very light and are mostly set in mid-water, so avoiding contact with the lake bed, although some contact is possible, especially towards the shore. Nets are anchored at each end and so gear loss is rare, with lost nets being recovered. Lake Vänern There are 70 fishermen of which all use gillnets and around 30 use fish traps. One hundred fish traps are allowed, with around 70 used. Gill nets tend to be used in spring and autumn and fish traps in summer; gill nets are not used in winter unless there is ice-melt. There is an allowance for 7000m gill-net per fisherman, although due to the high average age of fishers around 50 fishermen use 3000m each. Fishing areas and possible spawning areas has been mapped and in 14 areas fishing is closed from April 24 to May 25 (Figure 5). To protect pikeperch there are also areas in which, irrespectively of the season, only gill nets with larger mesh that 110 mm are allowed. Page 17 of 160

19 Figure 5 Areas closed to pikeperch fishing Apr' 25 - May 24 Lake Mälaren There are around 33 fishermen of which all use gillnets and around 25 use fishtraps. Fish traps may be used when there is no ice cover and around 200 traps are in use on the lake. The fishermen use 2000m each of gillnet. It is also noted that there is a lot of navigation in the lake, especially in the East near Stockholm, which restricts the area within which fishing may take place. Permissions are given for three year periods, but can be reduced if required. Fishery Management The fishery is managed through input control. The fishing intensity is regulated by the number of permits licensed. Such permissions are required for all commercial fisheries on public waters (the vast majority of the fishery). Permissions are granted for three year periods, and can be reduced if required, e.g. if there are decreases in the stock size. There is no total allowable catch system or other output constrain, but there are rules on the design of the fishing gears (depth for traps and mesh size for gill nets) and size limits for landed fish. Otherwise, there are no formalized management reference points or action plans in case of population reductions. Some fishery management regulations are set by SwAM; the gear types that can be used, minimum landing size of 45cm for pikeperch (MLS), gill-net mesh size (120 mm stretched mesh im L. Mälaren) and closed seasons. County Administrative Boards in turn determine the number of licenses which can be issued and limits on gear (number of traps, length of gill-net etc). Licenses are issued by SwAM but only approved by the local boards if there is sufficient fish production capacity in the lake. Lake Mälaren The four counties around the lake have a formal agreement (anon. 2015) on fisheries management, which is coordinated by the county board of Västmanland. The agreement is very general with the objective protect the fishable resources and allow their sustainable Page 18 of 160

20 usage, but without specific management measures except for clearly stating the need to be restrictive in issuing new commercial fishing licences. Lake Vänern This lake is shared by two counties, Västra Götaland and Värmland. These counties have together developed a management plan for Lake Vänern (anon. 2014a). Like for L. Mälaren, the objectives of the management plan can is very general with the objective protect the fishable resources and to be restrictive in issuing new commercial fishing licences. Other fisheries relevant to this assessment As well as the commercial pikeperch fisheries, there are commercial fisheries targeting pike, perch, whitefish and vendace which may take a bycatch of pikeperch, angling and subsistence fishing also take place (subsistence fishing including limited traps, gill nets and crayfish pots). The quantities taken in these fisheries are, however, small compared to commercial pikeperch targeted fisheries. In L. Vänern there are also commercial and recreational fisheries for crayfish. Since the trap nets are relatively few given the size of the lake, and as they are static gears, there is little or no competition for space. The pikeperch fishery supplies much of the bait (bream) for the crayfish fishery. Principle One: Target Species Background Biology of the target species Pikeperch (Sander lucioperca) is a piscivorous freshwater percid that occurs in eastern and central Europe. It is pelagic and found through lakes and in the Baltic (primarily in the littoral zone), with smaller individuals in shallower water. It can grow reasonably old (>20 yrs) and reach a mass of over 10 kg. The overall life history pattern of pikeperch is well established. Spawning takes place in shallow water (often 2-5 m) in the spring/early summer. The spawning site is aggressively guarded by the male until the eggs have hatched. Spawning takes place onto substrate at around 2-5m depth, typically clay/sand substrate with some vegetation. With the present size limitations in the fishery, and their growth in this lake, they are expected to spawn at least once before subjected to the fishery (sexual maturation at age 3-5). In the western and central Lake Mälaren, 50% of the females are sexually mature at cm length, while in the eastern part of the lake this is level of maturation is met at 55 cm. An external factor of importance for the recruitment of pikeperch is climate. Warm summers are associated with strong year classes and this has been documented for many years, both recently and during the mid 20th century. The correlation coefficient between year class strength and summer temperature (June-July) for the years was 0.75 (p<0.01, P. Nyberg, scientist retired from the Swedish Bd. of Fisheries, pers. comm.). Another factor that may influence recruitment, growth and production of pikeperch is the overall trophic status of the lake. There are no major and recent studies on the diet of pikeperch in the Lakes, but many studies have been conducted throughout Europe. The larval fish feed on zooplankton, but these prey are soon replaced by larger animals such as mysids and small fish. Adults feed almost entirely on fish. Small individuals are predated upon by perch, pike and also conspecifics. Tagging experiments in Lake Hjalmaren show that individuals can move more Page 19 of 160

