FOOD CERTIFICATION INTERNATIONAL LIMITED Findhorn House, Dochfour Business Centre, Dochgarroch, Inverness, IV3 8GY, Scotland, UK Tel: 00 44 (0) 1463 223 039 Fax: 00 44 (0) 1463 246 380 www.foodcertint.com
MSC Sustainable Fisheries Certification
Public Comment Draft Report for the Irish Pelagic Sustainability Group (IPSG) Western mackerel ( Scomber scombrus ) pelagic trawl fishery
JUNE 2009
prepared for: Irish Pelagic Sustainability Group (IPSG)
by: Food Certification International Ltd
A company incorporated in Scotland No SC313289. Registered address as above
IPSG Western mackerel pelagic trawl fishery
June 2009
Authors: T. Southall, P. Medley, N. Pfeiffer, M. Gill, M. McFadden
Certification Body: Client Contact: Food Certification International Ltd Irish Pelagic Sustainability Group Findhorn House Bruach na Mara Dochfour Business Centre St Catherine’s Road Dochgarroch Killybegs Inverness Co. Donegal Scotland Eire IV3 8GY UK
T: +44(0) 1463 223 039 T: +353 74 973 1089 E: [email protected] E: [email protected] W: www.foodcertint.com W: www.kfo.ie
Food Certification International Public Comment Draft Report
IPSG Western mackerel pelagic trawl fishery
Contents
1. Introduction...... 1 1.1 Scope...... 1 1.2 Report structure...... 1 1.3 Inspections & Consultations ...... 1
2. The fishery...... 3 2.1 The unit of certification ...... 3 2.2 The Irish Pelagic Sustainability Group...... 3 2.3 Fishing Fleet & Fishing Method...... 4 2.4 Target species ...... 6 2.5 Catches and landings ...... 8
3. Target stock status & harvest controls (P1)...... 10 3.1 Status of the Stock ...... 10 3.2 Reference Points ...... 11 3.3 Rebuilding Status ...... 12 3.4 Harvest Strategy...... 12 3.5 Harvest Control Rule and Tools...... 14 3.6 Information and Monitoring...... 15 3.7 Stock Assessment ...... 19
4. Environmental elements (P2)...... 21 4.1 Slipping...... 21 4.2 Discarding...... 22 4.3 Habitat ...... 23 4.4 Ecosystem impacts...... 23 4.5 Endangered, threatened and protected species (ETP) ...... 24
5. Administrative context (P3) ...... 25 5.1 Legislation ...... 25 5.2 Roles & Responsibilities ...... 26 5.3 Monitoring, Control and Surveillance...... 27 5.4 Compliance...... 28 5.5 Dispute resolution...... 29
6. Background to the evaluation ...... 30 6.1 Assessment team ...... 30 6.2 Public consultation...... 31 6.3 Stakeholder consultation ...... 32 6.4 Interview programme...... 32 6.5 Other certification evaluations and harmonisation...... 33 6.6 Information sources used ...... 33
7. Scoring...... 35 7.1Scoring Methodology...... 35 7.2 Scoring ...... 37
8. Certification recommendation...... 40 8.1 Overall Scores ...... 40 8.2 Limit of Identification of Landings ...... 40 8.3 Conditions...... 40 8.4 Recommendations...... 43 Food Certification International Public Comment Draft Report
IPSG Western mackerel pelagic trawl fishery
9. Applicant’s agreement to conditions...... 45
Appendix 1 – MSC Ps & Cs ...... 46 Principle 1...... 46 Principle 2...... 47 Principle 3...... 47
Appendix 2 – References ...... 49
Appendix 3 – Assessment Tree / Scoring sheets ...... 53 Principle 1...... 53 Principle 2...... 58 Principle 3...... 72
Appendix 4 – Peer review reports ...... 81
Appendix 5 – Client action plan...... 94
Food Certification International Public Comment Draft Report
IPSG Western mackerel pelagic trawl fishery
1. Introduction This report details the background, justification and results of Food Certification International’s (FCI) assessment of the Irish Pelagic Sustainability Group (IPSG) Western mackerel pelagic trawl fishery, carried out by Food Certification International to the standard of the Marine Stewardship Council (MSC) sustainable fishery programme. 1.1 Scope First and foremost, the purpose of this report is to provide a clear and auditable account of the process that was undertaken by the team of FCI assessors. The report aims to provide clear justification for the assessment scores that have been attributed to the fishery, and identify the sources of information that have been used to support these. This should enable subsequent surveillance or even re-certification teams to rapidly pin-point where the key challenges lie within the fishery, and quickly highlight any changes which may affect the overall sustainability of the fishery. In order to provide useful background and information for a wider readership it is also useful to provide a more qualitative account of the fishery in question. However, it should be reiterated that no primary research has been undertaken to inform this report. The report is therefore not intended to comply with the standard editing norms expected for scientific journals. Instead it is intended that the report should be sufficiently clear and unambiguous to be reviewed by fisheries specialists, whist remaining sufficiently accessible to provide insight for interested readers throughout the supply chain – including consumers. This is a challenging balance to strike without alienating either readership. 1.2 Report structure Early report sections provide the reader with a clear comprehension of the nature of the fishery, enabling a broader understanding of the issues debated by the team when scoring the fishery. For the purposes of precision, this begins with a description of the unit of certification, before expanding to outline some further background information, including details of the Irish Pelagic Sustainability Group, the fleet, fishing operations and gear and the species itself. Subsequent sections are then broadly aligned to the 3 MSC principles 1, which form the basic structure of the assessment, namely: • Principle 1: Target stock status and harvest controls (summarised in section 3) • Principle 2: Wider impacts of fishery operations (summarised in section 4) • Principle 3: The management System (summarised in section 5) Later sections of the report explain the procedures used to score the fishery, give details of the assessment team, and present the outcome of the team’s deliberations. Finally the report provides a statement of the team’s recommendations as to whether or not this fishery should go forward for certification to the standard of the Marine Stewardship Council, together with any conditions recommended. 1.3 Inspections & Consultations The full assessment process commenced in July 2008, in January 2009 three members of the assessment team, supported by an FCI staff member undertook a site visit to Killybegs in
1 Further information on the contents of the MSC principles and criteria are contained in Appendix 1. Food Certification International Public Comment Draft Report 1
IPSG Western mackerel pelagic trawl fishery
County Donegal, Ireland. This enabled a scheduled programme of consultations to take place with key stakeholders in the fishery – including skippers, scientists, fishery protection officers, NGOs, fishery managers and technical support staff. A complete list of those stakeholders interviewed in the fishery can be found in Section 6.4 of this report. The scoring of the fishery against the MSC principles and criteria took place at the conclusion of these consultations, whist the assessment team were still in Killybegs. Undertaking the scoring exercise ‘on-site’ has several significant advantages - including enabling any gaps in information, identified during the scoring process, to be efficiently addressed.
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2. The fishery 2.1 The unit of certification Prior to providing a description of the fishery it is important to be clear about the precise extent of certification. The MSC Guidelines to Certifiers specify that the unit of certification is “The fishery or fish stock (biologically distinct unit) combined with the fishing method / gear and practice (= vessel(s) pursuing the fish of that stock) and management framework ”. This clear definition is useful for both clients and assessors to categorically state what is included, and what is not. This is also crucial for any repeat assessment visits, or if any additional vessels are wishing to join the certificate at a later date. The unit of certification for the fishery under consideration is as set out below: The fishery assessed for MSC certification is defined as: Species: Mackerel ( Scomber scombrus ) Linnaeus 1758 Stock: Northeast Atlantic mackerel 2 Geographical area: EU Waters: in ICES sub-areas VI, VII and VIII and Division Vb, and International waters in sub-areas XII and XIV and Division IIa. Harvest method: Irish mid-water pelagic trawl undertaken by dedicated pelagic Refrigerated Sea Water (RSW) vessels. This includes single and pair pelagic trawl, but not purse seine. Management System: The stock is managed according the EU – Norway agreement. Within the EU EEZ, management is undertaken by EU member states – in this instance, Irish management is undertaken by the Department of Agriculture Fisheries and Food (DAFF) and the Sea Fisheries Protection Agency (SFPA). Management is informed by ICES advice, supported nationally by the Irish Marine Institute. In international waters management is undertaken by NEAFC. Local systems: The members of the IPSG have signed up to and implemented an on-board ‘Environmental Management System’, developed in association with BIM 3. It is intended that this will shortly be accredited to a certifiable standard 4. It is assumed that all vessels are compliant with all aspects of this, and a requirement of certification. 2.2 The Irish Pelagic Sustainability Group The client for this certification is the Irish Pelagic Sustainability Group (IPSG). Membership includes 22 large RSW pelagic vessels which landed 38,000 tonnes of mackerel in 2008, the two main pelagic Producer Organisations (the Killybegs Fisherman’s Organisation (KFO) and the Irish Fish Producers’ Organisation (IFPO)) and all the main pelagic processors and traders.
2 Although the fishery under certification is referred to as ‘Western Mackerel’, for management and assessment purposes it is the whole stock of North East Atlantic Mackerel that is relevant. For further explanation of the stock components, see section 2.4 of this report. 3 A State agency with primary responsibility for developing the seafish and aquaculture industries in Ireland. 4 BIM pers. Comms. Food Certification International Public Comment Draft Report 3
IPSG Western mackerel pelagic trawl fishery
The IPSG was established specifically to oversee the certification of its member’s pelagic fisheries as sustainable to the Marine Stewardship Council (MSC) standard. IPSG was established in 2008 and all vessels that are covered by this assessment are members of the IPSG and are required to conform with its guidelines and its Quality, Environmental and Sustainability Policies, the aims and objectives of which are: • To comply with all relevant laws, regulations and standards. • To co-operate with all industry stakeholders and regulatory authorities. • To produce safe, high quality seafood, and improve its marketability to maximise the financial return of the natural capital harvested. • To operate in a responsible manner with due regard to the marine eco-system, to maximise the value of the natural capital harvested and monitor environmental performance. • To minimise unintended bycatch and discards through the development of target species fishing procedure. • To minimise the amount of waste produced by fishing by being considerate of supplies and materials purchased. • To adopt and develop best practice to maintain the vessel and equipment fit for the purpose of catching, handling and storing seafood in an environmentally sound manner. • To use the latest machinery and modern technology to improve fuel efficiency. • To minimise the environmental impact from the vessel or shore based equipment / vehicles by ensuring that they all are operating efficiently, and that the risk of pollution from accidental spills is minimised in order to protect the environment, port facilities and fishery products. • To reduce unnecessary consumption of energy and water resources and dispose of all unavoidable waste generated though fishing operations in an environmentally sound manner. • To increase awareness and protection of wildlife, habitats, and ecosystems and act as stewards of the marine environment, by assisting in the clean up of litter generated by others. • To participate with the local community, industry organisations and government to the further development of environmental policies and management to generate a positive public image for our business and the seafood industry. • To contribute to the scientific understanding of the biological and ecological characteristics of the main fisheries and habitats that are affected by commercial fishing. • To support research into new technology and slippage survival rates. • To report and review the vessels performance regularly.
2.3 Fishing Fleet & Fishing Method The Irish pelagic fleet is made up of modern RSW pelagic trawlers. The majority of these trawlers are members of the KFO, with a smaller amount being members of the IFPO. In total there are 22 RSW registered vessels, with a combined present Gross registered Tonnage (GRT) of 21,810 tonnes – at an average of just less than 1,000 tonnes per vessel (although the largest vessel is just less than 2,000 tonnes). The current Irish RSW fleet covered by this assessment is illustrated below:
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Table 1: List of IPSG member vessels: Name Code Owner LOA GT Power PO AINE SO734 Aine Fishing Co Limited 43.25 798 1103 KFO ANTARCTIC D97 Antarctic Fishing Co Limited 50.7 1094 2500 KFO ATLANTIC CHALLENGE D 642 Killybegs Fishing Enterprises Ltd 59 1783 2940 KFO BRENDELEN SO709 Brendelen Limited 64.6 1499 2710 KFO CARMAROSE SO555 Carmarose Trawling Company Ltd 27 256 670.6 KFO COLMCILLE G 186 Colmcille Fishing Limited 27.05 256 708.79 KFO FATHER MCKEE SO708 Cavankee Fishing Co Limited 64.6 1499 2710 KFO FELUCCA SO108 Polar Fish Limited 58 1093 2710 KFO GIRL STEPHANIE G 190 Padraic Conneely 45 663 700 KFO Larry Murphy, Ryan Murphy, Wayne MENHADEN S 135 41.3 644 895 KFO Murphy (Decd) Legal Personal Reps NEPTUNE SO715 Eileen Oglesby 48.6 798 1070 KFO OLGARRY SO591 Noel Mc Ging 35.42 624 634 KFO PACELLI D 383 Mullglen Limited 40.4 624 708 KFO PAULA D 165 Doyle Fishing Company Limited 59.2 1302 3460 KFO SEA SPRAY S 89 Cloughlin Fisheries Limited 43.2 611 522 IFPO SHEANNE SO716 O Shea Fishing Company 61.6 1588 2238 KFO VERONICA D95 Atlantic Dawn Company 57.8 1630 1567 KFO VIGILANT SO109 Ocean Trawlers Limited 53.06 1093 1007 KFO WESTERN CHIEFTAIN SO237 Premier Trawlers Limited 45 663 1082 IFPO WESTERN ENDEAVOUR D 653 Western Seaboard Fishing Co. Ltd. 71 1988 2984.4 KFO WESTERN VIKING SO718 Frank Doherty 51 834 1544 IFPO WESTWARD ISLE G 185 Thomas Flaherty 41.1 470 700 KFO Source: Department of Agriculture, Fisheries and Food. The RSW pelagic vessels are technologically advanced with on-going investment in state of the art electronic equipment such as sonar, net and catch monitors, which have greatly improved the precision of this method of fishing. Pelagic trawls are towed at the appropriate level in the water column to intercept target shoals, with gear depth being controlled by altering towing speed and/or warp length. As a result, there is no impact on bottom habitats or structures. Figure 1: Typical Irish RSW pelagic vessel and diagram of trawl gear
The mid-water trawl used by the Irish fleet is designed and rigged to fish in mid-water, including in the surface water. The large net consists of a cone shaped body, ending in a cod end with lateral wings extending forward from the opening. The horizontal opening is maintained by mid-water otter boards (or in the case of pair trawling by two vessels operating a net’s width apart 5) whilst the vertical opening is maintained by a weighted ground line and floats on the headline – although these are not always required – depending on the way the net is rigged. Some single vessels may also use kites to maintain headline height and net gape. The wings of
5 There are currently 7 pairs operating within the member vessels. Food Certification International Public Comment Draft Report 5
IPSG Western mackerel pelagic trawl fishery the net start at 25.6 meters and taper down to 120mm full mesh. The codend is 50mm full mesh. Towing speed is typically 4 to 4.5 knots when targeting mackerel. Some skippers have been working closely with local net manufacturers and gear technologists at Bord Iascaigh Mhara (BIM) to integrate flexible grids into nets to provide an improved escape route for undersize mackerel. This research and development work is on-going and not sufficiently proven to warrant a requirement across the fleet, however if demonstrated to be effective it is likely that skippers will increasingly adopt this system. 2.4 Target species The target species for the fishery under certification is mackerel ( Scomber scombrus ). As indicated initially, this report does not intend to provide a scientifically comprehensive description of the species. Interested readers should refer to sources that have been useful in compiling the following summary description of the species. These include: • Fishbase: http://www.fishbase.org/Summary/SpeciesSummary.php?id=118 • ICES Fishmap: http://www.ices.dk/marineworld/fishmap/ices/default.asp?id=Mackerel http://www.ices.dk/marineworld/fishmap/ices/pdf/mackerel.pdf • Descriptions provided by national scientific bodies, such as: o Scottish FRS: http://www.frs-scotland.gov.uk/Delivery/standalone.aspx?contentid=765 o UK CEFAS: http://www.cefas.co.uk/media/31692/neamackerel.pdf Geographic Range North East Atlantic mackerel is widely distributed in the whole ICES area and are found in heavy concentrations over the North East Atlantic continental shelf; and in the shallow seas to the west of Europe. ICES currently uses the term North East Atlantic Mackerel to define the mackerel present in the area extending from ICES Division IXa in the south to Division IIa in the north, including mackerel in the North Sea and Division IIIa. Figure x: ICES chart and chart of Global Distribution of Scomber scombrus
Source: ICES and Lockwood 88 The stock is historically divided into three components; the North Sea component, the Western component and the southern component. It should be noted that considerable uncertainty surrounds the definitions of the spawning components, which are primarily defined by fish Food Certification International Public Comment Draft Report 6
IPSG Western mackerel pelagic trawl fishery aggregations in the separate areas identified by egg survey. There is no evidence of genetic separation, implying that these separate components are not isolated and there is enough migration between them for their population genetics to be the same. As it is not currently possible to allocate catches from the 3 components separately, they are at present, for practical reasons, considered together as the North East Atlantic Mackerel Stock. Catches cannot be allocated specifically to spawning area components on biological grounds, but by convention the catches from the southern and western components are separated according to the area in which they are taken. Northeast Atlantic Mackerel Distributed and fished in ICES Sub-areas and Divisions IIa, IIIa, IV, Vb, VI, VII, VIII, and IXa. Spawning component Western Southern North Sea Spawning Areas VI, VII, VIIIa,b,d,e VIIIc, IXa IV, IIIa
The North Sea component has been at an extremely low level since the early 1970s, although ICES regards the North Sea component as still existing – a fact confirmed by triennial egg surveys which regularly locate spawning clearly confined to the old central North Sea spawning grounds. As well as the North Sea, this component also spawns in the Skagerrak. Strong management measures are in place to protect the North Sea spawning component. These include total closures of IIIa, IV b & c and seasonal closures of IVa, supported by a minimum landing size. Because of an extensive feeding migration of the western and southern spawning components into Division IVa, a fishery is allowed from 1 st August until 14 th February despite the fact that the North Sea spawning component may be caught at the same time. Division IVa is closed to a directed mackerel fishery as soon as the western and southern spawning components have left Division IVa. Due to the timing of migrations of the two components and the very limited presence of the North Sea component in Division IVa during the season when fishing is currently allowed, the expectation is that the impact of the directed fishery on the North Sea component will be low. The FCI assessment team supports the management actions taken to protect this component and, more importantly, the process being applied to review ways to bring about recovery of this component. As long as the IPSG fleet abide by the controls to minimise the catch from the North Sea component, this is consistent with principle 1. Based on the above description it can be concluded that the Irish Pelagic fleet is catching predominantly mackerel from the western component (hence the use of the term Western in the title of the fishery assessment), however for the purposes of this assessment scoring is based on the whole North East Atlantic stock – the scale at which the fishery is managed. Lifecycle The basic annual migration of adult mackerel is from overwintering ground to spawning area, from spawning area to feeding ground and then back to overwintering ground. The western mackerel component is found near to the continental slope, over a vast area. These fish spawn between March and July, mainly to the south and west of the British Isles. When spawning is finished, most of the spent fish move to the feeding grounds in the northern North Sea and the Norwegian Sea where they mix with the other components. Some western mackerel, predominantly small individuals, also enter the North Sea through the English
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Channel. The western stock mackerel travel long distances between the feeding grounds and the spawning areas. Over the past 20 years, the pattern of the southerly migration and location of over-wintering grounds of the western component has changed dramatically in both timing and route. In the 1970s and 1980s this movement occurred in late summer and autumn with the fish passing through the relatively shallow waters of the Minch. Recently the migration has gradually occurred later in the year and is further offshore. The pattern of the return migration, after spawning, has remained relatively constant. The boundaries of the spawning areas have also slowly changed, with an increase in spawning activity in the north of the area and to the west of the shelf edge. Juvenile mackerel do not follow the migration routes of the adult fish, instead staying closer inshore. At one year old, only a small proportion of females are mature and able to spawn, while more than half can spawn at two years old. By the time they reach three years old, most mackerel are mature. Female mackerel shed their eggs in about 20 separate batches over the course of a spawning season, in spite of that they are, after considerable research, considered to be determinate spawners 6. An average-sized fish produces around 250,000 eggs. Juvenile mackerel grow quickly and can reach 22 cm after one year and 30 cm after two years. As soon as the juveniles mature they migrate to the spawning grounds and start to follow the extensive migration routes of the adults. Diet The diet of mackerel can vary with the area and the season. By weight, almost half of the food consists of crustacea (shrimps). The remainder is made up of juvenile fish such as sandeel, herring and Norway pout. Myctophids can also form an important part of the diet of mackerel, and a rich source of oil, these are found around and over the continental shelf edge. 2.5 Catches and landings At the October 2008 meeting at the NEAFC offices in London the coastal states decided that the international Total Allowable Catch for mackerel for 2009 should be set at 605,000 tonnes – representing an increase of almost 33% on the previous years TAC. After applying the EU relative stability key, the EU fleet receives some 60% of the TAC, with the Irish quota for 2009 was set at 62,000 tonnes – or some 10% of the overall TAC. Due to evidence of some Irish pelagic vessels contributing to landings of illegal, unreported mackerel into Scottish ports over the period 2000 to 2005, agreement has been reached between the Irish government and the European Commission for the “repayment” of over-quota fish from the national annual quota allocation, spread over a period of six years, running from January 2006.
