SDSG 4.10a – 4 June 2014
Rev. 5
27 May 2014
Joint Recommendation of the High-Level Group
Discard Plan for the North Sea
I.
Background
One of the main elements of the reform of the Common Fisheries Policy applying from
1 January 2014 is the gradual introduction of landing obligations for all catches subject to catch
limits. To this end Regulation (EU) no 1380/2013 (so called Basic Regulation) sets out the timeframes for the relevant fisheries as well as provisions for possible exemptions. At the same time this
regulation defines the general framework for regional cooperation on conservation measures.
According to the provisions of the Basic Regulation the landing obligation for pelagic and industrial
fisheries will come into force on 1 January 2015.
Scheveningen High-Level Group
Following Article 18 of the Basic Regulation the Fisheries Directors of the North Sea Member States
cooperating in the Scheveningen Group since 2004 established a High-Level Group (HLG) in
December 2013 and agreed on a Memorandum of Understanding setting out the principles and
working methods of the Group. Members of the Group are Belgium, Denmark, Germany, France, the
Netherlands, Sweden and the United Kingdom. From 1 January 2014 to 31 December 2014 the
Group is chaired by Germany.
Starting in autumn 2013 a specific Scheveningen expert group developed a first draft for a North Sea
Discard Plan for pelagic fisheries taking into consideration the guidance produced by the STECF
EWG 14-01. In parallel coordination with the North Western Waters Group was established in order
to ensure a consistent approach especially with regard to widely distributed species such as horse
mackerel, blue whiting and mackerel.
The HLG considered the first draft of the Discard Plan at its meeting on 18 March 2014 in Berlin.
Since then the Plan has been further developed in close consultation with the North Western Waters
Group. On 9 May 2014 the HLG reached agreement on the structure and the main elements of the
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plan and decided that further refinement should be done in particular with regards to the scope and
the proposed exemptions from the landing obligation. A separate discard plan is being developed for
industrial fisheries.
Consultation with relevant Advisory Councils
Being aware of the importance of solid input from stakeholders in the process of drawing up the
North Sea Discard Plan especially in relation to de minimis and high survivability exemptions and in
light of Article 18(2) of the Basic Regulation, the HGL-Chair sent a letter to the Pelagic Advisory
Council and the North Sea Advisory Council (AC) in January 2014 asking for specific
recommendations regarding the main elements of the future discard plan. In response to this demand
both ACs made comprehensive statements and presentations at the HGL meeting on 18 March and 9
May in Berlin. Further explanations and background information were given in the course of the
intensive discussion with the HLG at these two meetings.
For the time being only the Pelagic Advisory Council has been able to adopt agreed
“recommendations on implementing the EU landing obligation in pelagic fisheries”. The HLG
thoroughly scrutinized these recommendations. As regards the AC’s proposals on de minimis
exemptions the HLG was not able to follow the approach taken. While the AC recommends de
minimis exemptions for mackerel, blue whiting, boarfish, southern horse mackerel, herring (Celtic
Sea and south of Ireland) and possibly for other stocks pending ICES/STECF advice and sticks to the
current minimum conservation references sizes (MCRS) the HLG takes the view that, apart from one
specific case, no de minimis exemptions should be provided for. However, the HLG advocates the
removal of MCRS for mackerel, herring and horse mackerel.
The rationale behind the HLG’s approach is the following: Fisheries targeting small pelagic species
tend by nature to be very selective: Schooling pelagic fish normally occurs in single species
aggregations which causes catches to be relatively clean with little by-catch and there is a strong
economic incentive to only catch the target species since fishermen do not want to catch fish that
either cannot be sold or creates sorting difficulties.
At the same time available information on discards in pelagic fisheries does not indicate any major
discard problem.This information suggests that discards are generally at a low level. There seem to
be no incentives for fishermen to target juvenile fish for the time being. At the same time
survivability of released undersized fish which could have been utilized for human consumption is
extremely low. Hence, it appears that juvenile fish will not be endangered by removing MCRS
assuming that basic conditions remain unchanged.
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II.
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Proposal for a specific discard plan for pelagic fisheries in the North Sea
1. Implementing authority
a. Acting in accordance with Article 43(3) of the Treaty on the Functioning of the
European Union and taking into account the authority granted by Article 15.6 and
18.1 of Regulation (EU) No 1380/2013 to the European Commission to adopt discard
plans by means of delegated acts, the Member States of the North Sea submit a joint
recommendation, as per Article 18.3 of Regulation (EU) No 1380/2013, to the
European Commission for a specific discard plan for pelagic fisheries in the North
Sea.
