North Sea RAC Takes Strong Stand on Discards

3rd October 2008 in Advisory Councils, Discards, North Sea

The North Sea Regional Advisory Council, of which the NFFO is a prominent member, adopted a strong position on the discarding of marketable cod at its most recent meeting in York.

The North Sea Regional Advisory Council, of which the NFFO is a prominent member, adopted a strong position on the discarding of marketable cod at its most recent meeting in York.

The RAC has issued a position paper (see below) in time for the first round of the crucial EU/Norway annual negotiations which begin on 3rd November. The paper argues strongly that there is a misalignment between the current TAC for cod and the available fish on the grounds. Unless there is a substantial increase in the TAC for 2009, along with associated cod avoidance measures, the massive discarding of marketable cod seen this year will not only be repeated but will increase.

“There is a huge opportunity next year to move away from blunt measures that generate discards toward an approach that involves the vessels in active cod avoidance measures” said Barrie Deas Chief Executive of the NFFO.

“If the TAC is set at a level consistent with the upper reaches of what ICES projections tell us will be caught next year, there will be scope for vessels to ensure that discards of marketable cod can be reduced and even eliminated. Not only that but we will secure a further reduction in fishing mortality. The measures that have been taken so far, along with the improvement in recruitment, means that fishing mortality on North Sea cod is at the lowest for 40 years”

“The RAC recognised that this is a pivotal decision. Do we carry on with a low quota and discards or do we break the mould and tailor our approach to the prevailing circumstances? The unanimous advice provided by the RAC is that we should take the rational approach – reduce discards, increase landings and reduce fishing mortality – this year this a win /win/ win outcome is within our grasp.”

The North Sea Regional Advisory Council

The 2009 Fishery for Cod in the North Sea: Opportunities to reduce Discards – a Position Paper prepared by the North Sea Regional Advisory Council


The North Sea cod stock is recovering strongly on the basis of incoming recruitment and significant reductions in fishing mortality¹. The current fisheries management challenge is to ensure that this opportunity to rebuild the spawning stock biomass is not squandered through inadequate measures. This includes a TAC that has recently been set at a level that results in high levels of discards, given current fishing practices.

The consequence of the mismatch between the 2007 and 2008 quotas and cod on the grounds during the course of the year has been widespread discarding of marketable cod². This is not an unexpected or unpredicted situation but it:

  • is a waste of a valuable resource estimated at around €30 million
  • retards the recovery of the North Sea cod stock, as discarded cod will not contribute to the rebuilding of the spawning stock biomass
  • seriously undermines the reputation of the fishing industry, fisheries science and of the Common Fisheries Policy

Against this background, the North Sea RAC, as a matter of urgency, has examined a number of options for avoiding a repetition of cod discarding on this scale, or worse, in 2009.


Dutch Proposal:

A proposal from the Dutch fishing industry was found to have considerable merit but could not easily translate to the conditions found in other member states. This was the idea that vessels should

  • land all cod caught
  • all cod landed be carefully recorded to provide precision scientific data
  • all over-quota cod be sold, with the vessel receiving 20% of the proceeds from the vessel’s producer organisation and the balance going into a scientific fund to improve knowledge of the cod stock

Scottish Proposal

A Scottish proposal was also considered; it focused on ways to transfer catches from discards to landings, through an increase in the human consumption TAC, balanced by additional measures in the fishery to ensure that total fishing mortality would fall to a greater extent than a low TAC with associated discards. The elements of this approach would be:

  • a substantial increase in the TAC through which cod, currently discarded, could be landed legally
  • this would be accompanied by additional measures such as a reduction in days at sea, and cod avoidance measures such as real time closures and cod avoidance plans and technical measures, that would make a significant contribution to the reduction of cod mortality.

The central idea in the Scottish proposal – a trade off between a substantial increase in the TAC and the extension and deepening of cod avoidance strategies – was regarded as the way forward but there was no support for using a reduction in days-at-sea as currency in the trade off for a range of operational and economic reasons.

WWF By-catch Limits

A WWF suggestion that formal by-catch limits could have a role to play was also discussed. Whilst the concept of setting limits to which the industry would be left to adapt to in its own way has some attractions, there was doubt whether by-catch limits could be employed in the current context of North Sea cod without serious economic dislocation.