6 A determinate spawner is one in which the actual number of eggs to be produced during a season can be determined at a pre-defined stage during the oocyte maturation process in the ovary. It follows that after that stage no more oocytes become sufficiently mature (vittellogenic) to be released and fertilised during that spawning season .Generally the oocytes remaining in the ovary after spawning become atretic and are resorbed. Food Certification International Public Comment Draft Report 8
IPSG Western mackerel pelagic trawl fishery
Fig 2 (a) Distribution of International NEA mackerel landings (2006), (b) trend in Irish NEA mackerel landings (1980 – 2006).
140,000 120,000
100,000 80,000 60,000 40,000
Annual Landings Annual (t) 20,000 0 Other Spain Faroe Ireland France Islands Norway United Kingdom Denmark Germany Russian Federation Netherlands
140,000
120,000
100,000
80,000
60,000
40,000 Annual Landings Annual (t) Landings
20,000
0 1980 1982 1984 1986 1988 1990 1992 1994 1996 1998 2000 2002 2004 2006
Source: FAO Fishstat Plus 2006
The Irish fleet has the third largest share of the overall TAC agreed by the coastal states, after Norway and the UK (almost exclusively Scottish RSW vessels – recently MSC certified). Landings of NEA mackerel by the Irish pelagic fleet have generally been on a fluctuating, but downward trend for the last 25 years – in the main this has been as a result of TAC reductions, informed by scientific advice. The Irish RSW fleet lands mainly into Killybegs in County Donegal, Ireland. However, depending on factors such as the proximity of the fishing and market price, vessels may also land into Scotland (typically Lerwick, Peterhead or Fraserbugh) and Norway. Similarly tight landing controls as those described for Irish ports later in this report (5.3 & 5.4), apply in both Scottish and Norwegian ports. Additionally there is close cooperation between the Irish SFPA and their counterparts in both Scotland and Norway, to ensure coordinated monitoring, control and enforcement across the fishery. In all cases there is a high degree of confidence (on the part of the respective national inspection authorities) that the characteristics of the monitoring systems which, in the past, enabled the landing of unreported fish have been sufficiently overhauled and strengthened to prevent further substantial illegal landings .
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3. Target stock status & harvest controls (P1) The Principle 1 of the Marine Stewardship Council standard states that: A fishery must be conducted in a manner that does not lead to over fishing or depletion of the exploited populations and, for those populations that are depleted, the fishery must be conducted in a manner that demonstrably leads to their recovery. Principle 1 covers all fishing activity on the entire North East Atlantic stock - not just the fishery undergoing certification (or the Western Component). However, the fishery under certification would be expected to meet all management requirements, such as providing appropriate data and complying with controls, therefore demonstrably not adding to problems even if the problems will not cause the certification to fail. In the following section the key factors which are relevant to Principle 1 are outlined. The primary sources of information on this section are: • ICES Working Group on the Assessment of Mackerel, Horse Mackerel, Sardine and Anchovy (WGMHSA, 2007) • Report of the Working Group of Widely distributed Species (WGWIDE 2008) • ICES Advice 2008 in Book 9 on Northeast Atlantic Mackerel (combined Southern, Western, and North Sea spawning components) (ICES 2008a). 3.1 Status of the Stock It is likely that the stock is above the point at which recruitment would be impaired. The stock is close to but within the de facto biomass target region. Fishing mortality is now at its limit, after a considerable period of what appears to have been unsustainable fishing, based on the reference points. The spawning stock biomass (SSB) in 2008 was estimated to be 2.84 million tonnes, well above the precautionary reference point (B pa = 2.3 million tonnes). This is a marked increase on the 2007 estimate, partly caused by an upward revision (of +12%) of the 2007 egg survey estimate, and by the inclusion of the most recent catch year. The upward revision of the 2007 egg survey estimate was because the provisional estimate was made before all the relevant data had been fully analysed and verified. The SSB is thought to have risen from a low of 1.8 million tonnes in 2002 despite a relatively high fishing mortality due to the arrival of a large 2002 year class. ICES management advice classifies the stock as at “Full reproductive capacity”. Estimated fishing mortality (F) appears to have been 0.25 year -1 in 2007, which includes discards and landings exceeding the TAC. This is well below the new limit reference point. (F=F lim = 0.42), but above the target region (0.15-0.2) and a little higher than the precautionary level (F pa = 0.23). ICES management advice classifies the stock as being at “increased risk” and “overfished”. Over the last 15 years the indications are that the total adult fishing mortality has been over 0.3 year -1 on average and is thought to have declined with reduced catches in 2005 and 2006. The fact that fishing mortality has been so high for a number of years, and management has been slow to reduce it, makes the harvest rate of great concern for this fishery. The current fishing mortality is within the decision rule limit. If improvements in enforcement seen of the last few years continue or are extended, true catches of NE Atlantic mackerel are Food Certification International Public Comment Draft Report 10
IPSG Western mackerel pelagic trawl fishery expected to decline. There is a reasonable probability that this will result in an increase in stock size in the future, and some increase has already been observed. It should be noted that although the stock has become more abundant, this is at least partly due to a strong 2002 year class. It is likely that the stock will fluctuate and that the industry will have to withstand periods of reduced TAC where recruitment is low or there is a revision in the stock status due to statistical errors. Therefore, while current status is important, the medium and long term management (PI 2.2) is still important in meeting Principle 1. The best estimates of biomass from the stock assessment indicate that the stock is increasing in size. However, there has been very little change in the abundance index over the period that it has been collected. It is not clear whether changes in the index are random error or real changes in abundance. In either case, the index indicates that the stock is in no immediate danger, and that recruitment has not been impaired by recent changes in the spawning stock size. 3.2 Reference Points The biomass and fishing mortality reference points are derived from different sources. The biomass reference points are based on the lowest biomass in the time series during which no reduced recruitment was observed, whereas the fishing mortality is more theoretical, based on life history parameters and past stock assessments (Table 2). The working group considers the fishing mortality reference points more reliable. ICES considers the EU-Norway agreement, which forms the basis for defining the reference points (see performance indicator 1.2.2), to be consistent with the precautionary approach, if fishing mortality on average is kept below F pa . The rationale for ICES proposing F pa = 0.23 is to have a high probability of avoiding overexploiting the stock to a point where the stock recruitment is put at risk. However, projections indicate that F = 0.17 will optimize long-term yield (F0.1).
The biomass reference point (B pa ) represents a lower bound for the biomass, with management tasked with maintaining biomass above this point. Essentially this makes the biomass a trigger point, when fishing mortality should be reduced below the target level to increase the stock size. In practice, biomass has tended to be kept close to this level in recent years. The fishing mortality reference points consist of a target reference point (and a target range) and a limit reference point. These reference points are at least partly based on perceived risk, which the fishing above the limit point considered to place the stock at an unacceptable risk, whereas the target reference point represents a safe level of exploitation. For this type of fishery, best practice is to have limits and targets for both biomass and fishing mortality. Reference points should be reasonably consistent in that on average the target fishing mortality should result in the biomass target, and sustained fishing mortality at or above the limit should produce biomass below the limit point. The reference points previously defined for this fishery (1999-2007), were not entirely compatible, which led to a revision in 2008. The new reference points include a limit reference point for biomass and allow for an upward revision of the target fishing mortality in line with what the stock is likely to sustain. An evaluation of reference points was carried out (WGWIDE 2008) using the time series of SSB and recruitment 1972 – 2003 from the 2007 benchmark assessment (WGMHSA 2007). Investigations showed that there was no indication of reduced recruitment at biomasses above the lowest observed biomass of B loss =1.67Mt. supporting B lim taking the value of B loss . An F lim Food Certification International Public Comment Draft Report 11
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was proposed which was consistent with this B lim value. A precautionary fishing mortality was estimated based on Floss, the estimation error and a standard ICES procedure. It was concluded that Bpa could not be revised based on the available information, and it was clearly indicated that it is not good target reference point. Lower catches consistent with the target reference point and the decision rule may produce better data to reassess this issue at a later data. Table 2 Reference points used for the stock assessment (ICES, 2008a). The fishing mortality reference points are consistent with per-recruit reference points. The basis for Bl oss is the history of estimated biomass. Floss is estimated as the fishing mortality above which the stock would be expected to decline to an equilibrium spawning stock below the lowest observed value (i.e. B loss ). Type Value Technical Basis
Precautionary Blim 1.67 million t Blim =B loss , the biomass above which reduced Approach recruitment has not been observed. Bpa 2.3 million t Trigger reference point used in the current management agreed between Norway, Faroe Islands, and the EU in 1999. Flim 0.42 Flim =F loss , the fishing mortality estimated to lead to potential stock collapse. Fpa 0.23 Basis for setting the TAC so that there is only a small chance of exceeding F lim (F lim * 0.55 (CV 36%)) Target Fy Between 0.15 to 0.20 By > 2.3 million t
3.3 Rebuilding Status A rebuilding strategy is no longer required. Previously the stock was estimated as below the Bpa , and therefore required rebuilding. This has been achieved through a combination of factors, including probable improved enforcement resulting in lower catches and recent good year classes. As the stock is above its precautionary level, this performance indicator is not scored. 3.4 Harvest Strategy There is an appropriate mechanism to contain harvest and allow stock recovery. This is primarily the TAC which is adjusted each year in response to scientific advice to maintain the stock size at a precautionary level. There is evidence that this mechanism, properly implemented, can control stock size. However, there is considerable uncertainty over the impact of unrecorded mortality (mainly discarding as slippage). While this is controlled indirectly through setting the total allowable catch (TAC), the lack of direct control makes the mechanism less robust. In addition to this, Iceland has recently reported an increase in its catches in international waters. Iceland is not part of the TAC allocation and negotiations are on-going as to how to resolve resource allocation. Iceland catches are included in the stock assessment. A TAC is set each year under the EU-Norway agreement and applied to the landed catch. Parts of the quotas can be bought and sold, but the overall TAC is set annually. Landings have exceeded the TAC in some years, but generally control is considered to have improved and the TAC has been able to reduce landings in recent years. Scientific advice is provided each year in the form of a recommended TAC based upon alternative fishing mortality reference points and a stock assessment. The stock assessment
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IPSG Western mackerel pelagic trawl fishery uses total catch, catch composition samples and an abundance index to estimate current biomass and the exploitation rate. In 2008, the EU, Norway and Faroe Islands agreed a new harvest control rule (NEAFC, 2008, Annex II; see PI 1.2.2), which provides more complete guidance on setting the TAC and improves on the previous rule. Management aims for a fishing mortality of 0.20 to 0.22 year -1. The fishing mortality realised since 1998 has been in the range of 0.26 to 0.45, and continues to be higher than desirable due to unexpected catches, although fishing has been brought largely under control. Despite this poor record, biomass has recently increased after the reductions in reported catches in 2003 onwards (Table 3). The decision-makers have, in the past, tended to set a TAC which was not considered precautionary. It was set on the upper boundary (F=0.20) of the target range in 2006, although this follows a long period of fishing mortalities exceeding the target range. The recommendation also does not take account of the potential overshoot of the TAC or unrecorded mortality (Table 3). The TAC seems to have been consistently exceeded by the official landings since 2003-2005, although by only a small amount. Fishing mortality has been reducing following the trend in the advice. The mackerel fishery has a poor history of catches exceeding scientific advice. The estimates of catches by ICES have exceeded the annual TACs in most years and there are strong indications of substantial further underreporting of catches for this stock. Analyses carried out by ICES suggest an underestimation of catch by 60% or more over a period of at least 14 years up to 2001 compared to the ACFM catches. In some countries measures have been taken to improve the situation. However, unreported catches are still a major source of uncertainty affecting the reliability of the assessment, in particular the estimates of biomass. Although there is considerable doubt of the stock size in absolute terms, the current data are thought to capture trends in the stock and the estimated fishing mortalities. There is effectively no control over slippage and the mortality this might cause is significant. Slippage is not recorded routinely across all fleets. While the working group uses catches which attempt to take some account of discarding and slippage, and hence the TAC also attempts to account for these, mortality due to slippage is considered a significant source of uncertainty in the process and has probably adversely affected the past scientific advice. There is no evidence that this is taken into account in setting or adjusting the TAC control or the reference points. Stock projections are regularly conducted under the harvest control rule to check its performance under uncertainty. The projections fall well short of management strategy evaluation as there is no attempt to apply the harvest control rule as it is actually implemented, but it is applied as though catches are kept to the exact rule, For example, a TAC overshoot or the unrecorded mortality due to slippage introduces additional uncertainty which the current harvest strategy may or may not be robust to. While adequate management tools (primarily the TAC) exist to implement decisions appropriate to the fishery, their effectiveness has generally been poor, although evidence exists they are improving. The management tools being implemented are consistent with attaining reference levels, but harvest control has clearly not been fully effective and appears not to have fully taken account of risks. The management plan does not specify measures that would apply under poor stock conditions. Furthermore, the management plan assumes that catch information is unbiased so
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IPSG Western mackerel pelagic trawl fishery that absolute estimates of SSB can be produced. This condition has not been met for a number of years (ICES 2008a). Currently, the stock appears to be subject to increased variability in recruitment and, should this continue, the stock trajectory may be more variable in the future. Fishing capacity is particularly high in the pelagic fleet and a cause for concern (Strategy Review Group 2006). Beyond looking for an industry led approach, there is no management strategy to adjust fishing capacity to levels commensurate with the size of the available TAC. However, the well enforced TAC in the Irish fleet makes this issue more appropriate for considering under PI 3.1.4. It is believed that the level of underreporting due to undeclared landings has been significantly reduced, although slipping, the level of discards and high grading remain issues to be addressed in the mackerel fishery. These practices constitute a considerable waste of resources, so the common objective is to minimise such practices and eventually ban discards through effective regulation (NEAFC 2008). The EU, Norway and Faroes Delegations have agreed to recommend that methods are developed to minimise slipping and high grading in the mackerel fisheries, as well as technical measures to eradicate discards. This potentially includes developing a proposal for a prohibition on carrying equipment on vessels which might permit discarding mackerel, which might include specifying water separators, pipes, conveyor belts, pumps and chutes (water drainage system) and other installations. Table 3 Catch data for combined area including the Western, Southern and North Sea components (ICES 2008a). Weights are in thousands of tonnes. Since 2000 the TAC has been set in line with the scientific advice. The ACFM catch is the total landings and discards from divisions IIa, IIIa, IV, Vb, VI, VII, VIII, and IXa and generally exceeds the official landings and the scientific advice. The actual estimated F achieved is also provided for comparison. Year ICES Advice Predicted Catch Total Official ACFM Estimated Corresp. To Agreed Landings catch F Advice TAC 2000 F=0.17: Fpa 642 612 655 738 0.296 2001 F=0.17: Fpa 665 670 660 737 0.348 2002 F=0.17: Fpa 694 683 685 773 0.392 2003 F=0.17: Fpa 542 583 600 670 0.438 2004 F=0.17: Fpa 545 532 587 650 0.416 2005 F=0.15 - 0.20 [320-420] 422 447 543 0.358 2006 F=0.15 - 0.20 [373-487] 444 318 473 0.256 2007 F=0.15 - 0.20 [390-509] 502 558 579 0.208 2008 F=0.15 - 0.20 [349-456] 458 0.248 2009 F=0.15 - 0.20 [443–578]
3.5 Harvest Control Rule and Tools The current decision rules are set out in the EU-Norway-Faroes agreement for 2008, indicating target and precautionary values for biomass and fishing mortality (NEAFC 2008; Annex II). ICES development of these decision rules is well documented, suggesting that they are robust (ICES 2007b; ICES 2008a).