2. Objectives of the discard plan
a. As a result of the reform of the Common Fisheries Policy (Regulation (EU) No
1380/2013), concluded in 2013 and effective from 1st January 2014, there is now a
provision under Article 18 for Member States to elaborate joint recommendations for
regional management measures specific to their fisheries and submit these to the
European Commission for adoption via delegated acts.
b. The scope of these recommendations is provided for in Article 18 of Regulation (EU)
No 1380/2013 by way of reference to Article 15(6) thereof, which outlines the process
for adoption of a specific discard plan by the European Commission for a period of no
more than three years, to contain any of the specifications referred to in points (a) to
(e) of Article 15(5).
c. Under Article 15(6) of Regulation (EU) No 1380/2013, Member States may
cooperate, in accordance with Article 18 thereof, in the drawing up of a specific
discard plan with a view to the Commission adopting such a plan by means of
delegated or implementing acts or via the Ordinary Legislative Procedure.
d. The adoption of such specific discard plans is considered important to the successful
implementation of the landings obligation as specified in the reformed Common
Fisheries Policy.
e. As such, this discard plan will establish provisions for any of the specifications
referred to in points (a) to (e) of Article 15(5) of Regulation (EU) No 1380/2013,
including specific descriptions of any exemptions gained.
f. In association with this discard plan, it is anticipated that there will be complementary
changes in technical conservation and control measures, to be specified in revisions to
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the Technical Conservation Regulation and the Control Regulation.. This is to ensure
there is no conflict between the technical and control measures and the proper
implementation of the landings obligation.
g. If such revisions to the technical and control measures required to support the
implementation of the landings obligation are not ready in time for the start of the
landing obligation on 1st January 2015, alternatives will need to be explored in order
to ensure compliance.
h. It is desirable that any technical, control or compliance measures adopted for the
pelagic fisheries in the North Sea be efficient, proportional, and enforceable across all
vessels operating under this discard plan.
i. It is the position of Member States that increased selectivity, where possible, is the
most desirable way to deliver compliance with the landings obligation.
j. The securing and use of exemptions is to be considered following the acceptable uses
specified in Article 15.4 of Regulation (EU) No 1380/2013, further specified under its
paragraph 5(c), and will be based on a thorough, evidence-based process.
k. It is intended that the Commission delegated act giving effect to this discard plan shall
remain open to revision and adaptation at any time during its duration of up to three
years in order to retain flexibility in addressing the challenges that will be posed by
the introduction of the landing obligation for pelagic fisheries. It is considered to be
the joint responsibility of the Commission and the Member States concerned to
maintain oversight of the implementation of the provisions of this discard plan and to
review and amend any element that evidence and/or improved data show is not fit for
purpose.
l. The Member States of the North Sea consider it desirable to achieve consistency
between all the recommendations for specific discard plans being drafted by regional
groups in EU waters.
m. In accordance with Articles 18.2 and 14 of Regulation (EU) No 1380/2013, the
Member States of the North Sea region consulted the relevant Advisory Councils in
the drawing up of this recommendation for a specific discard plan.
3. The extent of the discard problem in North Sea pelagic fisheries
a. The available information on discards in pelagic fisheries (STECF; ICES; Pelagic
AC) suggests that discards are commonly low. By-catch of demersal species (e.g.,
whiting, hake) seem to occur regularly. However, quantitative discard information is
scarce and the representativeness of scientific estimates is considered very low (s.
point 3.1.2 of the Discard Atlas for North Sea fisheries, [reference to be inserted after
publication]). Thus, the real extent of discards might substantially deviate from the
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figures at hand and constitute a problem for fishermen with regard to the landing
obligation.
4. Definitions
a. For the purposes of this discard plan the definitions used shall be those specified in
Article 4 of Regulation (EU) No 1380/2013.
5. Duration
a. As per Article 15.6 of Regulation (EU) No 1380/2013, this specific discard plan shall
have a duration of no more than three years.
