The NFFO Team attend the the UK's Last December Council
Twelve Words and Two Failed Cod Plans
Twelve words have rocked the foundations of the EU Cod Management Plan and have undermined the whole basis of the EU’s strategy for rebuilding the cod stocks in the North Sea, Irish Sea and West of Scotland.
Those words, expressed by the scientists charged with reviewing the EU Cod Management Plan are:
Fishing morality should not be expected to follow trends in fishing effort.
Those rather dry, measured, scientific words carry huge significance because they challenge the attempt to rebuild the cod stocks through effort limitations (aka days -at-sea constraints) - one of the two main pillars of the current Cod Management Plan.
Although the NFFO, the fishing industry more generally, and the regional advisory councils, have repeatedly challenged the notion that reducing time at sea is an effective way of reducing fishing mortality, the significance of the statement lies in who is saying it and the context in which it is being said.
A joint ICES /STECF Working Group, which contains fisheries scientists from all of the member states affected by the cod plan, and some which are not, was charged under comprehensive terms of reference, with reviewing the Cod Management Plan agreed by the Council of Ministers in November 2008. A scoping meeting was held in Copenhagen in March of this year, followed in June, by a drafting meeting in Hamburg. In the interim, a battery of scientists, working to those terms of reference, have sifted evidence, analysed trends, listened to stakeholders and drawn their conclusions. Their report was quality-controlled in July by a plenary meeting of the EU’s Scientific, Technical and Economic Committee for Fisheries which endorsed its methods and findings. It now goes to the Commission, member states and the European Parliament for consideration. Largely on the basis of this report a decision will be made on whether a revised cod plan is required.
A Misguided Notion
The notion that constraining the time fishing vessels spend at sea could systematically reduce fishing mortality within a mixed, multi-species, multi-gear, multi-jurisdiction, fishery was a forlorn and misguided idea from the outset. Its adoption owed more to Brussels’ belief that effort (or input) control could be a simple and straightforward conservation measure to administer; especially because at the time the quota system was demonstrably failing because of black fish landings. It has been anything but. When the complexity of the first cod plan (2003-2008) proved unmanageable, responsibility for implementing effort control was shifted to member states through the allocation of individual pots of Kilowatt days for member states. The apparent flexibility associated with this approach has been quickly recognised as illusory. In fact, the system of effort control through Kilowatt days has become one of the more byzantine parts of the CFP.
In many respects the proponents of effort control have been behind the curve. Landing controls such as buyers and sellers’ registration, the reduction in the capacity of the fleets and a different mind-set within the industry, have pushed misreported landings off stage, a point accepted and commented on in the STECF/ICES report. Instead, there remains a problem of unaccounted removals of cod, of which discards are a significant but by no means the only factor. Few could credibly argue, in the face of the evidence of the last few years, that effort control is a realistic or effective approach to reducing discards. Discards of mature cod have soared at the same time that effort control has drastically ratcheted down permitted time at sea.
The North Sea and North West regional advisory councils both submitted position papers to the cod review, pointing out that the current management plan is based on two flawed assumptions: that a reduction in fishing effort (time at sea) would lead to a proportionate reduction in fishing mortality; and that relying on drastic TAC reductions would bring fishing mortality on cod down. The STECF/ICES report shares these views.
The report however, does highlight one area where the Cod Management Plan is getting it right, although even it is hamstrung by an excessively bureaucratic approach. This is the article 13 exemptions which motivate the industry and member states to adopt cod avoidance plans of various kinds, in return for exemption, or at least significant relief from, days at sea restrictions. The report acknowledges that this part of the plan has been effective, although much more could be done to build on the promising start that has been made, especially through the involvement of the industry in the design and implementation of cod avoidance measures and discard reduction initiatives.
The STECF/ICES report’s critical view of what has, or what can be achieved through effort control echoes the findings of a recent world-wide survey by researchers from Washington University. This report found high levels of over-exploitation in 47% of fisheries managed on this basis. This compare unfavourably with fisheries based on various types of quota constraints.
The report will now form the basis for discussions within the Commission, Council of Ministers and the European Parliament. There is a presumption within the report that the Commission will want to move on to the next stage, which is the preparation of an impact assessment for a revised cod plan. STECF gives some strong indicators on the approach that should be considered as a replacement, notably:
“Overall STECF concludes that the plan is not delivering reduced F and additionally in many areas does not have stakeholders’ support. A plan which stakeholders support is more likely to succeed because the stakeholders’ actions are needed to contribute to its success”.
However, a cod plan that is based on the support, involvement and cooperation of the principle stakeholders is incompatible with a framework that requires pre-programmed 25% reductions or similar hefty cuts in effort and TACs annually, when those cuts threaten the economic viability of those vessels.
Significantly, the Report also challenges the notion that it is currently possible to calculate the biomass reference points that are used to trigger these reductions because of endemic weaknesses in the assessments.
The immediate question is whether it is possible to turn Commission policy around in time to at least begin a new approach with more solid foundations next year. It is plain from the STECF report that further pre-programmed cuts in 2012 would:
- Do little or nothing to reduce fishing mortality of cod in the North Sea, Irish Sea or West of Scotland
- Increase the scope for discards
- Increase already severe economic strains within the fleet
- Alienate the very people that STECF/ICES consider should be at the heart of the cod plan
The STECF/ICES report is devastating for the credibility of the current cod plan. The question is whether the decision-makers in the Council, Commission and European Parliament can agree transitional arrangements along the lines suggested in the report in time for 2012, whilst a longer term approach is developed and agreed during the course of that year.