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The rule provides an optimised strategy in simulations (ICES 2007b). Importantly, it is consistent with the precautionary approach, but should yield over the long term approximately 630 000 t per year. The rule should be applied from 2009 onwards, allowing an evaluation of the practical performance of this new rule. The full text of the rule is set out in the box below:
ANNEX II: ARRANGEMEN T ON LONG -TERM MANAGE MENT OF THE MACKEREL STOCK (NEAFC 2008) The Parties agreed to implement a long-term management plan for the mackerel stock in the North-East Atlantic for 2010 and subsequent years, which is consistent with a precautionary approach and designed to provide for sustainable fisheries and a greater potential yield. The long-term management plan shall consist of the following elements: 1. For the purpose of this long-term management plan, “SSB” means the estimate according to ICES of the spawning stock biomass at spawning time in the year in which the TAC applies, taking account of the expected catch. 2. When the SSB is above 2,200,000 tonnes, the TAC shall be fixed according to the expected landings, as advised by ICES, on fishing the stock consistent with a fishing mortality rate in the range of 0.20 to 0.22 for appropriate age groups as defined by ICES. 3. When the SSB is lower than 2,200,000 tonnes, the TAC shall be fixed according to the expected landings, as advised by ICES, on fishing the stock at a fishing mortality rate determined by the following: Fishing mortality F = 0.22 * SSB/2,200,000 4. Notwithstanding paragraph 2, the TAC shall not be changed by more than 20% from one year to the next, including from 2009 to 2010. 5. In the event that the ICES estimate of SSB is less than 1,670,000 tonnes, the Parties shall decide on a TAC which is less than that arising from the application of paragraphs 2 to 4. 6. The Parties may decide on a TAC that is lower than that determined by paragraphs 2 to 4. 7. The Parties shall, as appropriate, review and revise these management measures and strategies on the basis of any new advice provided by ICES. 3.6 Information and Monitoring This performance indicator is assessed in relation to the adequacy of the information for the stock assessment. While this assessment will need the component of the fishery being certified to meet the recommended scientific monitoring, there are no special requirements. This certification applies to ICES Divisions IV, V, VI & VII where the western component of the S. scombrus species is caught. There is little risk of misidentification with other mackerel species, the most likely problem being confusing catches from spawning components, primarily the North Sea and western components. Although the Western component is well identified, catches cannot be distinguished between the North Sea and Western components and they mix when not spawning. There is a seasonal closure in place to minimise the take of the North Sea mackerel stock. The geographical range of NE Atlantic stock is well known as are the seasonal patterns of movement and availability. There is sufficient information to be able to clearly differentiate between three spawning components. The distribution of the biomass is monitored within certain regions each year using acoustic surveys, and every three years throughout the stock range using the egg survey. Tagging data is used as an indicator for the mixing of the Southern and Western components. The life history is clearly documented and well understood from eggs to spawning (ICES 2007c; WGFE, 2007). The species is relatively migratory, and conduct sustained movement over long periods. Natural mortality is treated as a fixed parameter over years and ages (M=0.15 year-1) and is based on results from the analysis of tagging data. Research has been conducted into the physical and biological factors affecting distribution, survival and recruitment. No obvious environmental signals have yet been identified that should be considered in assessment or management in the area west of the British Isles. However, Food Certification International Public Comment Draft Report 15
IPSG Western mackerel pelagic trawl fishery there have been recent changes in the distribution of mackerel, with decreased abundance in the south and increasing numbers of mackerel to the north and the west and in the Skagerrak and Kattegat, probably due to the effects of climate and ecosystem changing habitat suitability (WGFE, 2007; Reid et al ., 2006). These changes may have an impact on both fisheries and stock dynamics. The major trends in the NE Atlantic ecosystem are the steady warming of the area (WGRED 2008). The Rockall trough waters have been warming steadily for some years and are currently at an all time high. The general and continuing reduction of copepod abundance is also of major concern given the major role of these organisms in the food web. Both these factors are likely to have an impact on the life histories of many species, but particularly on the migratory pelagic species; mackerel, horse mackerel and blue whiting. Both mackerel and horse mackerel migrations are closely associated with the slope current. Specific information is available on fishing methods and gear types of all fleets which is regularly updated. A summary of this information is reported in the working group report each year. Vessel activity and landings are recorded by fleet nationality. Fishing methods and gear types are known throughout the fishery, although a minor component of the fleets from a few countries (France, Sweden, Northern Ireland) lack some details. The stock assessment relies on three main types of data: • Total Catch: Total catches are made up of landings and discards. Landings have been under reported in the past, and the Working Group remains concerned these are under-estimated. Discards in the form of slippage are not routinely reported. • Catch composition data: These are obtained from biological sampling of landings data and provide information on stock structure. The stock assessment requires catches broken down by age. • Abundance index: The primary abundance index is the mackerel egg survey. This is the only abundance index which is stock wide, and therefore the only one used to fit the population model. Total Catch Landings of the fleet being certified are accurately recorded with a new and improved inspection system. Misreporting areas is considered less of a problem with VMS and other measures put in place. The EU-Norway agreement has increased inspection of pelagic landings. Buyers and sellers registration within EU has also increased the control on misreporting. Previous misreporting has resulted in a TAC payback and there is clear evidence of corrections due to misreporting in the stock assessment. However, some area misreporting (particularly misreporting from IVa to VIa), still takes place, which threatens the recovery of the North Sea component. Since 1987 all catches taken in the North Sea (Division IV), Division IIIa and International Waters have been assumed to belong to the Western stock. It has not been possible to calculate the total catch taken from the North Sea stock component separately but it has been assumed to be 10,000 tonnes for a number of years. This is because of the very low stock size and because of the low catches taken from Divisions IVbc. More recently the estimate of the stock size in the North Sea has increased, so that the assumed catch of 10,000 tonnes may be low. The state of the North Sea component may prevent any catches from division IV being certified.
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All EU vessels are subject to VMS if over 15m and if fishing in EU waters – as defined within Common Fisheries Policy. For Norway, vessels with an overall length exceeding 24 meters require VMS. However, the bilateral agreement between Norway and EU has required mutual tracking of vessels above 15 meters from 1 January 2005. The main concern in this fishery is unrecorded mortality from discarding and slippage. In pelagic fisheries discarding occurs in a sporadic way compared to demersal fisheries. This is because pelagic fishing pursues schooling fish, creating hauls with low diversity of species and sizes and consequently often extreme fluctuation in discard rates. Extreme discards occur especially during ´slippage´ events, when the entire catch is released. The main reasons for ´slipping´ are daily or total quota limitations, illegal size and mixture with unmarketable bycatch. Quantifying such discards at a population level is extremely difficult as they vary considerably between years, seasons, species targeted and geographical region (WGQAF, 2008; WKDRP, 2008). The results of a recent analysis (Simmonds 2007) comparing reported landings and discards and fishery independent data (age structure, egg survey and tagging data) show that during the period 1992 to 2004 there was a statistically significant discrepancy between the estimate of biomass based on reported catch and that based on fishery independent data. The estimate of unaccounted mortality lies between 95% intervals of 1.6 and 3.4 times the catch with the most probable estimate being 2.4 times the catch. Discard estimates of pelagic species from pelagic fisheries and demersal fisheries have been published (WGMHSA, 2007). Discard percentages of pelagic species from demersal fisheries were estimated between 3% to 7% of the total catch in weight, while from pelagic fisheries were estimated between 3% to 17%. Detailed information on species composition (including non-commercial species) is available for the Dutch and German freezer trawler fleet. In the Dutch data (Dickey-Collas & van Helmond 2007) the most important commercial species discarded is mackerel, accounting for 39% of total pelagic discards. Discards occur in the mackerel fishery as well as in fisheries targeted at other species, notably horse mackerel and herring fisheries. Information on discards was provided to the working group for some countries, including sampling levels and raised discard estimates. The Netherlands, Germany and Scotland, representing 40% of the landings, provided 2006 discard data on mackerel to the working group and these were used in the stock assessment. For 2006 the total mackerel discards estimated for these fleets were approximately 19156t with discard percentages of the total catch varying between 6 and 20%. However, these data were treated with caution as sampling levels were low and treatment of the data varied from dataset to dataset. Because of the importance of discards on pelagic species assessments, the Working Group has recommended that observers be placed on board vessels in those areas in which discarding occurs, existing observer programmes should be continued and research be conducted on how to use these data. The Irish fishery, subject to this certification, has not provided estimates of discards (slippage). This fishery has no observer programme, although a programme is being initiated and there is a new initiative for voluntary reporting of slippage. Overall, the Working Group considers that the best estimates of catch it can produce are likely to be an underestimate for the following reasons:
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• Estimates of discarding due to high-grading or slipping are not available for most countries, and anecdotal information suggests that slipping may be widespread especially in the Q4 fishery in IVa and the Q1 fishery in VIa. • Confidential information suggests substantial under reported catches for which numerical information is not available for most countries. • Reliance on logbook data from EU countries implies (even with 100% compliance) a precision of 89% from 2004 and 82% previous to this (Council Regulation (EC) No’s 2807/83 & 2287/2003), and that this is likely to be underestimating catches (i.e. negatively biased). Where inspections were not carried out there is a possibility of a 56% under reporting, without there being an obvious illegal record in the logsheets. EU catches represent about 65% of the total estimated NEA mackerel catch. • The precision in the logbook records from countries outside the EU has not been evaluated. The Working Group concludes that the accuracy of landings and estimates of total discards are inadequate. Catch Sampling The age composition, weight-at-age in the catch and population and the maturity-at-age are obtained through the biological sampling. Biological sampling coverage for mackerel continued to increase and now stands at 85%, exceeding the long-term average (82%). This is considered at least adequate. In 2006, 85% of the total catch was covered by national sampling programmes, a small increase on the figure for the previous year (83%). The corresponding sampling intensity has increased significantly with the highest number of samples on record. Denmark, the Faroe Islands, Norway, Portugal, Russia and Spain all sampled 100% of their catch with Germany, Ireland and Scotland achieving rates over 85%. As in previous years, the Netherlands and England & Wales continue to sample smaller fractions (62% and 13% respectively). The remaining countries (of which France, Iceland, Northern Ireland, Sweden and Poland had significant catches) failed to sample any catches. There is inadequate sampling for stock weights during the spawning season. This applies particularly to the North Sea, where insufficient fish were sampled for the 9+ group. There is also uncertainty over the age reading and a call for a reassessment of the different methods by the different institutions involved ageing mackerel samples. Selectivity at age is estimated within the stock assessment. Selectivity is not available by gear type but it is not likely that selectivity would be very different for different gears as they operate in similar fashion (targeting schools located using the same methods). The biological sampling of the catches mean that selectivity can be well estimated by size, sex and maturity, with the exception that selection at final age is not well determined, increasing overall assessment uncertainty. Abundance Index The triennial egg surveys allow detailed monitoring of the distribution and abundance of the spawning stock. This, together with acoustic surveys, provides a fairly detailed map of the stock distribution through the year. In addition, there are on-going ecosystem surveys mapping the large-scale oceanic distribution and quantify the abundance, aggregation and feeding ecology of Northeast Atlantic (NEA) mackerel among others in the Norwegian Sea and surrounding
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IPSG Western mackerel pelagic trawl fishery waters. The working group is also exploring the use of bottom trawl surveys as a recruitment index. This triennial egg survey takes place every three years with the participation of Portugal, Spain, Scotland, Ireland, The Netherlands, Norway and Germany (WGMEGS 2008). This survey was used as the only abundance index in the stock assessment, which together with catch-at-age data is suitable for a catch-at-age model (virtual population analysis). The triennial mackerel egg survey (MEGS) has been used as a relative index in the recent stock assessments although it also gives an absolute estimate of the spawning stock biomass, based on the density of eggs and fecundity of female mackerel. Fecundity data is collected at the same time as the survey. The analyses of the abundance index alone show that the NEA mackerel stock increased by an estimated 504 700 tonnes to a total of 3.25 million tonnes, an 18% increase. However the majority of the increase is associated with the Southern component. The estimate for the western component increased from 2,468,000 tonnes in 2004 to 2,590,000 tonnes in 2007, a 5% increase, which is well within the standard error of the estimate (i.e. the change is not statistically significant). The survey index has been relatively flat since 1992 (Fig. 3), which would suggest that there have been no large scale or sustained changes in abundance over this period. The survey indicates that there has been some recovery in the North Sea spawning component since 1999, it is still small compared to previous indications before expansion of the fishery in the area.
Figure 3 The stock assessment estimate of biomass (Model SSB) and the underlying egg survey estimates for NE Atlantic mackerel rescaled to the biomass estimated in the stock assessment, 1992- 2007 (from WGMHSA, 2007). Although the stock assessment estimate of biomass (Model SSB) shows a recovery 2002-2005, the underlying egg survey estimates are relatively flat and show little change. The apparent recovery in the assessment is based on the reduction in legal landings and a large recruitment (unobservable). Given that the mortality due to illegal landings and slippage is highly uncertain, any recovery arguably has not been proven.
3000000
2500000
2000000
Model SSB 1500000 Egg Survey Estimate SSB (t)
1000000
500000
0 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 Year
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3.7 Stock Assessment The assessment is appropriate for the stock and for the harvest control rule, and is evaluating stock status relative to reference points. The stock assessment model is fitted to appropriate data. The model captures major features appropriate to the biology of the species and nature of the fishery, including fish migration, age, growth and spawning and takes uncertainty into account. The stock assessment is subject to peer review through the working group process and the full working group report is published on the internet. The stock assessment uses Integrated Catch-at-Age Analysis (ICA; Patterson 1995). Like most stock assessment methods, this is a specific piece of software that implements a method which uses standard data available for the fisheries being assessed. It was developed specifically for the typical data available to ICES working groups. The underlying model is the standard age structure population model widely applied in fisheries. The model is fitted to the observed catches-at-age data and abundance indices through estimated catchability patterns. The stock assessment approach is regularly reviewed. The Working Group conducted “benchmark” assessments in 2007, where they considered alternative stock assessment approaches. The catch and survey data were explored using the standard version of ICA, a version of ICA that uses Bayes estimation, and other software: AMCI and ISVPA. The Working Group considered the performance of ICA adequate, so the other models were only used for purposes of data exploration, which led to some changes in the model structure and assumptions. The Working Group also explored the effect of under reported catches on the assessment. Selectivity at age is estimated within the stock assessment, which also produces a time series of recruitment. The causes of low recruitment beyond low SSB, such as temperature, are not well understood, but there is clear evidence for ongoing research into recruitment. Although a stock recruitment relationship has been developed, it has not been used in stock projections. The stock recruitment relationship will probably have little impact on the assessment, but if accepted it will affect the reference points for the spawning stock biomass. It is not clear whether the model is being fitted to real changes in biomass or only to random noise in the survey index. The inter-annual variability, real or perceived, has been missed by the survey because it is conducted only every three years. However, these problems are common in fish stock assessments and are acceptable as long as risks are being considered, as they clearly are in this case. Furthermore, as the data time series is lengthened and assuming problems in the data continue to be reduced, the interpretation can continue to be re- evaluated and corrected. The assessment approach might be improved in terms of separate assessments for the three spawning components, which is not currently possible as catches cannot be separated, and in terms of more robustly coping with unrecorded mortality. Most stock assessment methods, including catch-at-age methods, require accurate catch estimates. However, this last problem is probably best approached through improved mortality data rather than attempting to model this additional error (see performance indicator 1.2.3). Changes in catch reporting can lead to “retrospective bias”, creating a problem with using the time series of data, even if misreporting and slippage become negligible. This was not the immediate cause of the previous retrospective bias which led to a sudden change in advice (Fig. 4). This error was primarily the result of a change in treatment of the survey index, but unrecorded changes in the catches could be the underlying cause for this and other problems in the stock assessment. Food Certification International Public Comment Draft Report 20
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Figure 4 Estimates of the spawning stock biomass (SSB) by year relative to the limit (solid blue line) and precautionary (dotted blue line) for each of the 2001 (shortest line) to 2007 stock assessments (red line). The estimate for the most recent year is always the most uncertain and generally is adjusted as more data become available. The large change in SSB was due a change in the treatment of the survey data in 2004.
The current best estimate of the SSB time series matches fairly closely previous estimates back to 2004 based on shorter time series of data (Fig. 4). However, there was a large change in the 2003-2004 estimate due to a change in the way the abundance index was used, where the treatment of the index changed from absolute to relative abundance. This was a one-off change and should not be repeated, but implies the stock assessment was poor before 2004. Since then the estimates have been relatively stable. Although the current biomass is estimated to be high, future assessments may lead to adjusting this value downwards.
4. Environmental elements (P2) Principle 2 of the Marine Stewardship Council standard states that: Fishing operations should allow for the maintenance of the structure, productivity, function and diversity of the ecosystem (including habitat and associated dependent ecologically related species) on which the fishery depends. The following section of the report highlights some of the key characteristics of the fishery under assessment with regard to its wider impact on the ecosystem. 4.1 Slipping The mackerel fishery is a very clean fishery with limited bycatch. Information obtained from SFPA, POs, and vessel skippers, corroborated by consultations with the Marine Institute, (including their observer programme), indicated that slippage (i.e. opening the net and releasing the fish before they are pumped out of the water) is not a significant issue in the mackerel pelagic trawl fishery. However, there remains an opportunity for slippage – as vessels are keen to only land mackerel, rather than mixed landings of mackerel and other species (such as mixed shoals with horse mackerel). In addition there is a price benefit to landing larger fish, which could be interpreted as an incentive to slip hauls with large numbers of small fish.