21 or less over the entire lake. In the tagging study, 2299 pikeperch in the size range mm were tagged and 887 of these were recaptured at least once. Of these individuals 28 fish were caught at least 10 times and one individual was caught 39 times. These catches were taken in trap nets which can be fine meshed since they are also targeting other fish species. The recapture rates indicate the high survival of discarded, undersized fish. The National Fisheries Board (NFB) has also produced information material, including a video, for the fishermen on how to minimize mortality in discarded fish. In general terms, there are data from L. Mälaren (Andersson et al. 2015) that supports the migration results from L. Hjälmaren and given the openness of L. Vänern it is realistic to assume that the migratory behaviour is the same also in L. Vänern. History of the fishery Lake Mälaren Over the last 50 years, annual catches have fluctuated between 100 and 200 tons (see Figure 6), which is substantially more than in the beginning of the 20 th century. Besides more efficient fishing gears, the increased catches since the beginning of the previous century is likely to have resulted from a eutrophi of the lake, increasing its productivity and possibly also favouring pikeperch since it thrives in turbid water. Data from are from Andersson (1942) and it is not clear to what extent non-commercial catches have been included. Later data compiled by Ulrika Beier, Dept. Aquatic Resources, Swedish Univ. Agricultural Sciences (SLU). Figure 6 Lake Mälaren pikeperch catches Data on relative abundance, expressed as catch per unit effort (CPUE) in commercial fisheries, are available for a shorter period (20 yrs) than landing data. The last peak in landings, during the second half of the first decade of the 21 th century coincide well with a peak in CPUE (see Figure 7 and Figure 8), indicating that at least this landing peak is a result of an increase in the pikeperch population and not an increased fishery, which is also supported by effort data (see Figure 9). Available scientific gill net test fishing include currently only catches from at most four years per station (period ) and data are consistent with commercial CPUE in that no catch trend is seen. Page 20 of 160

22 Figure 7 CPUE Pikeperch catch by year in Lake Mälaren Figure 8 CPUE Pikeperch in gillnet test fishing in Lake Mälaren Page 21 of 160

23 Figure 9 Effort by year in commercial fishery in Lake Mälaren Lake Vänern Despite the considerably larger size of L. Vänern compared to L. Mälaren, catches are lower. This is reasonably a consequence of L. Vänern being less nutrient rich. Like in L. Mälaren, annual catches fluctuate by a factor of 2 ( tons) and has increased since the beginning of the 20 th century (see Figure 10). Periods of good or poor catches appears to last longer in L. Vänern. Data from the same sources as for L. Mälaren. Figure 10 Pikeperch catches in Lake Vänern There is effort data and CPUE information available since As this data is only available over a short period, no trends in CPUE are evident. Page 22 of 160

