Regarding the evaluation criteria

1. Based on results in the Baltic sea fish stocks, implementation of the CFP is far from fulfilling its purpose
2. There has been little effort to achieve coherence between fisheries and environmental policy. For example, the Basic Agreement between the Commission and ICES explicitly states that environmental impacts on key indicators of Good Environmental Status under the MSFD is not be taken into consideration in ICES advice on fishing opportunities. 
3. Comparisons with a situation without the EU are hypothetical. Based on the situation before EU expansion in the Baltic region, the CFP may have somewhat slowed acceleration towards an ecological breakdown.

Regarding the instruments

1. There has been an overreliance on trying to achieve MSY. In short, a) it is much more difficult to estimate MSY than some have thought, leading to large uncertainties and b) attempts to capture the MAXIMUM of the (often overestimated) sustainable yield have contributed to the continued depletion of major Baltic stocks – which was foreseeable.
2. Lack of adequate control and compliance appears to have undercut the effectiveness of the landing obligation in demersal fishing. Together with abuse of flexibilities under art. 15 this has also contributed to misreporting and uncertainties in estimating MSY in pelagic fishing. 
3. The Baltic MAP has not achieved the two primary objectives of increasing and maintaining fish stocks above levels capable of producing MSY (art. 3.1) or minimizing the negative impact of fisheries on the marine environment (art. 3.3).
4. The capacity ceiling for the fleet is largely meaningless, as it does not take into account the incremental increase in actual capacity to catch fish (“technological creep”, estimated in the Green Paper from 2009 as 2-3% per year, i.e. at present about 40% compared to 2009). ITQ, by creating a protected oligopoly market and increasing capitalisation and profitability, may even have led to increased capacity to catch fish through substantial investments in more modern, effective vessels. The impact of the increase in vessel size and corresponding increase in spatial and temporal catch intensity on vulnerable stock components and the marine environment in general has not been taken into consideration.
5. Regionalisation has led to a slow-down in adoption of conservation as well as a decrease in transparency as negotiations on conservation measures and TACs de facto occur in Baltfish.

Managers and stakeholders appear to treat ICES estimates of current F in a stock and target Fmsy as certainties instead of the highly uncertain forecasts that they are. Fishing quotas are then awarded to countries based on what, in retrospect, often turns out to be overestimates of yield. This has been particularly apparent in the Gulf of Bothnia, where fishers have not managed to fill their quotas for some years. Further, managers tend to ignore warnings from ICES about future impacts of e.g. low recruitment. Focus has instead been on short term profitability for fishers and processers.

ICES forecasts for catches corresponding with MSY are measured in tonnes of biomass, with no consideration to the impacts on sub-populations or stock components (i.e. production units of a stock), on the age and size distribution (which can have consequences for the marine environment) or on the marine environment. If these impacts were taken into account fishing opportunities would normally have been lower. 

In the short run, due to the inherent uncertainties about stock development and environmental impacts, managers should base fishing opportunities on a lower level of the forecast MSY, for example at 50%. 

Further, the goal of restoring and maintaining stocks to robust levels should be made central in fisheries management.

In the longer term, management should focus on what is needed for more healthy ecosystems and food security.