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However, all vessels recognise that it is detrimental to everyone’s interests to slip fish – due to the impact of the stock of unnecessary mortality, and the cost in gear wear, fuel and time. As a result a number of systems are in place to minimise slippage. Recently, the Irish pelagic RSW fleet has sought to formalise some of these systems by inclusion in an on-board Environmental Management System, developed in association with BIM. The target species fishing procedure states that all vessels will: • Use electronic equipment to identify target shoals • Monitor communications, and make contact with vessels which may have already tested the mark • Use jigging machines / handlines – these are particularly useful for determining whether there is undersize mackerel in a shoal, however this method is less effective in hours of darkness. • In event of slipping, alert all vessels Continuing investment in sophisticated fishfinding equipment and sonar and the testing of marks by the use of jigging equipment (in some cases automated, but often just handline with feathers) is likely to improve the selectivity of the fishery, by providing skippers with greater knowledge about the size and species composition of shoals before nets are shot. In spite of this there is still not absolute certainty about the composition of a shoal so some slipping does occasionally still occur. As is common with many small pelagic species, shoals of fish tend to be of the same species, often incorporating fish of similar size, and this is a feature that is specifically exploited when these shoals are fished. Skippers search for shoals of fish that are of the species, size and density that they are seeking. Whilst species recognition using sonar is not a perfect science, matters have improved significantly in recent years, and skippers are able to make realistic judgements as to whether shoals contain more than one species, and in roughly what proportions. Although some skippers suggest that there may be some survival of slipped catches, research evidence suggests that actual mortality for slipped fish from pelagic trawls is likely to be substantial (Lockwood et al 1977, Pawson & Lockwood 1980, Holeton et al 1982, Lockwood et al 1983). In this context, scientists assume 100% mortality level when factoring a slippage estimate into assessment models. Slippage is regrettable but not illegal. Vessels are not currently required to record the level of slippage, however, some within the fleet have suggested that recording the level of slippage in order to pass the information onto ICES scientists may help to reduce the level of ‘unaccounted mortality’ in the stock models – which may ultimately be beneficial to the fleet. As slippage does not entail bringing the catch aboard it would not be possible to accurately determine the proportions in terms of species, length / weight and sex. Reasonable estimates, based on information contained in net monitors, could be recorded. 4.2 Discarding Discarding of fish (after it has been brought on-board) is illegal in the mackerel fishery. In this fishery, there is essentially no discarding of fish to sea, as a direct consequence of the design and layout of deck and fish handling equipment and facilities that make this difficult. When fish are pumped onboard from the net, they are fed into a system of sluiceways that allow the water to be separated from the fish, and the fish to be directed to Refrigerated Seawater (RSW)
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Tanks. There is no mechanism for sorting fish on deck, or for discarding fish through chutes or over the side. Whilst it is theoretically still possible to pump fish from the RSW tanks over the side whilst at sea (this is how fish are discharged to shore), there is limited operational or economic logic to such action, and it is said not to occur. The only situation where there might be an economic incentive to discard fish from the RSW tanks is where a mixed haul is brought aboard (unusual) or where fish quality has deteriorated to the point that it is unsaleable. This type of discarding is not illegal, but is strongly discouraged – both as an industry norm and by the IPSG and is not thought to occur. At port fish are pumped directly from the vessels to lorries, or (more typical when landing into other countries, such as Scotland) via a de-waterer and certified scales into the processing plant. 4.3 Habitat The pelagic fishing gear used in the Irish RSW mackerel fishing gear is not designed to come in contact with the sea bed. The net remains within the water column, and would be immediately (and expensively) damaged were it to come in contact with seabed structures. Skippers have good control over the position of the net, and once again the use of technology reduces the likelihood of any interaction. A net monitor (sonar) with a transducer actually on the net enables skippers to accurately fish to within a couple of meters of the seabed without making contact. There is far less danger of gear loss in pelagic fisheries than in demersal. This is partially due to the lack of contact with the seabed, but also because the nets are far lighter. For example, were a demersal trawl net to become entangled in, for instance a wreck, the heavy ground chain would not break. By contrast any pelagic net entangled in such a way would more easily break and be recovered. Interactions with the seabed or gear loss are therefore negligible; however the newly adopted IPSG Enviornmental Management System has introduced a new log for any interaction with the seabed or gear loss. 4.4 Ecosystem impacts There is considerable knowledge of the habitats and ecosystem of the North East Atlantic, drawing on more than one hundred years of regular monitoring and research, the intensity of which has accelerated in recent decades. The food web of the North East Atlantic has been studied over many years and is reasonably well understood, and there is a good level of information on the trophic position of the mackerel’s key life stages within this web. Many studies are available on the community structure in the North East Atlantic and mackerel is a key component of the wider marine ecosystem – both as prey and predator. In managing potential habitat and ecosystem impacts, industry and management authorities are guided by Irish commitment to a number of relevant conventions and agreements, such as: • OSPAR Biological Diversity and Ecosystems Strategy which is concerned with all human activities which can have an adverse effect on the protection and conservation of the ecosystems and the biological diversity of the North East Atlantic. The Strategy (i) sets ecological quality objectives in support of the ecosystem approach to the management of human activities, (ii) requires assessments of species and habitats that are threatened or in decline, (iii) the development of an ecologically coherent network of marine protected areas and (iv) the assessment of human activities which may Food Certification International Public Comment Draft Report 23
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adversely affect ecosystems and the development of programmes and measures to safeguard against such harm. • Council Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora came into force on 21 May 1992. The central aim of the Directive is to conserve biodiversity across the area of the European Union through a coherent network of Special Areas of Conservation (SACs). • The Convention on Biological Diversity was signed at the UN Rio Conference on Environment and Development (1992). This aims conserve biological diversity, encourage sustainable use of its components and the fair and equitable sharing of the benefits arising from the use of these resources. The Pelagic fishing fleet has robust and comprehensive systems in place to minimise any wider ecosystem impacts caused by waste pollution of any kind. The majority of these are legislative requirements in order to comply with MARPOL legislation. For example, all waste oil must be recorded and properly disposed of as a requirement of the licence, and catering waste is recorded and brought ashore. As a result of these systems it is not thought the IPSG mackerel fleet contributes to either marine litter or pollution. More sophisticated assessments of impact such as carbon foot printing are not required as part of the MSC assessment. 4.5 Endangered, threatened and protected species (ETP) In general, interactions between mackerel fisheries and ETP species are considered very limited on the basis of consultations with the Irish Whale and Dolphin Group and on the evidence from skippers and from various observer programmes. Skippers report sighting dolphins (mainly bottlenose – Tursiops truncates – a species listed as data deficient on IUCN Red List) when fishing for mackerel close inshore, but that there was no direct reported interaction. Relevant work has been undertaken in the UK, covering waters to the West of Scotland where the Irish fleet fishes. The Sea Mammal Research Unit (SMRU) at St. Andrews has undertaken extensive surveys to determine the level of bycatch of sea mammals in UK pelagic fisheries. To date no cetacean or seal bycatch has been seen by independent observers in the pelagic mackerel trawl fishery. In general, populations of endangered, threatened and protected (ETP) species are highly studied and well understood in the North Sea, with considerable work undertaken in relation to the regular monitoring of fishing activity through the deployment of onboard scientific observers, capture of anecdotal information, and a wide range of monitoring activity associated with the planning and management.
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5. Administrative context (P3) Principle 3 of the Marine Stewardship Council standard states that: The fishery is subject to an effective management system that respects local, national and international laws and standards and incorporates institutional and operational frameworks that require use of the resource to be responsible and sustainable. In the following section of the report a brief description is made of the key characteristics of the management system in place to ensure the sustainable exploitation of the fishery under assessment. 5.1 Legislation EU Ireland is a Member State of the European Union, and its fisheries are subject to the principles and practices of the Common Fisheries Policy. The North East Atlantic mackerel fishery is managed through the Common Fisheries Policy of the EU in accordance with the basic fisheries regulation (2371/2002). This policy came into being in the form we recognise today in 1983. It was reviewed thoroughly in 2002 and the current basic fisheries regulation (No.2731/2002) was adopted by the Council of Ministers on 20 December 2002. This regulation is a ‘chapeau’ regulation setting out the strategic aims of the CFP and enabling the Council of Ministers, or in certain cases the Commission, to make more detailed Regulations. These include ones dealing with control requirements, fleet structure, technical conservation, marketing and annual total allowable catches (TAC) etc. Outside the CFP framework other EU legislation dealing with habitats and species protection and is also relevant to fisheries management and to fishermen. National Implementation of the CFP at a national level is carried out through the individual Member States. Member States’ fisheries enforcement authorities co-operate in policing the fishery (e.g. satellite monitoring, landing recording etc). National fisheries administrations are responsible for a range of management and regulatory duties, including management of fleet activity, management of national quota, monitoring and control of all fisheries occurring within national jurisdiction, collection, collation and transmitting of key fishery data, and undertaking at least a base range of scientific monitoring and development work. Within EU member states, Fisheries Departments divide the national quota allocations agreed each year in the Council of Ministers in Brussels between their various fleets. In turn, fishers have to report landings to the National Authorities who in turn report aggregate national information to the European Commission. If the stage is reached when the aggregate Total Allowable Catch is near to being taken the Commission will make a Regulation to close the fishery. There are also systems in place to monitor national uptake, and the facility exists to stop the fishery nationally once the quota is taken up. The main legislative instrument of fisheries management in Ireland is the Irish Government’s Sea fisheries and Management Jurisdiction Act (2006). The act establishes, among other things: • Licensing procedures Food Certification International Public Comment Draft Report 25
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• Monitoring, control and surveillance procedures – formed the legal platform the establishment of the Sea Fisheries Protection Agency (which came into force on 1st January 2007) end established the powers to inspect throughout the supply chain. • Penalty procedures • Right of Appeal The Irish Pelagic Sustainability Group Western mackerel fishery is consistent with EU and national legislation as affirmed in national and European fisheries policies and plans, and the monitoring and evaluation of data returns and management performance. 5.2 Roles & Responsibilities There are several relevant organisations and bodies which take an active role in the fishery under assessment. Their roles are explicitly defined and well understood, and the interaction between them works effectively. Industry Representation There are several tiers of industry representation, which form a crucial role in providing the industry with an effective voice in both management and science. They also play an important role in lobbying at both national and EU level for the interests of fishermen. The first and, arguably the most important tier of industry representation is provided by Producer Organisations. In the Irish mackerel fishery all RSW vessels are members of either the Killybegs Fishermans Organisation (KFO) or the Irish Fish Producers’ Organisation (IFPO). Unlike several other EU member states, the Irish POs do not handle quota and allocate among member vessels, nor are they able to administer quota trading or leasing as this is not permitted in Ireland. None the less the POs form a vital conduit for information, communicating new management measures to the fleet and making managers and scientists aware of changes experienced on the fishing grounds. The two Producer Organisations are also members of the Federation of Irish Fishermen (FIF). Members of the KFO and IFPO sit on the Pelagic RAC and attend all of the meetings. A number of fishermen and other stakeholders also attended these meetings. The creation of Regional Advisory Councils (RACs) was one of the pillars of the 2002 reform of the Common Fisheries Policy in response to the EU and stakeholders’ desire to increase the latter’s participation in the CFP process. The RACs are made up of representatives of the fisheries sector and other groups affected by the CFP while scientists are invited to participate in the meetings of the RACs as experts. The Commission and regional and national representatives of Member States may be present at the meetings as observers. The Pelagic RAC has greatly improved effective communication links between industry, managers and scientists. Scientific Advice The core backdrop to the management of this fishery is the advice provided by the ICES Advisory Committee (ACOM) which draws on the on-going work of international scientists from relevant research laboratories and institutions on the stock biology and marine science. The main working group responsible for mackerel advice up to 2007 was the Working Group on the Assessment of Mackerel, Horse Mackerel, Sardine and Anchovy (WGMHSA), which drew on the work of many other working groups on surveys, reference points and N.E. Atlantic ecology. From 2008 the working group responsible for the NEA mackerel stock became WGWIDE (the working group on widely distributed stocks – which also covers species such as horse mackerel, Norwegian Spring Spawning herring and Blue Whiting). Food Certification International Public Comment Draft Report 26
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Scientific research and assessment is carried out by ICES Working Groups. The assessments are reviewed and evaluated by the ICES Advisory Committee (ACOM) which then provides advice on the status of target and non-target stocks to the European Commission. Where relevant (as for mackerel) the advice is considered at a joint meeting between officials of the EU and Norway. ICES advice, via Commission proposals, informs the annual EU Council of Ministers regulation establishing management measures, in particular TACs and quotas. TAC’s and quotas for this fishery are set in this regulation for EC member states and recorded for Norway. Stock assessment and data gathering methodologies are regularly reviewed - at ICES level and at the level of the contributing laboratories and research institutions. Within ICES, a methods working group keeps methods for fish stock assessment under regular review, and there are specific working groups dealing with various issues relevant to the fishery. The most important of these to NEA Mackerel include the “Working Group on Mackerel and Horse Mackerel Egg Surveys (WGMEGS)” which designs collection and processing of the survey data used to fit the population model, and the “Workshop on Limit and Target Reference Points [WKREF]”, which will review appropriate reference points for this stock. The problem of discarding and slippage is informed by the work of the “Working Group on Quantifying all Fishing Mortality (WGQAF)” and “Workshop on Discard Raising Procedures”. A number of working groups are concerned with more strategic long-term issues, such as “Study Group on Working Hypotheses Regarding Effects of Climate Change (SGWRECC)” which is highly relevant to changes in stock distribution. In Ireland, the Marine Institute is the main scientific body working in the area of fisheries science. Their scientists are closely involved in the stock assessment and egg survey work of ICES. A Marine Institute scientist was, until recently, the chair of the ICES mackerel working group. National Management Bodies The Irish Government’s Department of Agriculture Fisheries and Food (DAFF) is the main fisheries management body in Ireland. They represent Irish fisheries interests within the EU and at the coastal states. DAFF is also responsible for dividing quota allocations among the Irish fleet, and monitoring uptake of quota. In addition DAFF provide corporate governance for the Marine Institute, the Sea Fisheries Protection Agency (see below) and BIM (the Irish State agency with responsibility for developing the Irish Sea Fishing and Aquaculture industries, established under the Sea Fisheries Act 1952). 5.3 Monitoring, Control and Surveillance The Irish Sea Fisheries Protection Agency (SFPA) was established on 1 st January 2007 and is responsible for all monitoring, control and surveillance (MCS) within Irish waters, in conjunction with the Irish Naval Service. There is a high degree of enforcement and control and in the Irish mackerel fishery, which has increased recently in response to identification of substantial under-reporting, and which recent changes and improvements in overall monitoring, control and surveillance have been designed to address. National Authorities enforce EC fisheries legislation and report on their activities annually to the Commission. Enforcement includes use of satellite VMS, patrol vessels and aerial surveillance. In relation to TAC, there is a clear system of data collection, testing and clear feedback. There is regular inspection of landings. In the mackerel fishery there are regular inspections at sea, and fleet activity is monitored by aerial surveillance and through a satellite mediated VMS Food Certification International Public Comment Draft Report 27
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(Vessel Monitoring System). Where considered appropriate, more detailed and focused inspections and investigations are undertaken, combining information already collected with direct observation (off-loading and weighing of all catch) and inspection of further documentation. At processing plants, all landings must pass into the plant via weighbridges which have been calibrated, sealed and certified. The fish pass from via a de-waterer and limited tolerance is allowed for water. In Ireland (Killybegs) although much of the landings are transported via lorry to the processing plant (as opposed to direct pumping from ship to plant as is more typical in places like Scotland), the same basic principle of certified weighing of all landings applies. This secure weighing of all mackerel entering processing plants allows inspectors the opportunity to undertake mass-balance exercises (a complete audit of a product from one vessel going into a plant, and product coming out of a plant). This is typically done to each vessel at least once a year, and each plant several times a year. Such activity forms the backbone of the CFP Monitoring Control and Surveillance (MCS) system, and performance of this system against national and CFP targets, including details of infringements and prosecutions, is reported on an annual basis. These activities are coordinated through the new EU Fisheries Control Agency based now based in Vigo, Spain. The machinery of this system (operational procedures) is well developed, is in place, and is applied in a clear and transparent way. The reporting process provides timely information to the Commission. This information allows the Commission to exercise the power vested in it to close the EU fishery immediately all quota allocations have been taken. Non-compliance is dealt with by the relevant national authorities through their criminal justice systems, and using agreed and tested procedures. Much improved levels of compliance suggest that this system is becoming more effective. The already robust MCS procedures in place in Ireland are due to be further reinforced by the addition of quayside CCTV and electronic log books. 5.4 Compliance Compliance in the Irish pelagic fishery has not always been exemplary. Under regulation 147/2007, the European Commission stated that UK and Irish fleets had overfished mackerel stocks to the west and north of Scotland by a combined total of 195,083 tonnes in the period 2001-2004 and the activities of the pelagic fleet and processing sector were the subject of substantial scrutiny. The level of illegal operations now presumed to have occurred forced a substantial revision of MCS procedures across the whole of the EU and led to the introduction of the SFPA in Ireland. As well as VMS, spotter planes and the regular use of inspections at sea, the amount of monitoring of landings at port has also been substantially increased. Vessels are now required to report the amount onboard the vessel 4 hours before landing and 100% of all landings are now inspected, and tanks dipped by SFPA inspectors to verify landing figures. All catch pumped ashore passes over a certified tamper-proof weigh bridge / scale and occasionally (at least once per boat and per factory per year) SFPA will undertake a whole process inspection (effectively a mass-balance audit). At Killybegs lorries are weighed into and out of the port during unloading and fish are weighed on entry to the processing plants, which in Killybegs are a short lorry drive from the quayside. The new EU registration of buyers and sellers legislation, although not directly targeted at the pelagic sector, has also contributed to a major cultural shift within the industry, and there is now a sense of confidence on the part of the SFPA that strong systems, checks and balances are Food Certification International Public Comment Draft Report 28
IPSG Western mackerel pelagic trawl fishery now in place to quickly identify and punish any illegal activity. As a result there is a widespread belief that non-compliance is now no longer a major problem in the Irish pelagic industry. Overall, these measures have resulted in a big improvement in the reliability of the landings data. 5.5 Dispute resolution All member states have signed up to CFP, and are bound by European legislation. Disputes between Member States and the Commission are resolved in the Council of Ministers. Where appropriate, European legislation is enacted at the national level through relevant primary and secondary legislation. Formal procedures apply for the resolution of disputes through the national court systems. Ultimately, any European citizen or organisation can take legal action against the Council of Ministers in the European Court of Justice. This is a system that is widely known and has been used when considered necessary. Within the fisheries administrative structures of each member state there are also a wide range of bodies and committees through which problems can be raised and disputes debated and resolutions found. Local government and relevant planning committees also have a range of tools at their disposal to both inform and resolve relevant disputes. Outside the machinery of government, there are a wide range of institutional solutions to dispute resolution – through trade organisations, professional associations, and a range of decision-making bodies (at local, regional and national levels).