24 Figure 11 CPUE Pikeperch on Lake Vänern CPUE (kg) of pikeperch in the commercial fishery in Lake Vänern (see Figure 11) separated in two fishing gears, during the years The gears are pikeperch nets (blue), where the unit effort is 1000 m nets per day, and fykes (orange), where the unit effort is fykes per day. Statistics is collected from SWAM (Swedish Agency for Marine and Water Management) Likewise, the available data on monitoring of pikeperch population structure does not show any negative trends between 2012 and 2015, but actually an increased proportion of large fish (see Figure 12). Figure 12 Length distributions of pikeperch sampled by multimesh gillnets with standardized methods in deep and shallow areas in Lake Vänern, where different net types were used in each habitat. Comment: Pikeperch above the minimum size limit (450 mm) are caught in the fishery-independent sampling relatively more in Fishery independent sampling using these methods is carried out by SLU (Dept. Aquatic Resources) every third year in Lake Vänern. Page 23 of 160

25 Stock Status and Reference Points Lake Mälaren There are no reference points used in the management of the fishery. It is regulated by means of licences, limitations on the number of gears allowed, minimum mesh size in gill nets and a minimum landing size of 45 cm for pikeperch. The long term stable catches, varying between tons annually, and rather stable CPUE indicate that the fishery is currently sustainable. Recruitment data are derived from trawl catches of 0+ and 1+ fish and indicate large interannual variation, which is known to be common in this species. The strong year classes 1999 and 2001 are consistent with high CPUE values However, the three year classes are indicated as very weak but this is not reflected in exceptionally low catches in This casts some doubt on the possibility to develop recruitment reference points based on this index. Figure 13 Year class strength Lake Mälaren Lake Vänern There are no reference points used in the management of the fishery. It is regulated by means of licences, limitations on the number of gears allowed, minimum mesh size in gill nets and a minimum landing size of 45 cm for pikeperch. The long term stable catches, varying between 60 and 120 tons annually, and stable CPUE (albeit over only four years) indicate that the current fishing intensity is likely to be sustainable. There are no data collected to allow the year class strength to be assessed prior to the fish s recruitment to the fishery. Harvest Strategy The overriding objective is to maintain a sustainable commercial fishery in the lake (Nilsson et al. 2010). There are no quotas applied, but the rate of exploitation within the fishery is controlled by input controls. These are evaluated against trends in a number of separate indices of the stock (CPUE and pre-recruit year-class strength respectively) to ensure the fishery operates at a low risk of overfishing. Licences given for gill net fishing have been substantially reduced over time, and to some extent also the numbers of licensed fish traps (not all licensed gears are actually used). Page 24 of 160

26 Harvest Control Rules and Tools Management measures (with accompanying decision rules) in the event of population decreases are well known and can be applied via County Boards. Mechanisms to reduce harvest are: 1. removal of licences for fishers 2. complete closure of fishery on public waters 3. non-issuance of new licences to fish 4. reduction in effort (reduction in amount of gear allowed, notably reductions in lengths of gill-nets allowed and change in minimum size) Control of licensing and fishing activities is managed by SwAM and the county boards via close surveillance of activities on lake. Only input controls are applied. As licenses are renewed every 3 (gill nets) or 5 year (traps) it is possible to adjust both the quantity of gears allowed by individual fisherman and to control the number of licences available. In response to drastic changes in fish stocks it is also possible to change the allowed quantity of gears at any time. Although these measures are not reconciled with formalised reference points, the status of the stock and fishery are monitored to allow for implementation of management measures if there is a perceived risk of overfishing. However, the means and sequencing by which controls would be applied if necessary, is not clearly specified. This relates to lack of formal reference points and decision rules. Mesh sizes in trap nets vary since they are not only targeting pikeperch. However, this is not expected to significantly influence the size selective mortality, as undersized pikeperch are returned alive and show excellent survivor (Nyberg et al. 1996). Lo and time of fishing are not significant in affecting selectivity. Assessment, Information and Monitoring There are ongoing test fishing programs in both lakes, following a standard protocol for multi mesh gill-nets (Appelberg et al and Appelberg 2000). Available data series are rather short and of limited value to this evaluation. For pelagic fish there are, however, reasonably long data series from studies using hydroacoustics combined with trawling. Page 25 of 160