6. Subject matter and scope
a. This specific discard plan is applicable to small pelagic fisheries subject to catch
limits in the North Sea, Skagerrak and Kattegat, comprising ICES sea areas IIIa and
IV, as per as per Article 15(1)(a) first indent of Regulation (EU) No 1380/2013.
b. This discard plan will apply to all fishing vessels engaging in pelagic fisheries with
the relevant gears in the North Sea, Skagerrak and Kattegat without prejudice to rules
applicable outside the aforementioned Union waters under Member State jurisdiction.
c. The relevant fisheries are defined in this plan as fisheries targeting species listed in
table 1 and 2. Whilst these tables are intended to be exhaustive it is acknowledged that
certain vessels targeting small pelagic species may not have been incorporated. In this
instance, part (b) of this paragraph will apply, as will Article 15.1(a) and Article
15.1(c)(iv) of Regulation (EU) No 1380/2013.
Table 1:
Code
Fisheries in ICES IIIa (Kattegat and Skagerrak)
Pelagic fishing gear
Species targeted
OTM and
PTM
Mid-water trawl and mid-water
pair trawl
Herring, mackerel, blue whiting,
horse mackerel
PS
Purse seine,
Herring, mackerel, sprat (assumed
human consumption)
OTB and
PTB*
Bottom otter and bottom pair trawl
Herring, mackerel, sprat (assumed
human consumption)
GNS and
GND
Gill nets anchored (set), and
gillnets (drift)
Mackerel, herring
LLS, LHP
[and
LHM]
Set longlines, handlines and pole
lines (hand operated) [and
handlines and pole lines
Mackerel
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(mechanised)]
MIS
Miscellaneous gear, including
traps, pots and pound nets
Mackerel, herring, sprat (assumed
human consumption)
*Bottom otter and bottom pair trawl with mesh size < 70 mm
Table 2:
Code
Fisheries in ICES IV (North Sea).
Pelagic fishing gear
Quota species targeted
OTM and
PTM
Mid-water otter trawl and midwater pair trawl (inc. TR3)
Herring, mackerel, horse mackerel,
greater silver smelt, blue whiting,
sprat
PS
Purse seines
Herring, mackerel, horse mackerel,
blue whiting
OTB and
PTB
Bottom otter trawl and bottom
pair trawl
Herring, mackerel, horse mackerel,
sprat (assumed human
consumption), greater silver smelt,
blue whiting
GNS and
GND
Gillnets anchored (set) and gillnets
(drift)
Mackerel, herring
GTR
Trammel nets
Mackerel
LLS, LHP
and LHM
Set longlines, handlines and poles
lines (hand operated) and handlines
and pole lines (mechanised)
Mackerel
MIS
Miscellaneous gear, including
traps, pots and pound nets
Herring, sprat (assumed human
consumption)
*Bottom otter and bottom pair trawl with mesh size < 70 mm
7. Landings obligation
a. As per Article 15 of Regulation (EU) No 1380/2013 all catches in fisheries subject to
catch limits specified in Article 15.1(a) of Regulation (EU) No 1380/2013 and listed
in paragraph 6 of this discard plan made during fishing activities in Union waters also
specified in paragraph 6 shall be brought and retained on board the fishing vessels,
recorded, landed and counted against the quotas where applicable, except when used
as live bait.
b. In addition, by-catches of all other species subject to catch limits caught during
fishing activities by Union vessels in the fisheries defined in this discard plan shall
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also be included in the landings obligation from 1st January 2015, except when used
as live bait.
c. The obligation to land all catches as specified in part (a) of this paragraph shall not
apply to species for which there is a specific exemption in accordance with Article
15.4 of Regulation (EU) No 1380/2013 and as detailed in paragraph 8 of this discard
plan.
8. Exemptions
a. Situations where the landing obligation shall not apply are specified in Article 15.4 of
Regulation (EU) No 1380/2013. This refers to species in respect of which fishing is
prohibited, as defined by a Union legal act, species and fishing practices for which
scientific evidence demonstrates high survival rates, and catches falling under the de
minimis exemption, as outlined in Article 15.5(c) of Regulation (EU) No 1380/2013.
Prohibited species and fishery products unfit for human or animal comsumption
b. Regarding prohibited species for pelagic fisheries, these are currently those that are
specified in Article 12 of Regulation (EU) No 43/2014 and will continue to be
specified in equivalent ongoing TAC and Quota Regulations, and stocks with an
annual total allowable catch of zero tonnes.
c. Taking into account that Regulation (EU) No 1380/2013 Recital (16) states that the
CFP should pay full regard, where relevant, to animal health, animal welfare, food
and feed safety and Article 3 point h) recalls that the CFP shall respect consistency
with other Union policies, catches of aquatic animals for which flesh contaminants
would exceed the maximum limits set by EU rules for human or animal consumption
shall also be covered by this exemption. According to food safety prescriptions as set
out in Regulation (EC) No 853/2004 of the European Parliament and of the Council as
well as in Commission Regulation (EC) No 1881/2006 catches of contaminated fish
shall not be kept on board a vessel. This fish has to be disposed directly into the sea.