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6. Background to the evaluation 6.1 Assessment team Assessment team leader: Tristan Southall This evaluation was led by Tristan Southall, an experienced fisheries assessor who has worked as both principle 2 and principle 3 expert on a number of previous MSC assessments, including the Scottish Pelagic assessments for both herring and mackerel. More recently Tristan has been involved in the development and trialling of a new MSC assessment methodology, based on risk analysis, for use in data deficient situations. When not assessing the sustainability of fisheries Tristan specialises in fishing and marine industry consultancy, combining detailed understanding of marine ecosystems with broad experience of fishing and aquaculture industry systems, infrastructure and management. This provides him with an informed position which balances the needs of marine ecosystems, biodiversity and wider environment with the practicalities of the industry operation. Bridging these two important areas enables sustainably-minded consultancy, able to interpret and advise upon the impacts of different management decisions on both marine ecosystems and economics. Tristan’s professional experience also includes the evaluation of fisheries on sub-sea environments, analysis of fishery and fleet performance, and a wide range of fisheries and aquaculture planning and management studies, all of which seek to combine both socio- economic and environmental perspectives. Tristan has recently coordinated EU fisheries training and promotion activities – covering all aspects of sustainable fisheries management and control. Expert Advisor: Martin Gill Martin Gill, the Managing Director of FCI, coordinated the assessment process, and participated as a team member during the assessment as required. Martin is a marine biologist and fisheries specialist, a former staff member of the Copenhagen-based Eurofish international fishery development organisation, and is a shareholder and board member of Food Certification International. Martin was appointed as Executive Director of Food Certification (Scotland) Ltd in June 2002 and led a successful management buyout in early 2007. He joined from a five year period with FAO EASTFISH, a Food and Agriculture Organisation of the United Nations project providing a fish marketing and investment service for Central and Eastern Europe based in Copenhagen. (This project is now known as Eurofish). Among other duties he acted as the founding editor of the organisation’s Eurofish magazine. A graduate in Marine Biology from University College, Swansea, he was also a former Editor of World Fishing magazine for 5 years and has contributed since 1992 to the Encyclopaedia Britannica Book of the Year with the commercial fisheries section. Expert team member: Dr Paul Medley Dr Medley is an experienced stock assessment specialist, will assist with analysis of the fishery management systems in place, assessment of stock health. He is a fishery biologist and population dynamicist with particular experience with respect to pelagic fisheries, shellfish and small-scale fisheries, and wide experience with MSC pre-assessment and full assessments. Dr Paul Medley is an experienced fishery scientist and population analyst and modeler, with wide knowledge and experience in the assessment of pelagic stocks (amongst a range of marine Food Certification International Public Comment Draft Report 30
IPSG Western mackerel pelagic trawl fishery fish stocks and ecosystems). He has travelled widely and worked with a range of fishery systems and biological stocks, both as principal researcher and as evaluator. He is familiar with MSC assessment procedures, having participated in the first MSC full assessment – Thames herring – and is currently working with the MSC on the development of guidelines for certification of small scale, data poor fisheries. He has also participated in the full assessment of the South Georgia toothfish fishery, and with a number of pre-assessments. He is familiar with a wide range of fisheries in the North East Atlantic, and other parts of the world, and over the period 2000 to 2005 he has been serving with the Centre for Independent Experts, University of Miami, as an evaluator of various US fishery research programmes. He is based in York. Expert team member: Nick Pfeiffer Nick Pfeiffer is a fisheries and marine environmental consultant with a diverse experience and in depth knowledge of Irish marine fisheries. In particular, Nick has provided input during the evaluation of Principle 2 as part of the assessment. Working with the Marine Institute and NUI Galway, Nicks experience as a fisheries scientist spans ten years and includes the development of fisheries technical conservation measures for commercial fisheries as well as the evaluation of the impacts of a variety of fishing methods on marine ecosystems. As an industry analyst, Nick has been involved in many projects related to the fisheries sector since 2002 and most recently carried out a review of fisheries on Irish offshore islands. Through his work, Nick has always sought to develop a greater understanding of the principles that relate to the sustainability of coastal and fishing livelihoods. In this regard he is committed to promoting the concept that natural resources can be harvested in a balanced sustainable manner, thereby ensuring long-term security for coastal communities and natural systems. 6.2 Public consultation Public announcements of the progression of the assessment were made as follows: Date Purpose Media 06.08.08 notification of commencement of assessment notification on MSC website 29.08.08 nomination of Assessment Team candidates notification on MSC website From Aug 08 solicitation of inputs to stakeholder consultation email, phone and mail onwards and assessment 22.10.08 announcement of Assessment Tree and Scoring notification on MSC website Guideposts 24.11.08 announcement of assessment visit and direct email, notification on convening of stakeholder consultation meeting MSC website 12th-16 th Jan09 assessment visit meetings 19.02.09 notification of Proposed Peer Reviewers Notification on MSC website 09.06.09 notification of Public Comment Draft Report Notification on MSC website xxxxxxxxxxx notification of Final Report Notification on MSC website xxxxxxx Notification of Public Certification Report Notification on MSC website
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6.3 Stakeholder consultation Extent of available information At the time this assessment was undertaken, three MSC assessments of North East Atlantic mackerel fisheries had already been completed (detailed below) and findings presented in published assessment reports. These formed an important background resource for the assessment team – collating and reporting on available stock and fishery information, as well as highlighting areas of stakeholder and assessment team concern. A total of 45 stakeholder organisations and individuals having relevant interest in the IPSG mackerel assessment were identified and consulted during this assessment. The interest of others not appearing on this list was solicited through the postings on the MSC website, and by advertising in the Irish trade journal The Irish Skipper. Initial approaches were made by email and followed up by phone. Issues raised during correspondence were investigated during research and information gathering activities, and during interviews. Most stakeholders contacted during this exercise either indicated that they had no direct interest in this fishery assessment, or that they had no particular cause for concern with regard to its assessment to the MSC standard. Stakeholder issues Written and verbal representations were provided to the assessment team expressing a range of views, opinions and concerns. The team is of the view that matters raised have been adequately debated and addressed as a part of the scoring process for this fishery, and that none of the issues raised, therefore, require separate attention beyond that represented in this report. 6.4 Interview programme Following the collation of general information on the fishery, a number of meetings with key stakeholders were scheduled by the team to fill in information gaps and to explore and discuss areas of concern. Meetings were held as follows: Name Position Organisation Mr Sean O’Donoghue Chief Executive Killybegs Fishermans Organisation (KFO) Mr Ted Breslin KFO Contact KFO Mr John Ward Inshore Development Manager Irish Fishermans Producers Organisation (IFPO) Simon Berrow IWDG Co-ordinator Irish Whales & Dolphin Group Dr Michael Gallagher & Ms BIM manager & BIM officer Bord Iascaigh Mhara (BIM) Marianne Green Frank Fleming manager Environmental Management Systems Mr Pat McGarvey Director, Operations Unit, Sea Fisheries Protection Fisheries Protection Officer Authority (SFPA) Mr Daniel O’Callaghan Director Food Safety Unit SFPA Mr Seamus Gallagher Director of Operations SFPA
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Mr Andrew Kinneen Board Member SFPA Dr Ciaran Kelly Team Leader, Fisheries Science Irish Marine Institute (IMI) Dr Maurice Clerk Fishery Expert IMI Eugene Mullins Fishery Expert IMI Josephine Kelly Head of Marine Fisheries Dept of Agriculture, Fisheries and Food (DAFF) Kevin Moriarty Fisheries Manager DAFF Martin Oglesby, John Boyle, Skippers who met the team KFO/ IFPO Michael Cavanagh, Brendan Gill, Garry Mc Ging, Michael Callaghan, Tom Doyle Mr Karl McHugh Managing Director Quality Frozen Pelagics
6.5 Other certification evaluations and harmonisation North East Atlantic mackerel assessments have been undertaken and completed on three previous occasions: • An assessment of the South West Handline mackerel Fishery was first certified in May 2001, information can be found at http://www.msc.org/track-a-fishery/certified/north- east-atlantic/south-west-mackerel-handline • The Hastings fleet pelagic herring and mackerel fishery was first certified in October 2005. The full assessment report is available at http://www.msc.org/track-a- fishery/certified/north-east-atlantic/hastings-fleet-pelagic-herring-and-mackerel . • The Scottish Pelagic Sustainability Group have also recently undergone certification of NEA mackerel fishery, using Pelagic RSW vessels and mid-water trawl nets. Details of this assessment are available at http://www.msc.org/track-a-fishery/certified/north-east- atlantic/scottish-pelagic-sustainability-group-ltd-spsg In line with TAB 7 Directive D-015 (v2) on the harmonisation of assessments, representatives from the Certification Bodies that had undertaken previous and current mackerel assessments met in June 2008, witnessed by representatives of the MSC, to identify where differences in interpretation, argumentation and scoring were evident, and to debate and action how alignment of interpretation could best be achieved. This assessment of the IPSG mackerel fishery builds upon this ‘harmonised’ position, and seeks to justify where changes from this position are made. It is however notable, that this fishery is the first to be scored since the latest ICES working group report was published, the results of the latest triennial egg survey were published and the coastal states revised the management plan following the re-evaluation of reference points. In this regard, it should be expected for this fishery’s score to differ slightly. 6.6 Information sources used The principle sources of information used in this assessment process derive from information presented to the team by the client and fishery managers, by information derived as a result of interviews and consultations with members of the fishing industry, processors, regulators, and other stakeholders, and as a result of literature search.
7 TAB – MSC Technical Advisory Board Food Certification International Public Comment Draft Report 33
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The primary sources of information on this stock and the fishery are the Report of the Working Group on the Assessment of Mackerel, Horse Mackerel, Sardine and Anchovy (WGMHSA, 2007) and the Report of the Working Group on Widely Distributed Stocks (WGWIDE 2008) and ICES Advice 2008 in Book 9 on Northeast Atlantic Mackerel (combined Southern, Western, and North Sea spawning components) (ICES 2008a). Taken in combination these provide a clear consolidated view of the NE Atlantic mackerel stock, the fisheries that exploit the stock, and the science behind advice on the management of the stock. In addition a number of other sources have been used in this assessment, which is detailed in full in Annex 2.
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7. Scoring 7.1 Scoring Methodology Process The MSC is dedicated to promoting “well-managed” and “sustainable” fisheries, and the MSC initiative focuses on identifying such fisheries through means of independent third-party assessments and certification. Once certified, fisheries are awarded the opportunity to utilise an MSC promoted eco-label to gain economic advantages in the marketplace. Through certification and eco-labelling the MSC works to promote and encourage better management of world fisheries, many of which have been suggested to suffer from poor management. The MSC Principles and Criteria for Sustainable Fisheries form the standard against which the fishery is assessed and are organised in terms of three principles: • MSC Principle 1 - Resource Sustainability • MSC Principle 2 - Ecosystem Sustainability • MSC Principle 3 - Management Systems A fuller description of the MSC Ps & Cs and a graphical representation of the assessment tree is presented as Appendix 1 to this report. The MSC Principles and Criteria provide the overall requirements necessary for certification of a sustainably managed fishery. To facilitate assessment of any given fishery against this standard, these criteria are further split into sub-criteria. Sub-criteria represent separate areas of important information (e.g. Sub-criterion 1.1.1. requires a sufficient level of information on the target species and stock, 1.1.2 requires information on the effects of the fishery on the stock and so on). These Sub-criteria, therefore, provide a detailed checklist of factors necessary to meet the MSC Criteria in the same way as the Criteria provide the factors necessary to meet each Principle. Below each Sub-criterion, individual ‘Performance Indicators’ (PIs) are identified. It is at this level that the performance of the fishery is measured. Altogether, assessment of this fishery against the MSC standard is achieved through measurement of 31 Performance Indicators. The Principles and their supporting Criteria, Sub-criteria and Performance Indicators that have been used by the assessment team to assess this fishery are incorporated into the scoring sheets ( Appendix 3 ). Scoring of the attributes of this fishery against the MSC Ps & Cs involves the following process: • Decision to use the MSC Default Assessment Tree contained within the MSC Fishery Assessment Methodology (FAM v1). • description of the justification as to why a particular score has been given to each sub- criterion; • allocation of a score (out of 100) to each Performance Indicator. In order to make the assessment process as clear and transparent as possible, the Scoring Guideposts are presented in the scoring table and describe the level of performance necessary to achieve 100 (represents the level of performance for a performance indicator that would be expected in a theoretically ‘perfect’ fishery), 80 (defines the unconditional pass mark for a performance indicator for that type of fishery), and 60 (defines the minimum, conditional pass
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IPSG Western mackerel pelagic trawl fishery mark for each performance indicator for that type of fishery). The Assessment Tree and Scoring Guideposts for the IPSG mackerel fishery is shown as Appendix 3 to this report. Scoring outcomes There are two, coupled, scoring requirements that constitute the Marine Stewardship Council’s minimum threshold for a sustainable fishery: • The fishery must obtain a score of 80 or more for each of the MSC’s three Principles, based on the weighted average score for all Criteria and sub-criteria under each Principle; and • The fishery must obtain a score of 60 or more for each Performance Indicator. A score below 60 for a Performance Indicator would represent a level of performance that causes the fishery to automatically fail the assessment, unless performance is improved as a pre-condition to certification.
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7.2 Scoring The assessment team convened a scoring meeting on 14th , 15 th & 16 th January 2009. The output of these meetings is shown in the scoring sheets forming Appendix 3 to this report. The scores allocated to the assessment tree at Sub-criterion, Criterion and Principle levels are shown schematically in Fig 5. The weighted scores for those sub-criteria where a score of below 80 has been allocated at Performance Indicator level – and thus triggering the placing of a condition to bring that element up to good industry practice - are indicated in red. Fig 5: Summary of the scores for IPSG mackerel.
Principle 1 - Stock Status / Harvest Rules 1.1.1 Stock status 80 1.1.2Outcome Reference points 85 1.1.3 Stock rebuilding 1.2.1 Harvest strategy 90 1.2.2 Harvest control rules & tools 75 Management 1.2.3 Information & monitoring 75 1.2.4 Assessment of stock status 90 Principle 2 - Wider ecosystem impacts 2.1.1 Outcome 85 2.1.2Retained species Management 85 2.1.3 Information 90 2.2.1 Outcome 90 2.2.2Bycatch Management 80 2.2.3 Information 75 2.3.1 Outcome 75 2.3.2ETP species Management 75 2.3.3 Information 75 2.4.1 Outcome 95 2.4.2Habitats Management 95 2.4.3 Information 90 2.5.1 Outcome 80 2.5.2Ecosystem Management 90 2.5.3 Information 90 Principle 3 - Management / Governance 3.1.1 Legal & customary framework 90 3.1.2 Consultation, roles & resp. 85 Governance & policy 3.1.3 Long term objectives 90 3.1.4 Incentives for sustainable fishing 75 3.2.1 Fishery specific objectives 90 3.2.2 Decision making processes 80 Fishery specific 3.2.3 Compliance & enforcement 90 management system 3.2.4 Research plan 85 3.2.5 Mgt. performance evaluation 75
Further details are provided below on those areas where current practices are considered to be below good industry practice. In all cases however, these are not sufficiently below best practice to warrant an automatic failure (i.e. none score less than 60). In each of these cases a condition is placed upon the fishery as a requirement of certification, further explanation of the attached conditions 8 is provided in section 8.3.
8 In some cases several of the issues of concern raised in the scoring and outlined here, are covered by a single condition. Food Certification International Public Comment Draft Report 37
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And further elaboration on the justification for the scores is provided in the relevant performance indicator in the assessment tree in Annex 3. 1.2.2 Harvest strategy / management (effective HCR) This performance indicator requires that there are well defined and effective harvest control rules (HCR) in place. Whilst in the main this is undoubtedly true, the assessors were obliged to score the fishery down as a result of the continued unobserved mortality (slippage and illegal catch) in the overall fishery assessment (i.e. for the whole of the NEA mackerel stock). This undermines the effectiveness of this management tool and increases the uncertainty in the harvest control. 1.2.3 Harvest strategy / management (Info.) This performance indicator requires that relevant information is collected to support the harvest strategy. Once again, this is primarily true for this fishery; however the information on all fishery removals from the stock is incomplete. Notably, slippage is not fully monitored and could be a significant proportion of the catch. This unobserved mortality adds considerably to the uncertainty in the stock assessment. Even if monitoring improves, the absence of the data in the historical time series will continue to undermine the assessment. 2.2.3 Bycatch (Info) This performance indicator requires that information on the nature and amount of bycatch is adequate to determine the risk posed by the fishery and the effectiveness of the strategy to manage bycatch. Although the level of information about bycatch which is landed is sufficient (dealt with in this assessment under retained species) there remains a lack of scientific data in relation to the scale of bycatch which is not landed – i.e. which is slipped. No quantitative data have been made available to the assessment team about the scale of slippage in the IPSG mackerel fishery. 2.3.1 ETP species (Impact) This performance indicator requires that the fishery meets national / international requirements for protection of ETP species & does not risk serious or irreversible harm to ETP species or hinder recovery. Whilst the assessors conclude that the known effects are likely to be within limits of national and international requirements for protection of ETP species, this cannot be categorically stated. The Sea-Fisheries (Incidental Catches of Cetaceans in Fisheries) Regulations 2007 (S.I. No. 274 of 2007) give full effect to Council Regulation (EC) No. 812/2004 which lays down measures concerning incidental catches of cetaceans in certain fisheries. In 2007 the European Court of Justice ruled that Ireland had failed to implement fully and adequately several provisions of the Habitats Directive in so far as these relate to the strict protection and monitoring of cetaceans in Irish waters (Case C-183/05). In addition Ireland was ruled against for failing to collect information in relation to cetacean abundance and distribution within its 200-mile exclusive economic zone. 2.3.2 ETP species (Management strategies) This performance indicator requires that precautionary management strategies exist for the fisheries interaction with ETP species. The IPSG vessels have recently introduced Environmental Management Systems which include strategies for ETP species; however the management strategy is undermined by lack of information, reporting, collating and coordination with the relevant bodies, and, at national level, by a lack of observer coverage.
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Once this becomes available it may be possible to develop more informed management strategies. 2.3.3 ETP species (info) This performance indicator requires that information is collected to support management of impacts on ETP species. The assessors conclude that mapping of cetacean distribution at national level is insufficient, and that reporting and observer coverage is also insufficient to confidently and quantifiably describe the impact of IPSG vessels on cetaceans and other ETP species. 3.1.4 Governance and policy (incentives / subsides) This performance indicator requires that the management system provides economic / social incentives for sustainable fishing and does not operate with subsidies that contribute to unsustainable fishing. Since the revision of the CFP in 2002, subsides have been reduced to the point where this is no longer thought to contribute to unsustainable fishing. However, the IPSG fleet has considerable capacity, relative to the available quota. The lack of any form of quota trading means that it is difficult to envisage considerable contraction in the overall fleet capacity. Whilst it is not the role of this assessment to recommend how quota should be managed, it can be stated that capacity should remain the same or contract over time, in order to avoid increasing incentives to overfish. 3.2.5 Fishery specific management system (Monitoring and evaluation) This performance indicator states that monitoring and evaluating of the performance of the fishery-specific management system should be undertaken with an effective and timely review. Again, the assessors conclude that most of the requirements for fulfilling the performance indicator are in place; however the principle weakness of the monitoring programme is the relatively low observer coverage at sea for corroborating management information.
