Cod Plan: RACs Make Case For Change

The scientists have been charged with the task of evaluating the performance of the current Cod Plan.

Dependent on the content of the STECF/ICES report, the review could lead to proposals for minor or major revisions to the current arrangements. The current EU Cod Management Plan has been in place since 2008 and followed on from a previous EU Cod Recovery Plan implemented first in 2003.

Preparatory meetings were held by the RACs in London and Dublin to agree positions for the evaluation and these have now been presented in papers to be incorporated into the review.

Although there are differences in emphasis, both RACs take the view that the current Cod Plan is based on two assumptions, both of which are flawed. The first is the assumption that effort control (restrictions on time at sea) is an effective way to reduce fishing mortality on cod; and the second is the belief that cutting TACs will of itself deliver a reduction in fishing mortality. The RACs suggest that the evidence and experience of the current plan (and its predecessor), is that these assumptions do not hold water and that a revised plan that addresses these weakness is required.

Effort control has proven difficult and complex to implement but its main flaws lie in the Plan’s design.

Despite the establishment of elaborate effort management arrangements in the member states to date relatively few vessels have been constrained by days at sea limits and of those that have been constrained are few are those that catch most cod. In some member states the fishing industry’s costs have risen substantially under the impact of effort control, as active vessels have had to acquire Kwdays from inactive vessels in the fleet in order to remain economically viable. Part of the problem has been the lottery effect when effort baselines were established, as those member states which decommissioned part of their fleets during the 2006-7 reference period have had more headroom than those member states which decommissioned earlier.

However, a more serious issue is the growing recognition that when vessels are subject to effort constraints that bite, they respond in a variety of ways, to remain in business, some of which are consistent with rebuilding the cod stocks and some of which are not. Some vessels subject to the plan have joined catch quota programmes, which incentivise cod avoidance and ensure that vessels’ total catch (as opposed to landings) do not exceed their quota allocations. Alternatively, ICES stock assessments suggest that unaccounted removals amount to at least half the cod mortality in the North Sea. Discards are an important component of those unaccounted removals. In other words, to survive economically in mixed fisheries, the response to the current provisions of the Cod Plan has been both active cod avoidance and widespread discarding of cod depending on the vessels circumstances and part of the cod recovery zone in which they operate.

Drastic reductions in TACs for cod stocks in the North Sea, Irish Sea and West of Scotland have been the other plank in the Commission’s approach to rebuilding the cod stocks.

The fact that in the West of Scotland fishery the catch of cod is estimated by ICES to be 5 times the quota limit (the balance being discards) makes clear the futility of a Cod Plan based on cutting TACs - even where this is reinforced by effort control. The absence of a discernable response from the cod stocks in the cod stocks in the Irish Sea or West of Scotland may in part be due to a period of low productivity (recruitment) for cod and the growth of the grey seal population. The picture is made unclear by the effective collapse of the fish stock assessments in the Irish Sea and West of Scotland. Nevertheless, it is certain that discarding of most of the cod that is caught is likely to be an impediment to recovery.

In the North Sea, the political decision to set the TAC for cod at extremely low levels despite a rapidly rebuilding stock predictably resulted in obscene levels of discards of mature, marketable cod.

Despite its clumsy approach to cod recovery, the provisions of the Cod Plan does contain some progressive elements that now point the way forward – if they can be refined and reinforced. Cod avoidance does not mean not catching any cod. It means adapting fishing patterns –through type of gear, and where and when fishing takes place – to ensure that the total catch of cod is in line with the quota limits. Encouraging these types of fishing behaviours through various types of incentive is already a feature of the current Cod Plan. Analysing why such measures have only been partially successful is one of the main tasks facing the Hamburg meeting. Unnecessarily bureaucratic provisions and unclear language in the Regulation is certainly part of the picture but harnessing the industry’s knowledge and experience in designing and implementing effective cod avoidance has shown great promise – if it can be scaled up to higher levels.

Automatic TAC and effort reductions have failed to deliver reductions in fishing mortality but some measures have contributed to rebuilding the cod stocks. The two that have unequivocally helped are more rigorous approach to landing controls and vessel decommissioning. It is significant that in the North Sea fishing mortality fell dramatically between 2000 and 2004 primarily as a result of the reduced fleet capacity and tighter landing controls, although this progress was later squandered by the huge increase in discards. Improved selectivity may also have played a role, although ICES has previously noted that the average mesh size in use has fallen as vessels moved from the whitefish (large mesh) to the nephrops (small mesh) sector to escape the punitive regime there.

The NWWRAC has made the cogent point that the policy failures with respect to cod recovery in the Irish Sea and West of Scotland have led to the collapse of reliable and robust stock assessments. Not only do we not know where we are going, we don’t even know where we are in terms of assessing the abundance, trends and stock dynamics. For this reason, rebuilding the stock assessments must go hand-in-hand with redesigning the Cod Plan. A move away from the blanket one-size-fits-all approach, based on pre-programmed TAC and effort reductions, is required and should be replaced by collaborative science incorporating comprehensive industry data, within a new cod plan base on a realistic time frame. Effective and incentivised cod avoidance measures within an adaptive approach could rebuild confidence in the assessments and trust in the management regime.

The report produced in Hamburg will be presented to a plenary session of STECF (Scientific, Technical and Economic Committee for Fisheries) in July where it will be stress tested. Once adopted, it will be presented to the Commission and discussed by the member states. If the evaluation suggests that the current plan isn’t working, a new process will open towards recommendations for change and a new plan without the deficiencies of the old plan.

The Federation has worked hard within both the NSRAC and the NWWRAC to ensure that the all the available evidence, including vessel operators’ direct experience of working under the plan, has brought to the table. As strong advocates for a revised cod recovery plan the Federation will make the case for a move away from strong-arm reductions in effort and TACs towards a more intelligent and comprehensive approach focused on results.

In our view a new plan should:

• Clarify and increase the scope for encouraging effective cod avoidance so that TAC reductions actually achieve a reduction in fishing mortality rather than only generating discards
• Underpin effective cod avoidance with complementary decisions on TACs and effort; this means abandoning pre-programmed reductions in TACs and effort allocations
• Move to a recovery timeframe that makes sense in biological and economic terms
• Move away from effort restrictions as an unreliable and often counterproductive instrument in cod recovery; the NFFO has explained the weak or at least unpredictable correlation between effort and fishing mortality elsewhere: http://www.nffo.org.uk/news/cause_effect.html
• Adopt a fishery-by-fishery approach, which means different arrangements in the Irish Sea and West of Scotland from the North Sea
• Have a regional seas focus that allows measures to be tailored to specific fisheries
• Rebuild failed stock assessments in the Irish Sea and West of Scotland using industry data and cooperation, hand in hand with a new approach to management measures