Sea fisheries - future catching policy: consultation analysis

8. Discard exemptions (Q20)

Q20. Issues or unintended consequences of accounting for discard in this way

Overview

8.1. The consultation frames the way that the landing obligation and total allowable catch deductions have worked in the past and asks respondents to consider a proposed simpler system of discard rules. This system would involve making deductions to total allowable catches for species below Minimum Conservation Reference Sizes (MCRS) in a way that allows fishers to discard the catch under a blanket exemption, but the catch would be accounted for and factored into stock assessments and quotas.

8.2. Question 20 received 134 closed responses with 68% of answers indicating that respondents did foresee issues or unintended consequences of accounting for discards in the way the consultation proposes.

8.3. 91 respondents (61 individuals and 30 organisations) provided open response descriptions of issues foreseen. A wide variety of issues were suggested, most falling under the following two themes: sustainability issues and implementation issues.

Sustainability

8.4. Concerns with sustainability generally centred on discards and bycatches. Firstly, one argument among those who opposed the premise of accounting for discards in the way set out in the consultation document is that they viewed tight restrictions on discards or a ban on discards as favourable for sustainability reasons. Secondly, many respondents viewed these proposals as removing fishermen's incentives to avoid bycatch, and that this would therefore increase bycatch and reduce sustainability in fishing.

"Discarding must be outlawed; it is unacceptable in an age of biodiversity and climate crises. It is appalling that such cavalier activities are still allowed." [Individual]

"The purpose of the landing obligation was to incentivise avoidance behaviours, encourage and incentivise a shift towards more selective gear and to reduce catches of depleted stocks. Simply, allowing for a blanket exemption for undersize fish will completely remove any incentive to avoid catching these fish." [Organisation, Conservation]

"The fact that Marine Scotland are removing the individual incentive to avoid bycatch and are essentially doing away with the discard ban/landings obligation is reprehensible and makes this proposal not fit for purpose!" [Organisation, Fishing organisation]

Implementation issues

8.5. Various responses came under the umbrella of general implementation issues. On one side, concerns were expressed that it would be a challenge for scientists to come up with the required estimates, and that this could result in science being out of touch with fish stocks and the implementation of excessively low quotas. There were also concerns about enforcement and ability for fishermen to falsely report this information, with some respondents explicitly mentioning the role of REM in mitigating this.

"The success of these deductions is going to lie in the effectiveness of monitoring catches. The claim is made that "the catch would be fully accounted for and factored into stock assessments and quotas" but no indication is given as to how this will be achieved. Without effective monitoring through the use of REM and cameras to inform TAC deductions or quota top-ups, unintended overfishing may occur. It is vital access to quota top-ups is only given to vessels which can demonstrate compliance with the Future Catching Policy and all authorised discards are fully deducted from the TAC to prevent undermining efforts made to restore and protect fish stocks." [Organisation, Conservation]