High survivability
d. Regarding high survival, as detailed in Article 15.4 (b) of Regulation (EU) No
1380/2013, species caught by certain gears and taking into account fishing practices
and the ecosystem may be exempted from the landings obligation based on scientific
evidence of high survival (see paragraph (d)).
e. In the event of high survivabilitiy in specific fisheries, such as purse seines or pound
net fisheries, Member States will submit proposals for exemptions on a case-by-case
basis underpinned by scientific evidence.
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f. [The Member States recommend that a high survivability exemption should apply in
the following case: Fisheries for mackerel and herring in pound nets. See annex A for
supporting evidence.]
De minimis
g. According to recital 31 of Regulation (EU) No 1380/2013 de minimis exemptions
from the landing obligation should be established in order to cater for unwanted
catches that are unavoidable even if all the measures for their reduction are applied.
h. Regarding de minimis, as detailed in Article 15.4 (c) and further 15.5 (c) of
Regulation (EU) No 1380/2013, there is provision for de minimis exemptions of up to
5% of total annual catches of all species subject to the landing obligation. The de
minimis shall apply:
i. where scientific evidence indicates that increases in selectivity are very
difficult to achieve; or
ii. to avoid disproportionate costs of handling unwanted catches, for those fishing
gears where unwanted catches per fishing gear do not represent more than a
certain percentage, to be established in a plan, of total annual catch of that
gear.
iii. For a transitional period of four years, the percentage of the total annual
catches specified shall increase: by two percentage points in the first two years
of application of the landing obligation; and by one percentage point in the
subsequent two years.
i. Although the catches discarded under de minimis will not be counted against quotas,
any amount of catch discarded under application of de minimis shall be fully recorded
according to Article 15.5(c) second subparagraph of Regulation (EU) No 1380/2013
and taken into account by ICES in preparing their annual scientific advice..
j.
Fisheries targeting small pelagic species tend by nature to be very selective:
Schooling pelagic fish tend to occur in single species aggregations which causes
catches to be relatively clean with little by-catch and there is a strong economic
incentive to only catch the target species since fishermen do not want to catch fish
that either cannot be sold or creates sorting difficulties. [At the same time available
information on discards in pelagic fisheries does not indicate any major discard
problem].
k. The Member States recommend that a de minimis exemption should apply in the
following case:
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l.
[i - A maximum of 6% for years one and two, and 5% for year three for the artisanal
pelagic trawlers (using gear types OTM, PTM, OTB, PTB) targeting mackerel, horse
mackerel and herring in ICES area IV (% of the national quotas by gear type,
allocated to the Member State whose vessels are concerned). The available evidence
that demonstrates that the criteria of Article 15.5(c) of Regulation (EU) no 1380/2013
are met is detailed in Annex B.].
9. Documentation of catches
a. In accordance with Article 15.5(d) of Regulation (EU) No 1380/2013, specific discard
plans can make provisions on documentation of catches.
b. Catches of species subject to catch limits shall be recorded with the correct scientific
species name in order to quantify the exact catches, in accordance with Regulation
(EC) no 1224/2009. Documentation should be sufficiently rigorous to enable robust
scientific assessments to be undertaken and the application of methods of control.
c. [The North Sea group may wish to take account any advice issued by the
Scheveningen Control Experts Group relating to the documentation of catches in due
course.]