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8. Certification recommendation The target Eligibility Date is the 1 st January 2009. 8.1 Overall Scores The Performance of the IPSG western mackerel fishery in relation to MSC Principles 1, 2 and 3 is summarised below: MSC Principle Fishery Performance Principle 1: Sustainability of Exploited Stock Overall : 83 PASS Principle 2: Maintenance of Ecosystem Overall : 85 PASS Principle 3: Effective Management System Overall : 85 PASS
The fishery attained a score of 80 or more against each of the MSC Principles and did not score less than 60 against any MSC Criteria. It is therefore recommended that the Irish Pelagic Sustainability Group western mackerel fishery be certified according to the Marine Stewardship Council Principles and Criteria for Sustainable Fisheries. Following this recommendation of the assessment team, and review by stakeholders and peer- reviewers, the recommendation will be presented to the Governing Board of FCI to certify this fishery. 8.2 Limit of Identification of Landings This assessment relates only to the fishery defined in Section 2.1 up to the point of landing of North East Atlantic mackerel from the IPSG registered vessels to pelagic processing plants that have been approved to the MSC Chain of Custody Standard. 8.3 Conditions The fishery attained a score of below 80 against a number of Performance Indicators. The assessment team has therefore set a number of conditions for continuing certification that the Irish Pelagic Sustainability Group, as the client for certification, is required to address. The conditions are applied to improve performance to at least the 80 level within a period set by the certification body but no longer than the term of the certification. As a standard condition of certification, the client shall develop an 'Action Plan’ for meeting the conditions for continued certification, to be approved by Food Certification International. The conditions are associated with five key areas of performance of the fishery, each of which addresses one or more Performance Indicators. Conditions, associated timescales and relevant Performance Indicators are set out below.
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Condition 1: Record all incidences of slippage. Relevant Performance Indicators: 1.2.2, 1.2.3, 2.2.3 Timelines: The condition should apply from the start of certification. Recording of slippage should be in place as from the start of certification and evidence of this should be provided at the time of the first surveillance visit. Observer reports of slippage within the fishery should be provided for the second surveillance visit. Suggested Action: There is concern that slippage related mortality in the target species may be higher than currently considered. IPSG vessels should record all slippage. The IPSG should consult with the Marine Institute as to what information is required, but it is likely to include estimated quantity of fish by species, reason for slipping, and the condition of the school to give an indication of likely mortality. Where possible, vessels should take samples of slippage to more accurately estimate quantities, size and species mix. Again, IPSG should consult with the Marine Institute over what level of sampling is required. IPSG should collate information from all vessels, from their EMS logsheet records of slippage, and ensure that all vessels are complaint. Information should be collated and passed to Marine Institute. *Note: The Marine Institute have stated that all data can be anonymous.
Condition 2: Reduce slippage to minimum. Relevant Performance Indicators: 1.2.2 Timeline: The condition should apply from the start of certification and the target level reached before the certification expires. Suggested Action: The IPSG Environmental Management System already sets out a strategy to reduce slippage mortality. This should be strengthened and formalised in order to ideally be fully auditable and ensure that all vessels (and crew) are fully compliant. If slippage is eliminated, Condition 1 is also automatically met. Although zero slippage is preferable, it is recognised that this may be difficult to achieve in practice. Verifiably negligible slippage should be the ultimate target, although new techniques may need to be developed to achieve this. While in theory recording mortality should be enough (Condition 1), this condition recognises the lack of control the economic pressure for slippage induces through wastage (lost potential yield) and that estimates of the quantity of slippage will always be poor. Reducing slippage reduces uncertainty and ensures that TAC will be more likely to achieve the intended fishing mortality.
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Condition 3: Annual verification available that the fishery makes no contribution to the overshoot of the TAC. Relevant Performance Indicators: 1.2.2 Timeline: The condition should apply from the start of certification and be on-going until such time as the overshoot of target fishing mortality is no longer a problem within the NEA mackerel fishery as a whole. Suggested Action: IPSG must clearly demonstrate that its vessels do not contribute to overshoot of the TAC – i.e. that they fish within their annual quota allocation. During the period of certification, the total landings should be equal to or lower than the quota allocated to the client (including additional or reduced allocations resulting from quota swaps), which can be checked during the surveillance and this should be verified by monitoring and surveillance data from the Irish Sea Fishery Protection Authority.
Condition 4: Interactions with ETP species. Relevant Performance Indicators: 2.3.1, 2.3.2, 2.3.3 Timeline: By the time of the first surveillance visit, IPSG should have established links with the appropriate authorities, and with Irish Whale and Dolphin group, to further clarify requirements for both mapping and recording of interactions. Relevant ETP observer protocols should also be in place. By the time of the second surveillance visit, it must be demonstrated to the assessors that the fleet are fully engaged in the ETP interactions reporting, set out in the EMS, and the provisions under SI 274 of 2008 as they relate to pelagic pair trawling for North East Atlantic mackerel are implemented. Suggested Action: Although the known effects of the fishery are likely to be within limits of national and international requirements for protection of ETP species and are unlikely to create unacceptable impacts to ETP species, there is nonetheless a need for improved information upon which to base appropriate management strategies for endangered, threatened and protected species. This includes facilitating improved understanding of the overall species distribution, but also providing an improved understanding of the interactions of the key species with the fishery. To achieve this: 1) ISPG should facilitate and promote the full implementation of provisions under SI 274 of 2007 as they relate to pelagic pair trawling for North East Atlantic mackerel 2) IPSG should assist to facilitate the mapping of cetacean distribution and abundance in Irish waters by carrying researchers onboard 3) All vessels should compile the ETP species interaction data from the onboard Seafood Environmental Management System and the IPSG should annually collate this data and make available to appropriate authorities.
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Condition 5: Capacity. Relevant Performance Indicators: 3.1.4 Timeline: This applies from the moment of certification, throughout the life of the certificate Suggested Action: This certificate is awarded on the basis of a fleet size of 22 RSW vessels. The assessors note that this is a large capacity compared to the available resource, therefore providing a potential incentive to overfish. It is therefore a condition of certification that no additional capacity be added to fleet over and above the target limits set down by the Multi-Annual Guidance Programme IV (MAGP IV), unless it is clearly demonstrated that this is linked to an equal removal of Capacity from the Irish RSW pelagic fleet. In particular no additional capacity should be added to the fleet which is currently “off register” unless it can be clearly demonstrated that this is done within both the letter and the spirit of law (both national and EU), and will not lead to an increasing, and unsustainable pressure on the available resource. However any safety tonnage which may be approved under Regulation 413/1997 can be added to the fleet, but the certification body must be alerted of any such change.
Condition 6: Monitoring / observer coverage. Relevant Performance Indicators: 3.2.5, 1.2.3, 2.3.3 Timeline: Increased evidence of observer coverage should be evident by the first surveillance visit, including evidence of liaison with the appropriate Irish authorities. An observer protocol and recording system should also be developed for use in the pelagic fleet. By the second surveillance visit, observer reports and appropriate analysis of observer data should be available to assessors, and be being routinely passed to the Marine Institute. Suggested Action: For a fishery of this size and sophistication, there is a surprisingly low level observer coverage. For a fishery seeking to operate in a sustainable manner, this lack of independent corroboration undermines confidence in the levels of compliance within the fleet. By actively encouraging more observer coverage – through liaisons with DAFF, BIM and MI – the IPSG fleet can take a lead in demonstrating the culture of compliance and sustainable fishing within the mackerel fishery. Observer coverage should focus on a number of areas including; overall vessel operations and data recording, slippage and interactions with ETP species, seabed (sub-sea habitats). Where requested scientific observer access to the vessel / trip must not be denied without justifiable reason. All refusals should be reported to the Certification Body. 8.4 Recommendations In addition to the above Conditions, it is also considered that there are areas of performance that the team would like to see improvements in, despite the fact that they relate to Performance Indicators where the client vessels scored 80 or better. The assessment team has made a number of recommendations. These are not required to maintain certification but would improve the performance of the fishery against the MSC Food Certification International Public Comment Draft Report 43
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Principles and Criteria. Accordingly, the action taken and timescales are at the discretion of the client.
Recommendations are made in respect of: • Appeals Process / Administrative Penalties (3.1.3) – Although the Sea Fisheries Jurisdiction Act (2006) includes a provision for an appeals officer, it is understood that this is still to be implemented, therefore it cannot be stated that the appeals system has been tested and proven to be effective. In addition, skippers were not aware of any internal appeals process. Whilst the MSC clearly supports the idea of strong judicial disincentives to overfish, it is important that these are applied equitably and fairly. It is therefore recommended that the IPSG clarify the appeals process with DAFF and ensure that all skippers are aware of the process. It is particularly important to ensure that there is a fair, robust and accessible appeals process given the lack of administrative penalties for, even minor, fishing infringements. It is interesting to note that in the consultation process that is now underway on the reform of the CFP in 2012, which will include a reform of the control system, one area that is being examined is a points-based licensing. In this system minor infringements would accrue points, but repeated infringements may ultimately lead to a fishing permit being either suspended or permanently withdrawn. It will be interesting for Irish fleets and authorities to follow, and indeed contribute to, this debate.
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9. Applicant’s agreement to conditions The agreed and signed Action Plan of the IPSG to meet the above Conditions of Certification is appended to this report.
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Appendix 1 – MSC Ps & Cs
Below is a much-simplified summary of the MSC Principles and Criteria, to be used for over- view purposes only. For a fuller description, including scoring guideposts under each performance indicator, reference should be made to the full assessment tree, complete with scores and justification, contained in annex 3 of this report. Alternately a fuller description of the MSC Principles and Criteria can be obtained from the MSC website (www.msc.org ). Principle 1 A fishery must be conducted in a manner that does not lead to over-fishing or depletion of the exploited populations and, for those populations that are depleted, the fishery must be conducted in a manner that demonstrably leads to their recovery. Intent: The intent of this principle is to ensure that the productive capacities of resources are maintained at high levels and are not sacrificed in favour of short-term interests. Thus, exploited populations would be maintained at high levels of abundance designed to retain their productivity, provide margins of safety for error and uncertainty, and restore and retain their capacities for yields over the long term. Outcomes • The stock is at a level that maintains high productivity and has a low probability of recruitment overfishing. • Limit and target reference points are appropriate for the stock (or some measure or surrogate with similar intent or outcome). • Where the stock is depleted, there is evidence of stock rebuilding and rebuilding strategies are in place with reasonable expectation that they will succeed. Harvest strategy / management
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• There is a robust and precautionary harvest strategy in place, which is responsive to the state of the stock and is designed to achieve stock management objectives. • There are well defined and effective harvest control rules in place that endeavour to maintain stocks at target levels. • Sufficient relevant information related to stock structure, stock productivity, fleet composition and other data is available to support the harvest strategy. • The stock assessment is appropriate for the stock and for the harvest control rule, takes into account uncertainty, and is evaluating stock status relative to reference points. Principle 2 Fishing operations should allow for the maintenance of the structure, productivity, function and diversity of the ecosystem (including habitat and associated dependent and ecologically related species) on which the fishery depends Intent: The intent of this principle is to encourage the management of fisheries from an ecosystem perspective under a system designed to assess and restrain the impacts of the fishery on the ecosystem. Retained species / Bycatch / ETP species • Main species are highly likely to be within biologically based limits or if outside the limits there is a full strategy of demonstrably effective management measures. • There is a strategy in place for managing these species that is designed to ensure the fishery does not pose a risk of serious or irreversible harm to retained species. • Information is sufficient to quantitatively estimate outcome status and support a full strategy to manage main retained / bycatch and ETP species. Habitat & Ecosystem • The fishery does not cause serious or irreversible harm to habitat or ecosystem structure and function, considered on a regional or bioregional basis. • There is a strategy and measures in place that is designed to ensure the fishery does not pose a risk of serious or irreversible harm to habitat types. • The nature, distribution and vulnerability of all main habitat types and ecosystem functions in the fishery area are known at a level of detail relevant to the scale and intensity of the fishery and there is reliable information on the spatial extent, timing and location of use of the fishing gear. Principle 3 The fishery is subject to an effective management system that respects local, national and international laws and standards and incorporates institutional and operational frameworks that require use of the resource to be responsible and sustainable. Intent: The intent of this principle is to ensure that there is an institutional and operational framework for implementing Principles 1 and 2, appropriate to the size and scale of the fishery. Food Certification International Public Comment Draft Report 47
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Governance and policy • The management system exists within an appropriate and effective legal and/or customary framework that is capable of delivering sustainable fisheries and observes the legal & customary rights of people and incorporates an appropriate dispute resolution framework. • Functions, roles and responsibilities of organizations and individuals involved in the management process are explicitly defined and well understood. The management system includes consultation processes. • The management policy has clear long-term objectives, incorporates the precautionary approach and does not operate with subsidies that contribute to unsustainable fishing. Fishery specific management system • Short and long term objectives are explicit within the fishery’s management system. • Decision-making processes respond to relevant research, monitoring, evaluation and consultation, in a transparent, timely and adaptive manner. • A monitoring, control and surveillance system has been implemented. Sanctions to deal with non-compliance exist and there is no evidence of systematic non- compliance. • A research plan provides the management system with reliable and timely information and results are disseminated to all interested parties in a timely fashion.
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Appendix 2 – References Short reference Full citation ICES documents ICES (2008)a ICES 2008 Advice for North east Atlantic Mackerel (combined southern, Western and North Sea spawning components). ICES Advice 9.4.2. ICES (2008)b ICES 2008 Advice for herring in sub area IV, division VIId, Division IIIa (autumn spawners). ICES Advice 2008 6.4.18
ICES (2008)c ICES 2008 Advice for Western horse mackerel ( Trachurus trachurus ) (Divisions IIa, IVa, Vb, VIa, VIIa–c,e–k, and VIIIa–e). ICES, Advice 2008 Book 9 pp88-104 ICES (2007a) ICES (2007a) ICES Advice 2007. Book IX, 9.4.2 – North East Atlantic Mackerel (combined southern, western and North Sea spawning components). ICES (2007b) ICES (2007b) ICES Advice 2007, Book 9. 9.3.2.3 EC request on evaluation of management plan for NEA mackerel. Pp. 10-12. ICES (2007c) ICES (2007c) Mackerel Scomber scombrus ICES Fishmap Species Summary. LRC (2007) ICES LRC (2007) Report of the Living Resources Committee (LRC) SGWRECC (2008) ICES SGWRECC (2008) Report of the Study Group on Working Hypotheses Regarding effects of Climate Change (SGWRECC). ICES CM 2008 ACOM:43 WGFE (2007) ICES WGFE (2007) Report of the Working Group on Fish Ecology (WGFE). ICES Living Resources Committee. ICES CM 2007/LRC:03 Ref. ACE, ACFM WGMEGS (2008) ICES WGMEGS (2008) Report of the Working Group on Mackerel and Horse Mackerel Egg Surveys (WGMEGS) ICES WGMEGS Report 2008. ICES CM 2008/LRC:09 WGMHSA (2007) ICES WGMHSA (2007) Report of the Working Group on the Assessment of Mackerel, Horse Mackerel, Sardine and Anchovy (WGMHSA) WGMHSA (2006) ICES WGMHSA (2006) Report of the Working Group on the Assessment of Mackerel, Horse Mackerel, Sardine and Anchovy (WGMHSA) WGQAF (2008) ICES WGQAF (2008) Report of the Working Group on Quantifying All Fishing Mortality (WGQAF). ICES WGQAF Report 2008 ICES Fisheries Technology Committee. ICES CM 2008/FTC:03 REF. RMC WGRED (2008) ICES WGRED (2008) Report of the Working Group for Regional Ecosystem Description (WGRED) ICES CM 2008/ACOM:47 Ref. AMAWGC WGRED (2006) ICES WGRED (2006) Report of working group for regional ecosystem description (WGRED). ICES CM 2006/ACE:03. WGRP (2007) ICES WGRP (2007) Report of the Working Group on Recruitment Process (WGRP), ICES Oceanography Committee, ICES CM 2007/OCC:11 WGSAM (2007) ICES WGSAM (2007) Report Of The Working Group On Multispecies Assessment Methods (WGSAM) 15–19 October 2007. ICES CM 2007/RMC:08. WGWIDE (2008) ICES WGWIDE (2008) Report of the Working Group on Widely Distributed Stocks (WGWIDE). ICES CM 2008/ACOM:13 2–11 September 2008 ICES Headquarters Copenhagen WKDRP (2008) ICES WKDRP (2008) Report of the Workshop on Discard Raising Procedures. ICES WKDRP Report 2007 ICES Advisory Committee On Fishery Management ICES CM 2007 ACFM:06 Ref. RMC PGCCDBS WKEFA (2007) ICES WKEFA (2007) Report of the Workshop on the Integration of Environmental Information into Fisheries Management Strategies and Advice (WKEFA) 2007
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WKREF (2007) ICES WKREF (2007) ICES WKREF Report 2007. Report of the Workshop on Limit and Target Reference Points [WKREF] 29 January – 2 February 2007 Gdynia, Poland. ICES CM 2007/ACFM:05
Fisheries management BIM (2006a). Bord Iascaigh (2006) STEERING A NEW COURSE Report of the Seafood Industry Mhara (BIM) Strategy Review Group. Strategy for a Restructured, Sustainable and Profitable Irish Seafood Industry 2007-2013. BIM (2006b) Bord Iascaigh (2006) Report No. 1 under Council regulation (EC) No. 812/2004 Mhara (BIM) Ireland June 2004 – June 2006
BIM (2007) Bord Iascaigh (2007) Report No. 2 under Council regulation (EC) No. 812/2004 Mhara (BIM) Ireland 1 st July 2006 – 30 th June 2007
BIM (2007a) Bord Iascaigh (2007) Pelagic Trawl Selectivity – development of flexi grid devices to Mhara (BIM) reduce discarding in pelagic fisheries.