27 Principle Two: Ecosystem Background Ecosystem background Lake Mälaren The lake is 1072 km 2 with an average depth of 13 m and maximum depth of 76 m. With a large number of islands and narrow straits, the lake has several basins that may differ in their characteristics. Figure 14 Overview of Lake Mälaren basins Located in an area with fertile soils it is naturally rich in nutrients and has been eutrophied by run-off from agriculture areas and discharges from sewage treatment plants (the area around the lake has about 3 mil. inhabitants, ⅓ or the Swedish population). Active management has decreased the nutrient load to the lake, but it is still eutrophic. In large areas of the lake, total phosphorus concentrations in summer are around μg/l. Abundant piscivorous fish are pikeperch, perch (Perca fluviatilis) and pike (Esox lucius) and the lower trophic level species that they feed on include cyprinids, smelt (Osmerus eperlanus) and vendace (Coregonus albula). No complete and detailed food web description is available. Hydroacoustic studies (Axenrot, T. & Beier, U. 2015) combined with trawl catches show that the pelagic fish community is by number dominated by smelt which are about ten times as numerous as vendace. Besides pikeperch, commercial fisheries targets vendace, perch, pike and eel (Anguilla anguilla). The native crayfish (Astacus astacus) has been exterminated by the crayfish plaque (Aphanomyces astaci) and a North American crayfish (Pacifastacus leniusculus) has been stocked but not yet established a strong population. Differences among the basins results in geographic different in the growth of pikeperch. However, some of the differences in size of fish five years and older, with larger specimens Page 26 of 160

28 in the eastern basin, may result from a high fishing mortality of individuals larger than 45 cm (landing limit) in the western and central basin. Intensive boating restricts fishing activities in the eastern basin (see Figure 15). Figure 15 Calculated lengths of pikeperch in Lake Mälaren basins Page 27 of 160

29 Lake Vänern The lake is 5650 km 2 with an average depth of 27 m and maximum depth of 106 m. The lake is characterised by open water areas, with scattered islands along the coast. The lake is basically divided into two, a larger and deeper eastern area and a western area (see Figure 16). Figure 16 Lake Mälaren lake depth Page 28 of 160

30 Half a century ago, the lake was clearly eutrophied but phosphorus concentrations have now been brought down to levels which are considered to correspond natural conditions (~5-8 μg/l). Abundant piscivorous fish are pikeperch, perch, pike, but there are also burbot (Lota lota), landlocked salmon (Salmo salar) and trout (S. trutta). The prey fish used by these species include cyprinids, smelt and vendace. Nilsson (1979) reviewed fish and their diets in the early 1970s (foodweb below) when the lake was more eutrophic than today, but there are no more recent food web descriptions. Figure 17 Food and habitat of the Lake Vänern fish community Besides pikeperch, commercial fisheries targets whitefish (Coregonus sp.), vendace, perch, pike, eel and to some extent burbot. The native crayfish has been exterminated by the crayfish plaque but the North American crayfish (P. leniusculus) has established a strong population and is intensively fished. Hydroacoustic/trawl estimates (Axenrot 2015) of fish abundances suggest that the pelagic fish community is strongly dominated by smelt (90-95% and 50-65% of numbers and biomass respectively), with vendace contributing 6-7% and 20-25% respectively in For both species there are large abundance variations over time ( ). The trophic position of pikeperch is well known in general terms, including for different life stages and potential prey and predators are known. Page 29 of 160

31 The water management organisation of the lake monitors the water quality, phytoplankton, zooplankton and benthic invertebrates. Water quality data, in particular nitrogen and phosphorus, are important as indicators of lake productivity. The test fishing programme using fish traps and gill nets monitors populations of the main fish species present; During August two persons accompany four fishermen distributed over the lake and record all species of fish caught, count all specimens and measure the length of all fish caught in the fish-traps. As these fish-traps have fairly small mesh size, a number of other fish species will be caught. This will, in the long run, give results concerning the status of the populations of most species in the lake. Results of such monitoring are made publicly available and are collated and integrated with other work relating to the fishery. All data are regularly evaluated by the fishery management team and it is possible to impose restrictions should evidence indicate that a modifi of fishing pressure is required. Results from test fishing and the sampling of commercial catches are summarised in the figures presented earlier in this report. The nature and management of the fishery is such that only a small proportion of by-catch species is taken. Larger proportions of pikeperch are taken, but productivity is maintained (including through a large minimum size). No gear loss is possible, fish traps are large and nets are very well anchored to permanent moorings. Fish trap los are all mapped and liable to inspection by County managers. This information suggests no significant changes in ecosystem structure and function due to the removal of non-target species. The new national management authority (The Swedish Agency for Marine and Water Management, SwAM) wish to continue with an ecosystem based approach to fishery management (U.Beier, SUA, pers comm, 2011). Primary species Primary species are those which have management rules in place, including limit or target reference points. There are no species in either lake which is managed through reference points. This includes the target species, pikeperch, and other commercial species such as crayfish, pike and perch. Page 30 of 160