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10. Fixing of Minimum Conservation Reference Sizes (MCRS)
a. In accordance with Article 15.5 (e) and 15.10 of Regulation (EU) No 1380/2013,
MCRS may be established in specific discard plans with the aim of ensuring the
protection of juveniles of marine organisms.
b. If MCRS is already established in another Regulation, such as in the Technical
Conservation Regulation, then Member States may submit regionally-agreed
recommendations for the fixing of MCRS as part of specific discard plans.
c. The fixing of MCRS could take into account a variety of issues, including: the setting
of MCRS for market considerations; limiting the supply of particular size ranges to
prevent oversupply; social or ethical reasons; biological and ecologic considerations.
d. Changes to MCRS are under consideration in the Proposal for a Regulation of the
European Parliament and of the Council amending Council Regulations (EC) No
850/98, (EC) No 2187/2005, (EC) No 1967/2006, (EC) No 1098/2007, No 254/2002,
(EC) No 2347/2002 and (EC) No 1224/2009 and repealing (EC) No 1434/98 as
regards the landing obligation (otherwise known as the “Omnibus Proposal”)
e. The available information on discards in pelagic fisheries including juvenile fish
suggests that discards are generally at a very low level. There seem to be no
incentives for fishermen to target juvenile fish for the time being. At the same time
survivability of released undersized fish which could have been utilized for human
consumption is extremely low.
f. Therefore, the Member States of the North Sea region recommend to remove the
MCRS for mackerel, herring and horse mackerel (see table 2).
Table 3: Current minimum landing size and new MCRS
Species
Mackerel
Scomber scombrus
Herring
Clupea harengus
Current minimum landing size
New MCRS
areas 1-5
Skagerrak/Kattegat
all relevant areas
30cm1
(North Sea)
20cm
0 cm
20cm
18cm
0 cm
1
This is only a marketing standard (Reg.(EC) no. 2406/96) , there is no minimum landing sizes for mackerel in the North
Sea.
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Horse mackerel
Trachurus trachurus
15cm
15cm
0 cm
11. Revision and adaptation
a. Taking into account that the landings obligation constitutes a wholly new regime in
the management of fisheries in the EU, and that specific discard plans are a new
management tool, it has been agreed that this discard plan shall remain open to
revision and adaptation throughout its duration.
b. It is considered to be the joint responsibility of the Commission and Member States to
maintain oversight of the implementation of the provisions of this discard plan and to
call into question any element which may be in need of revision and adaptation at any
time.
c. In particular, this discard plan shall remain open to the later inclusion of exemptions
under high survival and de minimis, and to the inclusion of specific provisions for
MCRS to be specified at any time.
12. Other issues
a. Member States agree the need to have a coordinated regional approach on the
following items in support of the above recommendations for a specific discard plan:
i. Specification of quota convertibility for the application of interspecies
flexibility.
ii. Equivalence of enforcement measures.
iii. Force majeure.
iv. Technical measures.
Any arrangements deemed helpful for facilitation in-year quota exchanges.
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Annex A
Exemption for pound net fisheries from landing obligation for reason of high survivability
Exempted species:

Mackerel (Scomber scombus)

Herring (Clupea harengus)
Stocks:
Mackerel and herring in the North Sea, Skagerrak and Kattegat, ICES sea areas IV and IIIa.
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Management unit, incl. gear, catch composition, operational characteristics:
Fisheries using pound nets entails a method where nets are staked out perpendicular to the coast in
permanent location for the season. Nets are emptied every day or for more days (up to 4-5 days) if
the weather is poor. Fish are kept under water and are able to swim around in the holding area of the
net until the net is emptied.
The nets are emptied by pulling the holding area of net onto the vessel.
Fish being let go from the nets occurs before bringing the catch on board if the fisherman finds that
the catch does not comply with expectations for the catch (species and size). The net can then be
lowered to allow the fish to leave the holding area. Alternatively the catch is handled on deck in les
than 5 minutes before being returned to the sea. In some cases however, the catch will be landed in
full as the vessels do not have the capacity to sort on board. The catch will then comply with the
landing obligation.
Selectivity is optimized by placing the nets in the migrating routes of the targeted species.
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Fisheries using pound net (DCF gear type classification FPN) seem to have full survivability of the
fish led to the holding area of the net. See Rostock report2, March 2014 on pound net fisheries of
cod. According to this study all fish are released alive on board, specimens with minimum landing
size are landed, under-sized specimens are released alive. The sorting process onboard usually takes
only a few minutes. Survival of released fish is considered to be close to 100%. Similar survivability
is expected for mackerel and herring although no studies have been made. No data are available for
discards in pound net fisheries of mackerel and herring.
Catches
Danish catches of mackerel and herring using pound nets (FPN) in ICES IV and IIIa:
kilos
2010
Mackerel IIIa
Herring
35.550
3AN
3AS
980
4B
4.145 .
4N
4R
2012
83.742
11 .
4L
Total
2011
19.100
.