BIM (2008) Bord Iascaigh (2008) Seafood Environmental Management System - environmental Mhara (BIM) manangment manual for the production sector. An Bord Iascaigh Mhara, Crofton Road, Dun Laoghaire. Co Dublin. EC (2008a) European (2008a) EU-Coastal States 2008 agreement. Agreed Record of Commission Conclusions between the European Community and the Coastal States for 2008. Brussels EC (2008b) European (2008b) EU Involvement – Commission http://ec.europa.eu/fisheries/cfp/external_relations/international _agreements_en.htm EC (2008c) European (2008c) The CFP - http://ec.europa.eu/fisheries/cfp_en.htm Commission EC (2008d) European (2008d) ACFA - Commission http://ec.europa.eu/fisheries/cfp/governance/acfa_en.htm EC (2008e) European (2008e) Common Fisheries Policy - Commission http://ec.europa.eu/fisheries/cfp_en.htm EC (2008f) European (2008f) Reform of the CFP - Commission http://ec.europa.eu/fisheries/press_corner/press_releases/archi ves/com02/com02_60_en.htm EC (2008g) European (2008g) Control and enforcement under the CFP - Commission http://ec.europa.eu/fisheries/cfp/control_enforcement_en.htm EC (2008h) European (2008h) European Community Fisheries Control Agency - Commission http://ec.europa.eu/fisheries/cfp/control_enforcement/control_ag ency_en.htm EC (2008i) European (2008i) EU Fisheries Scoreboard – Commission http://ec.europa.eu/fisheries/cfp/control_enforcement/scoreboar d_en.htm EC (2008j) European (2008j) European regional socio-economic studies – summary maps – Commission http://ec.europa.eu/fisheries/cfp/structural_measures/socio_eco nomic/study_2003/regions_en.htm EC (2007) European (2007) General Principles of the Common Fisheries Policy – MS Commission PowerPoint presentation by Jorgen Holmquist, Director-General for Fisheries & Maritime Affairs DG of the European Union. EC (2002) European (2002) CFP Regulation – Reg2371/2002 – http://eur- Commission lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32002R23 71:EN:HTML PRAC (2008) PRAC (2008) Pelagic Regional Advisory Council (RAC) – http://www.pelagic- rac.org/ SFPA (2008) SFPA (2008) Annual Report of the Scottish Fishery Protection Agency - http://www.sfpa.gov.uk/docs/2006-07%20annual%20report.pdf STECF (2008) STECF (2008) Scientific, Technical and Economic Committee for Fisheries (STECF) – http://stecf.jrc.ec.europa.eu Food Certification International Public Comment Draft Report 50
IPSG Western mackerel pelagic trawl fishery
UNCLOS (2008) UNCLOS (2008) Law of the Sea – http://un.org/Depts/los/reference_files/chronological_lists_of_rat ifications.htm#The%20United%20Nations%20Convention%20o n%20the%20Law%20of%20the%20Sea sources of more specific information Berrow et al (1998) SD Berrow, (1998) (1998). DISCARDING PRACTICES AND MARINE MAMMAL MO’Neill, D BY-CATCH IN THE CELTIC SEA HERRING FISHERY. Biology Brogan AND Environment: Proceedings OF THE Royal Irish Academy. Vol. 98B No. 1 (1-8). Defra (2003) Defra (2003) DEFRA 2003. UK Small Cetacean Bycatch Response Strategy. Defra (2007) Defra (2007) Defra (2007) Charting progress: an integrated assessment of the state of UK seas – marine habitats and species. http://defra.gov.uk/environment/water/marine/uk/stateofsea/ Dickey-Collas et al. Dickey-Collas, (2007) Discards by Dutch Flagged Freezer trawlers. Abstract reported (2007) M., van Helmond, in WGMHSA (2007) Pg. 671. Document available from Mark E. Dickey-Collas, Wageningen IMARES, P.O. Box 68, 1970 AB, IJmuiden, the Netherlands, E-mail: [email protected] EC (2008k) European (2008k) European state aid to the fisheries and aquaculture sectors – Commission http://ec.europa.eu/fisheries/legislation/state_aid_en.htm Edwards et al (2006) Edwards, M. (2006) Ecological Status Report: results from the CPR Survey Johns, D.G., 2004/2005. (2006). Licandro, P., John, A.W.G., Stevens, D.P. FAO (2006) FishStat+ (2006) Fishery Statistical Collect ions 2006, Global Production. Food and Agriculture Organisation of the United Nations. FAO (2008) FAO (2008) FAO – Gear Type Fact Sheet; Mid water trawl http://www.fao.org/fishery/geartype/207 Farina, A.C. (1997) Farina, A.C., (1997) Demersal fish assemblages in the Galician continental shelf and Freire, J., upper slope (NW Spain): Spatial structure and long-term Gonzalez- changes. Estuarine, Coastal and Shelf Science , 44, 435–454. Gurriaran, E. (1997) Fock, H (2002) Fock, H., Uiblein, (2002) Biodiversity and species-environment relationships of the F., Köster, F., demersal fish assemblage at the Great Meteor Seamount von (subtropical NE Atlantic), sampled by different trawls. Marine Westernhagen, Biology, 141: 185-199. H. (2002) GTZ (2008) GTZ (2008) International Fuel Prices by GTZ - http://www.international-fuel- prices.com Holeton et al 1983 Holeton, G. F., (1982) "Gill ventilation, gas exchange and survival in the Atlantic M.G. Pawson & mackerel (Scomber scombrus L.)." Can. J. Zool, 60: 1141- Shelton, G., 1147.
IEEP (2008) IEEP (2008) Work conducted by IEEP and commissioned by WWF – http://www.wwf.fi/wwf/www/uploads.pdf/SUBSIDIESReport.pdf Lockwood et al 1977 Lockwood, S. J., 1977. "Effects of holding mackerel at different densities in nets Pawson, M.G. of various sizes." M.A.F.F., Fish. Res. Tech. rep. No. 33, 10 pp and Mumford, B.C.,
Lockwood et al 1983 Lockwood, S. J., ., 1983 "The effects of crowding on mackerel (Scomber scombrus L) - M. G. Pawson physical condition and mortality". Fisheries Research, 2: 129- and D. Eaton 147.
Lockwood 1988 Lockwood, S. J ., 1988 "The mackerel – it’s assessment, biology and the management of the fishery". Farnham, Fishing News Books. Food Certification International Public Comment Draft Report 51
IPSG Western mackerel pelagic trawl fishery
Pawson & Lockwood Pawson, M. G. 1980 "Mortality of mackerel following physical stress, and its 1980 and Lockwood, probable cause." I.C.E.S. rapp. proc. verb., 177: 439-443. S. J., Northridge (2008) Northridge, S (2008) Personal communication with Simon Northridge of the Sea Mammal Research Unit, St Andrews Patterson (1995) Patterson K.R. (1995) Technical reference for the Integrated Catch-at-Age Programmes, Version 1.2 . SOAFD Marine Laboratory. Aberdeen. Patterson (1998) Patterson, K.R. (1998) 1998. Integrated catch at age analysis version 1.4. Scottish Fisheries Research Report No. 38. Pinnegar J.K., (2002) Pinnegar J.K., (2002) Long-term changes in the trophic level of the Celtic Sea fish Jennings, S., community and fish market price distribution. Journal of Applied O’Brien, C.M. & Ecology, 39: 377-390. Polunin N.V.C. (2002) Reid, et al. (2006) Reid, D., Eltink, (2006) Long-term changes in the pattern of the pre-spawning migration A. et al. of the western mackerel (Scomber scombrus) since 1975 using commercial vessel data. ICES CM 2006/B:14. Ross A, Isaac S Ross A, Isaac S (2004) The net effect? A review of cetacean bycatch in pelagic trawls (2004). (2004). and other fisheries in the north-east Atlantic. London, UK: Greenpeace Environmental Trust. Simmonds (2007) Simmonds J. (2007) Evaluation of potential unknown missing biomass and removals from the NE Atlantic population. Simmonds (WD2007) reported in WGMHSA (2007) pp.69-74. SPSG, 2009 FCI (2009) Public Certification report for the Scottish Pelagic Sustainability Group Ltd (SPSG) Western Mackerel Fishery ( Scomber scrombus ). Food Certification International
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SCORING INDICATORS Justification References Score
Appendix 3 – Assessment Tree / Scoring sheets The following Assessment Tree includes description of the scoring guideposts (SGs) and performance indicators (PIs) used to score the fishery. The Assessment tree provides detailed justification for all scores attributed to the fishery, in a way which is clearly auditable by future assessors NAME OF FISHERY IRISH PELAGIC SUSTAINABILITY GROUP – WESTERN MACKEREL PELAGIC TRAWL FISHERY
A fishery must be conducted in a manner that does not lead to over-fishing or depletion of the exploited Principle 1 populations and, for those populations that are depleted, the fishery must be conducted in a manner that demonstrably leads to their recovery.
1.1 Outcomes
The stock is at a level that maintains high productivity and has a low probability 1.1.1 Stock status 80 of recruitment overfishing. 60 It is likely that the stock is above the point where recruitment would be impaired. It is highly likely that the stock is above the point where recruitment would be impaired. WGMHSA 80 It is highly likely that the stock is above the point where recruitment would be impaired. The stock The SSB in 2008 was estimated to be 2.8 million tonnes, well above the precautionary 2007 is at or fluctuating around its target reference point. reference point (B pa = 2.3). The SSB is thought to have risen from a low of 1.8 million WGWIDE 2008 100 There is a high degree of certainty that the stock is above the point where recruitment would be tonnes in 2002 despite a relatively high fishing mortality due to the arrival of a large ICES 2008a impaired. There is a high degree of certainty that the stock has been fluctuating around its target 2002 year class and improved enforcement reducing illegal landings. reference point, or has been above its target reference point, over recent years . The exploitation rate is close to its target reference point. A new target reference point for fishing mortality of 0.22 has been adopted based on model simulations. For management purposes target fishing mortality appears to have been set at 0.2 in 2007, but the effective fishing mortality, including discards and landings (including Iceland) exceeding the TAC was above this. Fishing mortality in 2008 was estimated to be slightly higher than the target reference point (F=0.25), but fishing mortality has remained relatively constant over the last few years while the stock has increased in size.
1.1.2 Reference points Limit and target reference points are appropriate for the stock. 85 60 Generic limit and target reference points are based on justifiable and reasonable practice Reference points can be estimated and are appropriate for the stock. The biomass ICES 2008a appropriate for the species category. reference points are not based on a stock recruitment relationship, but the historical WGWIDE 2008 80 Reference points are appropriate for the stock and can be estimated. The limit reference point is time series over which period recruitment has not been impaired by depletion. There is NEAFC 2008 set above the level at which there is an appreciable risk of impairing reproductive capacity. The only a trigger point (B pa ) which forms part of the decision rule, and a defined target target reference point is such that the stock is maintained at a level consistent with BMSY or region (B > B pa ). some measure or surrogate with similar intent or outcome. For low trophic level species, the target reference point takes into account the ecological role of the stock.
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100 Reference points are appropriate for the stock and can be estimated. The limit reference point is There is now an explicit biomass limit reference point. set above the level at which there is an appreciable risk of impairing reproductive capacity following consideration of relevant precautionary issues . The target reference point is such that The fishing mortality limit reference point is set below the level at which there is an the stock is maintained at a level consistent with BMSY or some measure or surrogate with appreciable risk of impairing reproductive capacity. The fishing mortality target similar intent or outcome, or a higher level , and takes into account relevant precautionary issues reference point is precautionary, such that the stock is maintained at a safe level. It is such as the ecological role of the stock with a high degree of certainty. used as the basis for recommending TACs. No specific account is taken of the ecological role of the stock, but the target fishing mortality is sufficiently precautionary to allow for likely consumption of mackerel as a prey species.
1.1.3 Stock recovery Where the stock is depleted, there is evidence of stock rebuilding. n/a 60 Where stocks are depleted rebuilding strategies which have a reasonable expectation of success are in place. Monitoring is in place to determine whether they are effective in rebuilding the stock This is not applicable in this case. within a specified timeframe. 80 Where stocks are depleted rebuilding strategies are in place. There is evidence that they are rebuilding stocks, or it is highly likely based on simulation modelling or previous performance that they will be able to rebuild the stock within a specified timeframe. 100 Where stocks are depleted, strategies are demonstrated to be rebuilding stocks continuously and there is strong evidence that rebuilding will be complete within the shortest practicable timeframe.
1.2 Harvest strategy / management 1.2.1 Harvest strategy There is a robust and precautionary harvest strategy in place. 90 60 The harvest strategy is expected to achieve stock management objectives reflected in the target The harvest strategy is responsive to the state of the stock . The TAC is evaluated ICES 2008a and limit reference points. The harvest strategy is likely to work based on prior experience or annually and recommendations made by the management based on the decision rule ICES plausible argument. Monitoring is in place that is expected to determine whether the harvest and state of the stock. 2007bEAFC strategy is working. 2008 The current harvest strategy has not yet been fully tested, but monitoring is in place 80 The harvest strategy is responsive to the state of the stock and the elements of the harvest WGWIDE 2008 and the evidence suggests that it is achieving its objectives. The stock assessment strategy work together towards achieving management objectives reflected in the target and limit gives annual feedback to management on how well they are achieving their objectives. reference points. The harvest strategy may not have been fully tested but monitoring is in place However, the harvest strategy is hampered by the significant unrecorded mortality (PI and evidence exists that it is achieving its objectives. 1.2.2) and by the historical poor biomass estimates (PI 1.2.3), considered under
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100 The harvest strategy is responsive to the state of the stock and is designed to achieve stock 1.2.2) and by the historical poor biomass estimates (PI 1.2.3), considered under management objectives reflected in the target and limit reference points. The performance of the separate performance indicators. The infrequent collection of the abundance index harvest strategy has been fully evaluated and evidence exists to show that it is achieving its means that the harvest strategy has not yet been fully evaluated. objectives including being clearly able to maintain stocks at target levels. The harvest strategy is periodically reviewed and improved as necessary. The different elements of the harvest strategy are consistent. The TAC and closed areas are designed to achieve management objectives reflected in the target and limit reference points and stock structure. The harvest strategy is periodically reviewed and has recently been improved, exceeding the 80 guide post. Reference points and the harvest control rule are undergoing a re-evaluation in 2008, and there is evidence that corrections to the assessment are implemented, and that the harvest responds to improved information. This on-going development which should also be monitored through future surveillance audits.
1.2.2 Harvest control rule(s) & tools There are well defined and effective harvest control rules in place. 75 60 Generally understood harvest control rules are in place that are consistent with the harvest A well defined harvest control rule is in place that is consistent with the harvest strategy ICES 2008a strategy and which act to reduce the exploitation rate as limit reference points are approached. and ensures that the recommended exploitation rate is reduced consistent with the There is some evidence that tools used to implement harvest control rules are appropriate and reference points. The current decision rules are set out very clearly in the EU-Norway- ICES 2007a effective in controlling exploitation. Faroes agreement. ICES 2007b 80 Well defined harvest control rules are in place that are consistent with the harvest strategy and ICES 2007c The selected harvest control rule takes into account the main uncertainties and, on the ensure that the exploitation rate is reduced as limit reference points are approached. The selection NEAFC 2008 face of it, is precautionary. The current target fishing mortality of 0.22 year -1 is of the harvest control rules takes into account the main uncertainties. Available evidence indicates WGWIDE 2008 considered reasonable for a species with this life history and has been tested using that the tools in use are appropriate and effective in achieving the exploitation levels required simulations of the population and fishery. under the harvest control rules. 100 Well defined harvest control rules are in place that are consistent with the harvest strategy and Available evidence indicates that the tools in use are appropriate and effective, with ensure that the exploitation rate is reduced as limit reference points are approached. The design of the exception that no account is taken of the unobserved mortality. The primary tool is the harvest control rules take into account a wide range of uncertainties. Evidence clearly shows the TAC, which is appropriate given the available information and stock assessment that the tools in use are effective in achieving the exploitation levels required under the harvest approach. There are significant disclosure and enforcement systems in place to control rules. detect and discourage misreporting. All vessels are subject to VMS if over 15m. The unobserved mortality (slippage and illegal catch) undermines the effectiveness of this management tool and increases the uncertainty in the harvest control. Nevertheless, this is mitigated by the precautionary target fishing mortality and slippage, at least, is likely to decrease as the TAC is decreased.
1.2.3 Information / monitoring Relevant information is collected to support the harvest strategy. 75
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60 Some relevant information related to stock structure, stock productivity and fleet composition is Sufficient relevant information related to stock structure, stock productivity, fleet WGMHSA available to support the harvest strategy. Stock abundance and fishery removals are monitored composition and other data is available to support the harvest strategy. The life history, 2007 and at least one indicator is available and monitored with sufficient frequency to support the spawning areas, stock structure and productivity are reasonably well understood. The WGWIDE harvest control rule. fleet and fleet activities are well monitored, with complete information on the fleet and at 2008 sea monitoring using VMS. An estimate of natural mortality and dispersion is available from a previous tagging programme. Stock abundance and fishery removals are regularly monitored at a level of accuracy and coverage consistent with the harvest control rule. The total landings are monitored, and recently landings monitoring is thought to have improved. The Working Group provides its own estimated catches, including misreported and unallocated catches, to the assessment replacing the official reports where necessary. Biological sampling, which provides age composition, weight-at-age in the catch and population and the maturity-at-age, covers overall 85% of landings, which is considered at least adequate. 94% of the Irish fleet landings were covered. One abundance index is available and monitored with sufficient frequency to support the harvest control rule. The triennial egg surveys allow detailed monitoring of the distribution and abundance of the spawning stock. This survey should provide a good estimate of spawning stock biomass and/or fecundity and spawning success. However, as the survey is only made ever 3 years, the time series has been slow to grow, but now should be adequate with sufficiently good catch monitoring. Other approaches to abundance monitoring are also being developed. The information on all fishery removals from the stock is incomplete. Notably, slippage is not fully monitored and could be a significant proportion of the catch. This unobserved mortality adds considerably to the uncertainty in the stock assessment. Even if monitoring improves, the absence of the data in the historical time series will continue to undermine the assessment. There is an improving understanding of the inherent uncertainties in the information, 80 Sufficient relevant information related to stock structure, stock productivity, fleet composition and and the robustness of the assessment and management to this uncertainty. No obvious other data is available to support the harvest strategy. Stock abundance and fishery removals are environmental signals have yet been identified that should be considered in regularly monitored at a level of accuracy and coverage consistent with the harvest control rule , assessment or management in the area west of the British Isles, but oceanographic and one or more indicators are available and monitored with sufficient frequency to support the indices are monitored and are assessed for this purpose. harvest control rule. There is good information on all other fishery removals from the stock. The requirement that the fishery being certified provides all necessary information is addressed by PI 3.2.3.