32 Secondary species Secondary species are those species not P1 or Primary or ETP. Landing data have been provided by SLU-Aqua, based on SwAM catch statistics. Main species (comprising 5% or more of the catch, or 2% or more of less resilient species) are identified in blue below in Table 3. Lake Mälaren Table 3 Bycatch in lake Mälaren Fish Trap Av catch Kg Gill net Av catch Kg Average Species percentage Pikeperch Eel * 6.6 <0.1 Pike Perch Vendace Asp Salmon Burbot Bream <0.1 Trout 16 < <0.1 Whitefish 0.4 < <0.1 Roach 37 < Rainbow trout 2.1 < Trench 2.6 <0.1 2 <0.1 Smelt <0.1 Brill <0.1 *indicates eel caught in eel directed traps as well as pikeperch directed traps, and will therefore be an overestimate. Average percentage As eel are considered under ETP species (Section 3.5.4), the remaining main secondary species are pike caught by both gear types. As pike features as a main species in both Lake Mälaren UoAs, it is subject to a cumulative assessment. Table 4 Bycatch in lake Vänern Fish Trap Gill net Species Av catch Kg Average percentage Av catch Kg Average percentage Pikeperch Bream Perch Eel <0.1 Pike Salmon Whitefish Roach Burbot Vendace Trout Smelt 262 < <0.1 Asp Page 31 of 160

33 Grayling <0.1 Rainbow trout <0.1 Birds 28 < <0.1 Asp are included on the Swedish red list (not formally an ETP designation), but this species is largely affected by river engineering works. Catches of asp in both lakes are below the 2% limit (the highest catch is an average 0.6% of the catch in Lake Mälaren fish traps). As the stock status is uncertain for the pike, perch and Lake Vänern burbot populations, and no reference points are in place, the Risk-Based Assessment Framework (RBF) is used to evaluate the outcome status. Management The management of fisheries in general is done within EU and national Swedish regulations and specifically for L. Mälaren and L. Vänern there are formalised cooperation between the counties around the lakes (anon. 2014a, 2015). There are no rules regarding catches of pike, burbot, perch and bream. Of these species, only burbot is on the Swedish red list where it is classified as near threatened. It is caught primarily in L. Vänern and their catches has decreased over time (see Figure 18). Catches of eel are strictly controlled and specimens <70 cm are not allowed to be landed. It is noted that bird catches are recorded in Lake Vänern. Birds are discussed more fully under ETP species. Figure 18 Burbot as % of Lake Vänern catch Endangered, Threatened and Protected Species Fish. The only protected fish species which may be affected by the fisheries is eel caught in fish traps; the shape of the ell and mesh sizes used mean that gill-net catches are negligible. In 2007, the European Union implemented a Regulation establishing measures for the recovery of the stock of European eel, obliging EU Member States to develop a national Eel Management Plan. The common limit is an escapement of at least 40% of the silver eel biomass relative to the escapement if no anthropogenic influences would have impacted the stock and recruitment would not have declined. The Swedish plan was submitted in 2008 and relevant protective measures implemented. Currently, for the total inland stock (including the large lakes) status indicators are that the stock biomass is below the limit level, and anthropogenic impacts (fishery, hydropower etc) exceed the current limit. These indicators are derived from a detailed reconstruction of the silver eel production over the past decades, but ground-truthing the results has not been achieved and the quality of the landings data is doubtful. Management actions include assisting migration, restocking, fishing restrictions and Trap & Transport. It is also noted that Page 32 of 160