2013
116.511
.
2.120
141.538
.
21.033
.
3.950
13.227
4.500
12.150 .
18 .
1.756
346.564
361.853
323.208
294.503
406.350
451.683
472.902
455.524
Catches of other Member States to be added.
Monitoring:
As pound nets are stationary nets controls can easily be carried out by the national control body.]
2
Thünen Institute of Baltic Sea Fisheries, Germany: Survivability og cod in pound nets, 04.03.2014
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[Annex B
Supporting evidence for application for a de minimis exemption to the landing obligation for
artisanal trawl fisheries targeting mackerel, herring and horse mackerel in ICES sea area IV
1. Level
Given the difficulty to increase the selectivity and the disproportionate cost of handling unwanted
catches, a de minimis exemption of 6% of their total annual catches of all species subject to the
landing obligation is requested for the first two years (2015 and 2016) for the French artisanal
pelagic trawlers targeting mackerel and herring in North Sea (Table 1). This percentage should be of
5 % after the third year.
The differences between small and large scale pelagic fisheries in terms of number and
diversity of fisheries, in terms of causes and composition of discards, and in terms of existing data,
have to be kept in mind when assessing the evidence available in such a short time to support the
application for a de minimis for the French artisanal small pelagic fisheries.
2. Difficulty to increase the selectivity
French artisanal small pelagic fisheries have particularly low rates of discards due to their selective
nature, including the fact that fishermen already adopt voluntarily spatio-temporal measures to avoid
unwanted catches. Nevertheless, unwanted catches might be more important and diverse than for
large scale pelagic fisheries, notably because the fishing areas are close to the coast and / or are at
small depth, explaining for example the presence of demersal species in some catches and discards.
Discards are mainly a mixture of species, or sizes of the same species.
As Pelagic RAC recommendations emphasized, the rather clean nature of small pelagic fisheries may
explain why there has been only limited development and research effort directed to increasing
selectivity in pelagic trawl fisheries. Consequently, increasing selectivity in pelagic fisheries is
extremely difficult with the technology currently available.
It is important to notice that scientific studies are ongoing or planned in France and Europe
(REDRESSE, SIMBAD, EODE, EU fund call "H2020") to test new selective devices and new
spatio-temporal approaches for small pelagic fisheries to avoid residual discards of species under
quota, especially under new technical measures context. New results are expected in two to three
years but would not be available on time for the beginning of the landing obligation and the
implementation of the first discard plan.
Considering the example of the pelagic fishery detailed from the ObsMer data and the planned
studies (see below), the difficulty to increase the selectivity should lead to de minimis exemptions for
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fisheries targeting mackerel, herring and horse mackerel in North Sea at least for the first years of the
landing obligation, notably in order to ease its implementation.
The number of ObsMer data in 2011 and 2012 is unfortunately insufficient to characterize the
discards of the French artisanal small pelagic fisheries targeting mackerel, herring and horse
mackerel in the North Sea. Nevertheless, most of the vessels also fish in VIId with the same kind of
gear and with almost the same discards in terms of composition and causes; they are taken as
example to justify the need for a de minimis. This example illustrates the composition and the causes
of the discards
It is important to note that results from ObsMer may highly vary from a year to another. No
or not enough ObsMer data are available for the others pelagic métiers and gears in the North
Sea.
Example of pelagic trawlers targeting mackerel (ObsMer)
The 2012 results of ObsMer for this fishery show low discard rates of species under catch
limits (Table 2), underlining its already high selectivity. Discards reason depend of the
species, and concerns quota limitations, minimal landing size or the (local) low market value.
Discards of undersized mackerel occur in the ICES subarea IVc because of the different
minimal size (30 cm) compared to the VIId (20cm). The removal or at least the harmonization
of the minimum reference conservation size (so as to have a minimum reference conservation
size of 20 cm in the North Sea) between the two areas would help to reduce unwanted catch
of undersized mackerel.
The low market for horse mackerel explains the majority of the discards observed; it seems
difficult to develop a market for this specie in France on the short term. It also seems really
difficult to increase the selectivity, as the discards already represent a small percentage of the
catches. Market problem also apply to some catch of demersal species.
Finally, some discards are also due to the quality of the fishes, which can be damaged by the
scissors effect and others mechanical effects of the nets (< 1%). Few solutions exist for these
kinds of discards, especially in terms of selectivity.
