Cod Plan: Uncertain Future

At the recent meeting in Brussels, representatives from the North Sea and North West Waters RACs, including the NFFO, highlighted the need to make urgent changes to the plan as its provisions continue to tie the fleets into large, preordained, annual reductions of effort and TACs. STECF’s report published in July, questions the validity of this approach on the basis of the evidence so far.

The key elements of the STECF Report are:

North Sea

• That fishing mortality declined significantly before the Cod Management Plan but has seen only minor reductions in the two years since the plan was introduced
• Spawning Stock Biomass has continued to increase gradually but is still below Blim.
• The cod stock has more than doubled in the last 6 years

West of Scotland

• There are only indicative trends in mortality but it is believed to be stable. Fishing mortality is certainly not declining.
• The spawning stock has increased but is well below Blim

Irish Sea

• ICES only has indicative trends (weak assessment)
• Fishing mortality uncertain but believed to be very high (around F1.5 equivalent to the level that crashed North Sea herring in the 1970s)
• No indications of any recovery in Spawning Stock Biomass

Overall Indications in the STECF Report

Although it is too early to say how the Plan will develop in the future, it is possible to say:

• The Plan is not delivering a reduction in fishing mortality as required
• Significant parts of the Plan does not have stakeholders’ support
• The Plan is more likely to succeed if it has stakeholder support; if stakeholders support the plan they are more likely to take their responsibilities to cod recovery more seriously
• The Plan has delivered improvements in selectivity through Articles 11 and 13
• Actions taken under these articles have also been responsible for a significant reduction in discards
• Some technical measures have reduced cod by-catch (grids in the nephrops fishery for example)
• Reported landings are in line with TAC limits; but catches are well in excess of TACs as a result of quota-driven discards
• Cod avoidance has been insufficient
• Unintentional targeting of cod is a reality (possibly as a result of gear in use)
• Fishing mortality on other species such as haddock, whiting and saithe are consistent with CFP objectives
• In the West of Scotland seal predation has resulted in an increase in natural mortality
• The effort regime, contrary to expectations, has been difficult to administer and implement
• Article 13 which provides effort exemptions in return for positive fishing behaviours have proven their worth:
• Tailored responses and industry support
• Redistribution of effort away from cod-rich areas
• Reduction in discards
• Encouragement of more selective gear
• Encouraged temporal/spatial avoidance
• However verification of Article 13 exemptions is complex
• Fleet capacity has reduced but mainly before the beginning of the Plan
• This type of meta analysis is not very helpful as it masks changes that take place at the business level
• Some articles in the Plan are difficult to apply, some are ambiguous
• Reliance on a combination of TAC (enforced as landing limits) and effort reductions is a core weakness in the Plan1
• There has been inadequacy in the control systems in controlling total cod removals (discards)
• Fishing mortality cannot be expected always to follow proportionately trends in fishing effort
• There are problems in providing catch advice (Harvest Control Rules rely on mortality estimates which are inaccurate or imprecise)
• There is a lack of an analytical assessment in the West of Scotland and Irish Sea cod fisheries
• There are benefits in using alternative methods for setting TACs based on catches rather than landings
• Catch advice is given without consideration of interaction with other species

Regional Advisory Councils

The North Sea and North West regional councils made presentations to the meeting that stressed:

• The openness in the STECF review process that allowed the RACs to participate fully, although responsibility for writing the report lies with STECF alone
• That the Report endorsed many of the points about the weaknesses in the Cod Management Plan that had been highlighted in RAC advice, most significantly that:
• That fishing mortality cannot be expected to follow reductions in fishing effort (examples of the perverse outcomes generated by effort constraints were provided)
• That striving to reduce fishing mortality through restrictive TACs alone has, and would continue to, generate high levels of discards unless a different approach was taken
• That aligning economic incentives with management objectives is essential and that failure to do so had led to perverse outcomes
• That various kinds of incentivised cod avoidance offers a surer way to rebuild the cod stocks
• That a management plan which fails to take into account the mixed fishery and multi-species interactions is not likely to succeed
• That a regionally focused plan that allows scope to deal with the specifics of different fleet and stock characteristics and dynamics is more likely to succeed

What now?

The Commission made clear that, notwithstanding an ongoing dispute between the Commission and the Council with the European Parliament over who has competence for approving management plans, revision or renewal of the Cod Management Plan would be through co-decision making. This would be an extended process, tied inevitably into CFP reform, with the earliest prospect for a revised plan being 2014. Given current relations between the parties there is no guarantee that it would not take longer.

Before the Lisbon Treaty, it would have been expected that the current Plan would have had a three year lifespan. Now it looks like we are tied into a plan that neither rebuilds the cod stock in the way hoped for but has crippling consequences for the fleets.

The RACs forcefully made the point that the STECF evaluation had highlighted fundamental flaws in the management Plan, and that the pre-programmed annual effort and TAC reductions required under the Plan would extinguish economic viability in those parts of the fishing industry subject to the plan, unless urgent remedial steps are taken.

This is the impasse that has been reached. It is recognised that the Plan is flawed but the political process for revising it is apparently too cumbersome to break out of its economically damaging but from a stocks point of view, counterproductive, provisions. The possibilities now seem to be:

• That the Commission authorises a new and more flexible approach to providing effort exemptions using Article 13, as recommended by STECF. This could, if used boldly, release significant parts of the fleet from effort control whilst encouraging cod avoidance and discard reduction
• Following internal considerations, the Commission and the European Parliament find some way to fast-track changes to the Plan to accommodate STECFs conclusions, pending a much more thorough review and revision of the Plan in the context of CFP reform.

As the fishing industry braces itself for a further round of effort and TAC reductions required under the plan for 2012, the stakes could not be higher.

A Multi-Species Plan

There is broad agreement that the current Cod Plan should be replaced by a broader multi-species fisheries plan. What this could include in concrete terms will be the subject of discussions in STECF in November and December. Although the industry’s focus is naturally on the immediate future, it is important for the RACs to remain engaged in this process as it will undoubtedly have a major influence on the future direction of fisheries management in the Context of CFP reform.