34 the current management limits are based on outdated assessments, with recommendations to develop an updated, comprehensive management plan for the inland stock; to improve the quality of the landings data, and to improve the quality of the assessment (Dekker, 2015). In Lake Vänern, the presence of four Hydroelectric power (HEP) plants on the main outflow of the lake has led to the instigation of a trap and transport (T&T) programme whereby eel caught in fish traps and transported below the HEP plants and released. The project started in 2010, with the system developing over the first years. There is a permitted eel fishery in the lake, which results in some remaining actual catches. The development of the trap and transport (T&T) programme is summarised in Table 5 Development of the trap and transport (T&T) programme Year Prodn. Catch (t) T&T % T&T Actual catch Escape (t) =73% = 87% , = 92% = 93% , = 97% , = 97% , = 98% In Lake Mälaren, fishers without special permission to catch eel have escape panels in their fish traps. The few fishermen allowed to land eels are generally old and when they leave the fishery the fishing possibility is not passed on to other or new fishers, resulting in an expected successive decrease in the eel fishery. The eel population in L. Mälaren is primarily derived from stocking the lake with elvers and tagging experiments indicate that these eel for some reason have problems with leaving the lake, and those which do are in a poorer condition that migratory eels in general (Sjöberg et al. 2016). It is thus possible that eel produced in L. Mälaren contributes less to recruitment than the average eel does. A licence allows for fishing over at most 120 days/yr, but must be stopped if 8 tons has been caught (anon. 2014b). The catch figures above include some targeted eel fishing as well as bycatch in the pikeperch directed fishery. Birds. Sea eagles (Haliaetus albicilla) and ospreys (Pandion haliaetus) are present on both lake. There are no direct interactions of raptors with the fishery. There are nesting pairs of cormorants (Phalacrocorax carbo sinensis) in each of the lakes (Pettersson & Lundmark 2015, anon. 2014a), and assuming 2 adults and 3 juveniles and non-nesting birds per pair this corresponds to individuals/lake. During seasonal migrations, cormorants (and potentially also other piscivorous birds, notably mergansers) increases substantially in numbers. Birds can be caught in both traps and gill nets, in particular as they sometimes try to feed of fish caught gears. Numbers of piscivorous birds affected by the fishery were recorded for Lake Vänern, with average annual numbers of 28 birds in fish traps and 21 in gill nets. This is comparable with numbers in Lake Hjalmaren (Intertek Moody Marine 2013) where <5 per annum were caught in the traps and they were all cormorants. Some culling of cormorants in L. Mälaren is allowed (licenced number around birds annually), primarily directly around commercial fishing gears. There is no culling in L. Vänern. Bird populations are monitored by the ornithological society and data are collated by the Swedish Natural History Museum. Page 33 of 160

35 Other Species. Otters and beavers are present in both lakes but there are no reports of bycatches or other interactions with the fishery. Habitats No Natura 2000 area that interacts with the fishery in Lake Mälaren (pers. comm. Ronny Hermansson, fisheries officer at the county board of Västmanland and coordinator for the fisheries management of that lake). In L. Vänern, Natura 2000 and other protected areas are explicitly taken into account in the fisheries management plan (anon. 2014a). Traps are placed in areas of sand and muddy sand or gravel/pebble habitat with reasonably steeply sloping lake bed; stony areas and macrophytes are avoided as these damage the net and/or allow fish to escape the net. These two habitat types are considered in the riskbased assessment (Appendix 1.2): Coastal margin; sediment plain; fine flat sediment; no apparent fauna or flora; depth <25m Coastal margin; sediment plain; flat; gravel/pebble; no apparent fauna or flora; depth <25m Gill-nets operate in the same habitats, these are mostly mid-water but may impact on habitat at the shallower lake margin; gill nets are also anchored at both ends. The lo of fishing operations is very well known and traps are moved little if at all between years. All los are known on an annual basis and fish trap los are mapped and subject to inspection, as illustrated below for L. Vänern. Figure 19 Los for fish traps in Lake Vänern Page 34 of 160

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