There is agreement across the board (including from fishermen) that discards are undesirable and wasteful. From an ecological and ethical point of view discards are highly controversial. For a start, they are wasted food. Discards can also lead to the underestimation of fishing mortality where large quantities of a stock that is subject to Total Allowable Catch (TAC) regulations is discarded - this underestimation impairs sustainable management of that stock. However there is disagreement as to the best way to address the problem.
The authors of the paper argue that the following impacts of the new discard ban have been overlooked:
1. Effects of the ban at different levels of biological organisation:
a. Several marine species (eg seabirds and bottom-dwelling invertebrates) have, for decades, adapted to the 'unnatural' source of food provided by discards. A substantial reduction in discards in the marine environment through forcing such discards to be landed will have direct and indirect effects on such species which are as yet unknown;
b. As discarded biomass is a source of energy which is removed and then immediately returned to the ecosystem, landing the discards increases the net loss of biomass and production which could impact the resilience of the ecosystem and accelerate its deterioration by reducing secondary production and recycling of energy.
2. Economic, operational and technical challenges of the ban:
a. The landing of discards could create new fishmeal markets (for aquaculture and agriculture) so perversely, the discard ban could encourage rather than discourage the production of discards (to take advantage of such new markets);
b. Fishers will have additional operational costs from landing discards and storing them onboard which means a reduced capacity to land products of higher economic value and these costs are likely to be covered by subsidies. Public subsidies to fishing which have long been heavily criticised as detrimental for the ecosystem and for the profitability of European fisheries.
c. Enforcement of the ban will be very difficult especially if there are little or no economic incentives to land discards with little market value.
The authors state that it is contradictory to avoid discards by promoting their landing and not by reducing discards at source. They suggest that a real reduction in discards can be achieved more effectively through (a) a focus on developing more selective and non-destructive fishing gear (eg to allow identification of target species in the water before capture); (b) the enforcement of regulations; (c) reducing overall fishing capacity. They conclude by calling for an investigation of the impacts of the discard ban from a scientific and technical perspective before it is implemented.
I think it is important that the impacts of the ban should be investigated from more than just a scientific and technical perspective. The authors argue that the Ecosystem Approach is being disregarded by the discard ban's failure to take into account the potential negative effects of the ban on different levels of biological hierarchy within an ecosystem. However, their call for investigation of the impacts of the ban from a 'scientific and technical perspective' with 'a rigorous and open scientific debate on key issues' is too narrow. The Ecosystem Approach is not limited to biological science. The definition of the Ecosystem Approach by the Convention on Biological Diversity (CBD) takes us away from the idea of an ecosystem as a tangible biophysical unit by recognising that that humans, with their cultural diversity, are an integral component of ecosystems. The application of the Ecosystem Approach is supposed to help reach a balance of the three objectives of the CBD: (i) biodiversity; (ii) sustainable development; and (iii) equitable sharing of benefits. Application of the 12 principles of the Ecosystem Approach is supposed to follow five points of operational guidance:
1. Focus on the relationships and processes within the ecosystem
2. Enhance benefit sharing (which provides the basis of human environmental security and sustainability)
3. Use adaptive management practices
4. Carry out management actions at the scale appropriate for the issue being addressed, with decentralisation to the lowest level, as appropriate
5. Ensure intersectoral co-operation
If the Ecosystem Approach is being diregarded by the discard ban, it is important not to disregard this very approach in tackling the issues.