As demonstrated for pelagic trawlers for mackerel in VIId, whose characteristics can be transposed
to pelagic trawlers in IVc, if some solutions are already in place, it will not be enough to take into
account all the residual discards of these fisheries. Selectivity is already high for small pelagic
fisheries and cannot be enhanced by January 1st, 2015.
Table 2. Discards information available for small pelagic fisheries in North Sea based on the pelagic
trawlers targeting mackerel in VIId.
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Total
discard
rate in
2012
Gear : OTM / OTB
Target species : Mackerel
Mesh size : < 70 mm
ICES area: VIId*
Number of boats** : 78
Sampling 2012 : 30 ft ; 43 fo
11% [4 ;
20]
Total discard of
species UCL /
total catches of
species UCL in
2012 (ObsMer)
12% [4 ; 20]
Species
UCL
mainly
discards
(ObsMer)
Mackere
l
Catches of the
species / total
catches of
species UCL in
2012 (ObsMer)
82% [73 ; 92]
Discard of the
species / total
catches of
species UCL in
2012 (ObsMer)
2% [0 ; 2]
Demersa
l species
11% [1 ; 20]
8% [0 ; 17]
Horse
mackerel
Herring
6% [1 ; 11]
1% [0 ; 2]
1% [0 ; 2]
1% [0 ; 2]
Cause of
discarding
(CarRejet ;
Leleu et al.
2014)
Quota
limitat
ion
Minim
al size
No
market
No
market
Quota
limitat
ion
[ ] Intervals of confidence; ft : Fishing trip ; fo : Fishing operations; UCL : under catch limits
*Not enough data for ICES areas IVb and IVc
**The number of boats calculated by ObsMer does not necessarily reflect the specific métiers and/or target species they
sampled (example : the number of boats in VIId concern boats targeting mackerel and herring, but 96% of the fishing
operation sampled apply only to mackerel)
3. Disproportionate costs of handling unwanted catches
To support this exemption request, it is also important to emphasize that the landing obligation will
result in many additional costs,as underlined by the Commission staff working paper,
2011(http://ec.europa.eu/fisheries/reform/sec_2011_891_en.pdf). These costs are disproportionate
compared to the valorisation which could be made of the unwanted catches to be landed.
1. Unwanted catches is often due to the absence or the low local market because of the inherent
low market value of some species (horse mackerel, herring) or the quality of the fishes
(scissors effect of the nets, etc.)
2. Catches are sorted by men and not machines, thus increasing the labour cost onboard if
unwanted catches with low market value have to be sorted and stored
3. Vessels have a legally limited capacity of storage, which may be affected by the need to store
unwanted catches at the expense of targeted and commercial catches
4. Storing these catches (storage box and icing in particular), if mandatory, will increase the cost
of fishing. Moreover, most of the artisanal vessels (~25 years old in average) will certainly be
technically unfitted to handle all the unwanted catches
5. Companies which can enhance the economic value of unwanted catches are still rare in
France, resulting in additional costs related to the logistics of collecting these unwanted
catches. Their onshore processing will be even more problematic, because landings of
unwanted catches will not be regular in terms of quantity and quality
6. Development of new market for unwanted catches will not be possible before January 1st,
2015
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27.05.2014
Because of the diversity and the complexity of the French artisanal pelagic trawler fisheries, but also
because of the non-existence of data allowing calculating them, information on revenue losses
induced by the landing obligation could not be collected in such a short time.
4. References
Commission staff working paper. 2011 Impact assessment accompanying Commission proposal for a
Regulation of the European Parliament and of the Council on the Common Fisheries Policy
[repealing Regulation (EC) N° 2371/2002].
Cornou A-S., Diméet J., Tetard A., Gaudou O., Dubé B., Fauconnet L., Rochet M-J. 2013.
Observations à bord des navires de pêche professionnelle. Bilan de l'échantillonnage 2012.
http://dx.doi.org/10.13155/27787
Leleu, K., Rochet, M-J., Frangoudes, K. et Ciolek, D. 2014. Document de restitution finale CarRejet
: Caractérisation des Rejet. CNPMEM. 82 pp
Leleu, K., Rochet, M.J., Frangoudes, K., Trenkel, V. 2014. Identification des causes de rejet. Cas
d’étude CarRejet. CNPMEM. 100 pp
Pelagic Regional Advisory Council. 2014. Recommendation on implementing the EU landing
obligation in pelagic fisheries. 102 pp]
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