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This research aimed gain a better understanding of the practice of discarding and stakeholders’

perceptions of the LO. This was done by interviewing 24 stakeholders from NGOs, the Ministry of LNV, the Directorate General of Maritime Resources of the EU, (ex)-fishers, fisheries representatives and by investigating the practice of discarding by using a social practice approach on board a Dutch demersal cutter. The understanding of different stakeholder perceptions can thereby contribute to bridging the gap between policy and practice and the social practice application can thereby lead to a better understanding of how the practice of discarding can be changed. This led to the formation of a central research question and three sub-questions which will be answered in this concluding chapter. The main research question of this research is:

RQ: What are the current practices of discarding since the introduction of the Landing Obligation and what are the perceptions of stakeholders of the Landing Obligation in Dutch demersal fisheries?

The sub-questions are:

SQ1: What is the CFP and what does the Landing Obligation entail?

SQ2: What are the current practices of discarding?

SQ3: What are the current perceptions of the Landing Obligation of the multi-level governance actors (science, policy-makers, the fishing industry and NGOs)?

8.1.1 SQ1: What is the CFP and what does the Landing Obligation entail?

The CFP was gradually introduced in the 1970s, granting European member states access to each other’s waters and eventually led to the introduction TACs and the division of quota among member states based on the relative stability key in 1983. This introduction also meant the introduction of technical measures and the creation of the STECF which should complement ICES in providing fisheries advice. The goal of the CFP was thereby to manage fisheries sustainably as this sector is highly susceptible to the Tragedy of the Commons as described by Hardin (1968). The 1992 and 2002 reforms of the CFP were both seen as not being very ambitious and the problem of discarding was in both reforms seen a being insignificant and an inevitable result of fishing. In 2006, however, the STECF released a report stating the discards could reach up to 60% in beam trawl fisheries in the North Sea, which led to a ban on high-grading. The discard issue increasingly gained public awareness and was seen as undermining the CFP. This eventually led to the LO, which was gradually phased in from 2015 to 2019, implying that all TAC-regulated (including undersized fish) species and species with MLS should be landed whereas these previously had to be discarded. The landed undersized fish are due to this regulation only allowed to be used for non-human consumption by using these for fishmeal or fish oil extraction as this would otherwise lead to the creating a market for undersized fish. The LO led to a 30% increase in TACs and meant the introduction of some exemptions to keep the LO somewhat feasible. The top-down introduction of the LO thus meant a radical shift in the discard paradigm and fisheries management to solve the discard problem by increasing selectivity measures.

8.1.2 SQ2: What are the current practices of discarding?

As appeared from the participatory observation on board of a Dutch cutter, it appeared that the practice of discarding is a highly routinized practice involving three different phases of discarding with the fishermen being the practitioners. The first phases of discarding takes place on deck while picking the sized fish from the mesh in the net while the undersized fish are left in the net. The second and third phases of discarding take place on the conveyor belt where the sized fish are picked and put in baskets in the second round on the basis of estimation and are re-measured on a measuring board in the third round. The material elements of discards hereby appeared to be primarily the MLS, the mesh size, the fishing grounds, the measuring board and

treated as being an object rather than a living being and that discarding primarily occurred on the based on value and compliance with the relevant exemptions on board. Furthermore, regarding the competences and knowledge sharing, the fishermen rarely communicated about discards but primarily communicated about good or bad hauls. The quantity of discards was not seen as a complicating factor and would also not lead to a change of fishing grounds in cases when hauls were sufficient. Communication with other fishermen and vessels thereby also occurred rarely as there is a high level of competition in Dutch fisheries. Moreover, it appeared that the fishermen should have the skills of recognizing marketable fish and should have knowledge of the relevant exemptions. The fishermen declared that the LO is an unfeasible policy due to the high quantity of discards, which has not led to a change of practice of discarding but has only led to more hassle. As this vessel cooperates in an FDF research project, this implied that six hauls of discards should be kept and sorted, leading to a substantial increase of work and the deliberate killing of juvenile fish as the fishermen stated. According to them, the exemptions are the only way to stay economically alive. Regarding the on-shore practices, it appeared that fish prices, owning quota, fishing gear innovation and the creation of exemptions are the most important practices influencing discard routines. Consequently, the fishermen all plead for an alternative to the LO.

8.1.3 SQ3: What are the current perceptions of the Landing Obligation of the multi-level governance actors (science, policy-makers, the fishing industry and NGOs)?

From the interviews appeared that since the introduction of the LO in the demersal fisheries sector in 2019, little has changed in the practice of discarding due to several reasons. Firstly, from almost all interviews it appeared that there is low to zero monitoring or control of the LO regarding the landings and registration of the undersized fish on both EU and Dutch governmental levels. This business-as-usual effect also relates to the fact that a substantial number of exemptions have been granted by the Dutch government based on various grounds.

These exemptions, however, are by NGO representatives seen as undermining the LO as it prevents the selectivity effect, whereas from a fisheries industry perspective these exemptions are seen as essential to keep fisheries going and the LO workable. Increased selective fishing gear is by the fishing industry not seen as attractive as this will also lead to a loss of marketable fish and thus a loss of money. NGO representatives, however, state that this selectivity should be enforced by law or be actively controlled with CCTV of which the fishermen think this insults their privacy. The fact that fishermen do not take up more selective gear also relates to the highly competitive nature of fisheries, the incidence of free-riding and the large division within the Dutch demersal sector as fishermen who cooperate in research projects with the government are often denigrated. Interestingly, the LO has according to the interviewees led to greater awareness of discards, but these discards are not perceived as harmful. NGO representatives and policy-makers, however, still perceive the amount of discarding problematic, which is mainly caused by the high amount of exemptions. Furthermore, the landings of undersized fish were oftentimes not used for non-human consumption but destroyed. In addition, all stakeholders agreed upon the fact that the relationship between researchers and the fishing industry has improved due to the LO. The fishermen, however, are very distrustful towards the policy-makers in both Brussels and The Hague as the LO has according to them little to do with the demersal fishing practice.

8.1.4 Answer to main research question

Overall, the answers to these research sub-questions lead to the conclusion that that LO has been introduced by a means of a hierarchical approach to solve the discarding problem in EU fisheries as undersized fish should be landed with this policy to incentivize selectivity measures.

This research has shown that the LO is presently an unfeasible policy measure in Dutch demersal fisheries (with current fishing practices) due to the large quantity of discards and the fact that the practice of discarding has largely remained unchanged due to the derogations. The discarding practice is thereby primarily economically motivated, consists of three phases of discarding and is of highly routinized routine. Thereby, it appeared that the selectivity measures of the LO have not been achieved, there is little to no control of the LO and undersized fish are in the Dutch case not processed in fishmeal or fish oil, but destroyed. The LO has, from a fisheries perspective, led to some change in awareness about discards, but such discards are not deemed problematic as they are feed for the healthy North Sea ecosystem. Policy-makers and NGO representatives, however, state that discards are still a very problematic issue. The exemptions are, according to the fisheries sector respondents necessary to survive economically, whereas NGO representatives perceive these as undermining the policy.