The Way Forward

Taking all of the above considerations into account, the NSRAC believes that the following features should govern the management of the North Sea cod fishery in 2009:

  • recognition that the TAC for cod in 2008 has been out of line with the availability of marketable fish on the fishing grounds, resulting in widespread discarding
  • all parties³ should be committed to eliminating the discarding of marketable cod in 2009
  • on the basis of ICES projections, discarding of cod will be at a higher level in 2009 than this year, if a similar TAC setting rule (15% increase) is applied because the stock is recovering at a faster rate.
  • if a TAC for North Sea cod is set for 2009 at the highest level consistent with ICES projections, the NSRAC could consider a prohibition on the discarding of marketable cod. (Denmark already applies such a measure)
  • If the TAC for North Sea cod is set towards the upper range of ICES projections for catches in 2009, it will be incumbent upon the fishing industry and member states to ensure the establishment of extensive accompanying measures to reduce or eliminate discards of marketable cod
  • a reduction in days-at-sea would not directly address the problem of discarding to any significant degree as restricting time at sea does not constrain the level of discarding when the vessels are at sea
  • the widespread implementation of “cod avoidance” measures to accompany an increased TAC should, all other things being equal, result in a lower fishing mortality for cod than would be the case if there is a low TAC, high discarding and minimal cod avoidance activities.

Cod Avoidance

The intensification of cod avoidance activity in 2009, would build on the start made on cod avoidance in 2008. This includes:

  • Conservation Credits/Real Time Closures to protect aggregations of juvenile and spawning cod: the successful real time closure programme introduced for the Scottish, English and Danish demersal fleets during 2008 which has secured demonstrable operational changes in line with the objectives of cod recovery
  • Individual Vessel Cod Avoidance Plans: A pilot project in the English fleet testing the efficacy of cod avoidance plans in ensuring that vessels operate to restrict catches of cod to their quota allocations, through spatial, temporal and gear adaptations.
  • Technical Measures such as the eliminator trawl, which allows effective fishing for haddock and whiting whilst eliminating cod from the catch, and semi-pelagic fishing that similarly has very low discard rates
  • Equivalent measures in fisheries in which cod is a by-catch

Validation and Monitoring

The validity of cod avoidance measures rests to a high degree on the extent to which they can be monitored and evaluated. To address this question the NSRAC supports the following:

  • on-board observers, subject to availability and cost
  • the voluntary use of on-board CC TV cameras that show promise in demonstrating compliance
  • on-board self-sampling
  • the use of reference fleets to check the performance of larger groups of vessels
  • checks on landing patterns from landings declarations

Buy-in/ Peer Group Pressure

We recognise that the approach outlined in this paper, if adopted, would represent a step change in the way that our fisheries are managed and would involve the fishing industry in a central and active role. To facilitate this approach the members of the RAC will continue in their efforts to encourage the fullest possible involvement and support at port and vessel level through port and local fishermen’s associations. Fishermen should engage in the monitoring of compliance and in counter-acting socially and environmentally unacceptable behaviour.

Effective co-management schemes and strengthened liaison arrangements with control bodies could be part of the way in which peer-group pressure could be used to reinforce observance of cod avoidance and discards reduction.


Central to the new approach are robust auditing arrangements. To monitor the progress of cod avoidance measures, participating vessels/organisations should provide regular reports on fishing target species, by-catch species and levels of discards.


We are convinced that a substantial increase in the TAC for cod, accompanied by the extensive deployment of cod avoidance measures will deliver:

  • a dramatic reduction in discards
  • a commitment from the member states and the fishing industry to cod avoidance and discard reduction measures on very significant scale
  • a reduction in fishing mortality on the basis of the survival of cod that would otherwise have been discarded

We recognise that the successful implementation of the approach outlined above is contingent on the various fleets and the member states meeting their obligations to implement effective cod avoidance measures. In the event of a failure to deliver, and evidence of continuing high levels of discarding, we would acknowledge the necessity to rapidly apply secondary restrictions.

¹ ICES ACOM May 2008

² ICES North Sea and Skagerrak Demersal WG report May 2008

³ EU, Norway, member states and their respective fishing industries