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100 A comprehensive range of information (on stock structure, stock productivity, fleet composition, stock abundance, fishery removals and other information such as environmental information), including some that may not be directly relevant to the current harvest strategy, is available. All information required by the harvest control rule is monitored with high frequency and a high degree of certainty, and there is a good understanding of the inherent uncertainties in the information [data] and the robustness of the assessment and management to this uncertainty.
1.2.4 Stock assessment There is an adequate assessment of the stock status. 90 60 The stock assessment estimates stock status relative to reference points. The major sources of The assessment is appropriate for the stock and for the harvest control rule, and is WGMHSA uncertainty are identified. evaluating stock status relative to reference points. The model captures major features 2007 80 The assessment is appropriate for the stock and for the harvest control rule, and is evaluating appropriate to the biology of the species and nature of the fishery, including fish WGWIDE stock status relative to reference points. The assessment takes uncertainty into account. The stock migration, age, growth and spawning. The estimates of biomass and fishing mortality 2008 assessment is subject to peer review. are currently made annually and directly compared to target and limit reference points, 100 The assessment is appropriate for the stock and for the harvest control rule and takes into account and is appropriate for the harvest control rule. the major features relevant to the biology of the species and the nature of the fishery. The The assessment takes uncertainty into account. Key areas of uncertainty are assessed assessment takes into account uncertainty and is evaluating stock status relative to reference through simulations and projections testing the decision rule. However, the assessment points in a probabilistic way. The assessment has been tested and shown to be robust. Alternative approach could improve in terms of separate assessments for the three stocks, which hypotheses and assessment approaches have been rigorously explored. The assessment has is not currently possible as catches cannot be separated, and in terms of more robustly been internally and externally peer reviewed. coping with unrecorded mortality. However, this last problem is probably best approached through improved mortality data rather than attempting to model this additional error (see PI 1.2.3). There is a time series of recruitment and selectivity at age available from the stock assessment. Although a stock recruitment relationship has been developed, it has not been used in stock projections. The stock recruitment relationship will probably have little impact on the assessment, but if accepted it will likely affect the reference points for the spawning stock biomass (see PI 1.1.2). The potential causes of low recruitment apart from low SSB are not well understood. The stock assessment is subject to peer review through the working group process. The full working group report is published on the internet. While external review is conducted on ICES stock assessments, these reviews are not routine. There is however evidence of significant improvements in the assessment and identification of and correction of errors. There are independent assessments of uncertainty, notably unobserved mortality, through independent assessments informing the working group and the assessment.
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Fishing operations should allow for the maintenance of the structure, productivity, function and Principle 2 diversity of the ecosystem (including habitat and associated dependent and ecologically related species) on which the fishery depends
2.1 Retained species
The fishery does not pose a risk of serious or irreversible harm to the retained 2.1.1 85 Outcome Status species and does not hinder recovery of depleted retained species. 60 Main retained species are likely to be within biologically based limits or if outside the limits there The main retained species is highly likely to be within biological based limits. ICES 2008c are measures in place that are expected to ensure that the fishery does not hinder recovery and ICES 2008b rebuilding of the depleted species. The Irish RSW fishery for North East Atlantic Mackerel has very limited interaction with If the status is poorly known there are measures or practices in place that are expected to result in non-target species. The main retained species is western horse mackerel. Small the fishery not causing the retained species to be outside biologically based limits or hindering volumes of herring are also retained from time to time, mainly when vessels are fishing recovery in Area IVa. Any herring or horse mackerel landings are counted against TAC and are therefore considered in their respective assessments and management advice. 80 Main retained species are highly likely to be within biologically based limits or if outside the limits there is a partial strategy of demonstrably effective management measures are in place such that Retained catches of horse mackerel are minimal. Based on the most recent estimates the fishery does not hinder recovery and rebuilding. of SSB, ICES (2008) classifies the western horse mackerel stock as having full 100 There is a high degree of certainty that retained species are within biologically based limits. reproductive capacity. Relatively high catch rates of the 2001-year class in 2002–2006 Target reference points are defined and retained species are at or fluctuating around their target and an increase in the egg production in 2007 suggest that SSB has increased until reference points. 2005. Fishing mortality in recent years is estimated to be relatively low. However key reference points for fishing mortality for this stock have not been defined. There is no evidence to indicate that the Irish pelagic fishery for North East Atlantic Mackerel is having a negative impact on stocks of western horse mackerel. Based on the most recent estimates of SSB and fishing mortality, ICES Advice for 2008 classifies herring in Area IV as being at risk of having reduced reproductive capacity and at risk of being harvested unsustainably. Retained catches of herring are considered negligible and amounted to 10 tonnes in 2008. Of this, 9 tonnes was taken in Area IVa. Catches of herring in area IVa totaled 279,528 tonnes in 2007. The contribution to this total of herring taken in the IPSG fishery for North East Atlantic Mackerel is insignificant and the fishery is not contributing appreciably to the risks highlighted by ICES in relation to Area IV herring.
There is a strategy in place for managing retained species that is designed to 2.1.2 Management strategy ensure the fishery does not pose a risk of serious or irreversible harm to 85 retained species.
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60 There are measures in place, if necessary, tat are expected to maintain the main retained species There is a full strategy in place for managing retained species. The objectives of the IPSG pers. at levels which are highly likely to be within biological based limits, or to ensure the fishery does strategy are to assist in maintaining retained species within biologically based limits by comms not hinder their recovery and rebuilding. minimising retention of non-target species in the mackerel fishery. The measures are considered likely to work, based on plausible argument (e.g., general BIM, 2006a experience, theory or comparison with similar fisheries/species). The strategy is based on well-documented information and data in relation to the fishery and the species involved and reported landings data in relation to retained 80 There is a partial strategy in place, if necessary that is expected to maintain the main retained species provides a firm basis for confidence that the strategy is working. species at levels which are highly likely to be within biologically based limits, or to ensure the fishery does not hinder their recovery and rebuilding. Retention of non-target species does not constitute optimal use of quota. While There is some objective basis for confidence that the partial strategy will work, based on some landings are recorded against TACs they generally achieve a lower sale price. There is information directly about the fishery and/or species involved. evidence that vessels seek to minimise non-mackerel component of catches (IPSG pers. comms). Onboard Seafood Environmental Management Systems specify target There is some evidence that the partial strategy is being implemented successfully . species fishing procedures and provides for best practice in identifying shoals. The use 100 There is a strategy in place for managing retained species. of electronic equipment (dual frequency sonars) and improved communications at sea The strategy is mainly based on information directly about the fishery and/or species involved, and between vessels from EU member states that target mackerel, as well as sampling of testing supports high confidence that the strategy will work. unfished shoals using hand lines or jigging machines, has increased the ability of crews There is clear evidence that the strategy is being implemented successfully , and intended changes to distinguish mixed shoals and therefore minimise catches of non-target species. are occurring. There is some evidence that the strategy is achieving its overall objective . The National Seafood Strategy 2007-2013 (BIM, 2006a) has as a core theme the adoption of an environmentally conscious, responsible and compliant approach to all industry activities. The strategy represents national policy going forward in relation to the seafood sector in Ireland. Key recommendations of the strategy in relation to the environment include: • Recommendation 8.1 Increase awareness and response to environmental policies • Recommendation 8.2 Promote local area management strategies and the Coastal Zone Management approach. • Recommendation 8.3 Promote the introduction of Environmental Management Systems. • Recommendation 8.4 Ireland to take a lead role on Regional Advisory Councils (RACs) and the DCMNR and the industry to improve performance on conservation. • Recommendation 8.5 Develop management strategies that specifically aim to reduce discarding in fisheries. • Recommendation 8.6 Promote the development and uptake of environmentally friendly and fuel-efficient fishing gear. The retained species management strategy is being implemented successfully and all vessels now implement the Seafood Environmental Management System and engage in best practice with respect to shoal identification.
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Information on the nature and extent of retained species is adequate to 2.1.3 Information monitoring determine the risk posed by the fishery and the effectiveness of the strategy to 90 manage retained species. 60 Qualitative information is available on the amount of main retained species taken by the fishery. Information is sufficient to quantitatively estimate outcome status and support a full Information is adequate to qualitatively assess outcome status with respect to biologically based strategy to manage main retained species. Catches of horse mackerel and herring are limits. estimated to within +/- 10% tolerance and are recorded in onboard logbooks prior to landing. Retained species are fully accounted for on landing and all weights are taken Information is adequate to support measures to manage main retained species. against TACs. Systems are in place that facilitate cross checking of retained species 80 Qualitative information and some quantitative information are available on the amount of main reporting by the SFPA. Information recorded in logbooks in relation to retained species retained species taken by the fishery. is based on estimates of the haul and does not contain information in relation to Information is sufficient to estimate outcome status with respect to biologically based limits. species size or sex composition. Information is adequate to support a partial strategy to manage main retained species. Sufficient data are available to allow catch and the impact of fishing to be quantitatively Sufficient data continue to be collected to detect any increase in risk level (e.g. due to changes in estimated for main retained species. Available information is adequate to determine the the outcome indicator scores or the operation of the fishery or the effectiveness of the strategy). effectiveness of the management strategy in achieving its objective. Landings of main 100 Accurate and verifiable information is available on the catch of all retained species and the retained species are fully accounted for and are included in relevant stock assessments consequences for the status of affected populations. and fishery advice updates. The processors protocol contained in the Coastal States Information is sufficient to quantitatively estimate outcome status with a high degree of certainty . agreement and separately between DAFF and the IPSG stipulates that 100% of Information is adequate to support a comprehensive strategy to manage retained species, and landings from the North East Atlantic mackerel fishery must be weighed. evaluate with a high degree of certainty whether the strategy is achieving its objective. Monitoring of retained species is conducted in sufficient detail to assess ongoing mortalities to all retained species.
2.2 Bycatch
The fishery does not pose a risk of serious or reversible harm to the bycatch 2.2.1 Outcome Status species or species groups and does not hinder recovery of depleted bycatch 90 species or species groups. 60 Main bycatch species are likely to be within biologically based limits, or if outside such limits there The main bycatch issue is t he slippage of low value mackerel. The impacts of this WGMHSA are mitigation measures in place that are expected to ensure that the fishery does not hinder slippage are addressed under Principal 1 (unexplained mortality). 2007 recovery and rebuilding. Slippage may also occur rarely as a consequence of the presence of other species in Marine If the status is poorly known there are measures or practices in place that are expected result in the catches. Mixed species catches may reduce the potential value of landings, particularly Institute, pers. fishery not causing the bycatch species to be biologically based limits or hindering recovery. where Boarfish ( Capros aper ) may be present in catches. comms 80 Main bycatch species are highly likely to be within biologically based limits or if outside such limits The Boarfish is increasingly the target of a directed fishery in Areas VII and further FAO there is a partial strategy of demonstrably effective mitigation measures in place such that the south, where the species appears to be most abundant. Landings by Irish vessels have Fishstat+ fishery does not hinder recovery and rebuilding. grown significantly in recent years and are reported to be approximately 20,000 tonnes 2006
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100 There is a high degree of certainty that bycatch species are within biologically based limits. per annum (Marine Institute, pers. comms). Based on an analysis of FAO data, in Pinnegar et excess of 80% of the Irish mackerel TAC is taken in Area VI and north of this (FAO al. , 2002 Fishstat+ 2006). While currently unquantified, bycatch of Boarfish in directed mackerel fisheries is believed to be an infrequent occurrence and overall volumes are likely to be ICES, 2008a minimal. In the northeast Atlantic, a marked decline in mean trophic level of some fish Farina et communities over time has been documented (Pinnegar et al. , 2003), resulting in a al .,1997 reduction in the abundance of large piscivorous fishes such as cod and hake, and an increase in smaller pelagic species which feed at a lower trophic level. Since 1990 the Fock et al. , Boarfish Capros aper has become particularly abundant in French and UK survey 2002 catches (ICES, 2008a). This phenomenon has been reported as occurring elsewhere Seafood in the North Atlantic, including the Bay of Biscay (Farina et al .,1997) and offshore Environmenta seamounts (Fock et al. , 2002). There is no TAC in place and there has been no l biological assessment of Boarfish stocks to date. It is however considered highly likely Management that Boarfish are within biologically based limits and that the IPSG RSW mackerel Systems fishery does not present a significant risk of causing serious or irreversible harm to (BIM, 2008) Boarfish.
Onboard Seafood Environmental Management Systems (BIM, 2008) specify target species fishing procedures and provides for best practice in identifying shoals. The use of electronic equipment (dual frequency sonars) and improved communications at sea between vessels of all jurisdictions targeting mackerel, as well as sampling of unfished shoals using hand lines or jigging machines, has increased the ability of crews to distinguish mixed shoals and therefore minimise incidences of bycatch.
There is a strategy in place for managing bycatch that is designed to ensure the 2.2.2 Management strategy fishery does not pose a risk of serious or irreversible harm to bycatch 80 populations.
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60 There are measures in place, if necessary, which are expected to maintain main bycatch species at There is a full strategy in place for managing bycatch that is designed to achieve the BIM, 2007a levels which are highly likely to be within biologically based limits or to ensure that the fishery does bycatch outcome 80 level of performance or above. There is a clear strategy in place not hinder their recovery. for managing bycatch that may result in slippage. Clearly stated onboard procedures DAFF pers. for minimising mackerel bycatch are documented in the Seafood Environmental Comms The measures are considered likely to work, based on plausible argument (e.g. general experience, Management Strategy and an element of this includes the collection and collation of BIM, 2006a theory or comparison with similar fisheries/species). data in relation to slipped bycatch. WGMHSA The IPSG are keen to avoid slippage where possible, as this is expensive – in terms of 2007 operational costs – and detrimental to the stock, and are collectively making efforts to reduce slippage. Under the IPSG Sustainability policy, the RSW fleet has undertaken to minimise unintended bycatch, discarding and high grading through the implementation of the Seafood Environmental Management System target species fishing procedure. This is very likely to have contributed to a reduction in slippage through: • communications on the fishing grounds between vessels, including vessels from other member states, enabling the fleet to collectively avoid particular areas where bycatch is more likely to occur • investment in state of the art on-board dual-frequency sonar that enables vessels to target appropriate shoals • use of handline or automatic jigging systems to sample a mark of fish prior to shooting nets • the development of flexi grid devices aimed at increasing size selectivity in pelagic trawls through the use of flexible sorting grids. This industry led initiative, assisted by BIM, has demonstrated the potential to allow small mackerel and herring to escape (BIM, 2007a). The IPSG is actively encouraging the use of flexi-grid devices amongst its membership and many member vessels have already invested in and use this technology. Other than slippage there is no discarding. All fish that are pumped aboard into tanks are landed and verified. No onboard sorting of the catch takes place – and vessel design makes onboard sorting all but impossible. The Boarfish fishery is very new and interest in this species has grown only because its abundance has increased. The current management strategy for Boarfish is to monitor development of this fishery by collecting data in relation to landings and to limit access to the stocks to EU registered fishing vessels. Faroese interests have recently sought access to Boarfish stocks in EU waters however this was denied to the Faroese during recent EU-Faroes negotiations (DAFF pers. comms). The strategy is based on some information on the fishery and the species involved and there is an objective basis for confidence that the strategy will work. As part of the species management plan there is consensus to moving towards full reporting of bycatch that leads to slippage. There is some evidence that the management strategy is being implemented. All
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80 There is a partial strategy in place, if necessary, for managing bycatch that is expected to maintain vessels have implemented the Seafood Environmental Management System and have main bycatch species at levels which are highly likely to be within biologically based limits or to agreed to greater reporting of bycatch. ensure that the fishery does not hinder their recovery. The National Seafood Strategy 2007-2013 (BIM, 2006a) has as a core theme the There is some objective basis for confidence that the partial strategy will work, based on some adoption of an environmentally conscious, responsible and compliant approach to all information directly about the fishery and/or the species involved. industry activities. The strategy represents national policy going forward in relation to the seafood sector in Ireland. Key recommendations of the strategy in relation to the There is some evidence that the partial strategy is being implemented successfully. environment include: 100 There is a strategy in place for managing and minimising bycatch. • Recommendation 8.1 Increase awareness and response to environmental The strategy is mainly based on information directly about the fishery and/or species involved, and policies testing supports high confidence that the strategy will work. • Recommendation 8.2 Promote local area management strategies and the Coastal Zone Management approach. There is clear evidence that the strategy is being implemented successfully, and intended changes • Recommendation 8.3 Promote the introduction of Environmental are occurring. There is some evidence that the strategy is achieving its objective. Management Systems. • Recommendation 8.4 Ireland to take a lead role on Regional Advisory Councils (RACs) and the DCMNR and the industry to improve performance on conservation. • Recommendation 8.5 Develop management strategies that specifically aim to reduce discarding in fisheries. • Recommendation 8.6 Promote the development and uptake of environmentally friendly and fuel-efficient fishing gear.
Information on the nature and amount of bycatch is adequate to determine the 2.2.3 Information / monitoring risk posed by the fishery and the effectiveness of the strategy to manage 75 bycatch. 60 Qualitative information is available on the amount of main bycatch species affected by the fishery. Information is adequ ate to broadly understand outcome status with respect to SPSG, 2009 biologically based species limits and is adequate to support measures to manage Information is adequate to broadly understand outcome status with respect to biologically based bycatch. Potential impacts of bycatch on mackerel stocks are considered under limits. Performance Indicator 1. Some information is available on the amount of bycatch and Information is adequate to support measures to manage bycatch. the main species affected by the fishery. The available information has been adequate to support the introduction of bycatch minimisation measures (SEMS). However there is 80 Qualitative information and some quantitative information are available on the amount of main a lack of scientific data in relation to the scale of bycatch in the IPSG mackerel fishery bycatch species affected by the fishery. and no quantitative data have been available to the assessment team. Information is sufficient to estimate outcome status with respect to biologically based limits. Information is available on the amount of bycatch and the main species affected by the Information is adequate to support a partial strategy to manage main bycatch species. fishery and is adequate to broadly understand the impact of the fishery on main bycatch species. Sufficient data continue to be collected to detect any increase in risk to main bycatch species (e.g. due to changes in the outcome indicator scores or the operation of the fishery or the effectiveness of The fact that slippage does occur within the North East Atlantic mackerel fishery has the strategy). been recorded by the Scottish Pelagic Sustainability Group (SPSG, 2008) and this has
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100 Accurate and verifiable information is available on the amount of all bycatch and the consequences been corroborated by scientific and observer monitoring of Scottish vessels The for the status of affected populations. indications are that slippage is a minor but nonetheless persistent issue in the SPSG mackerel pelagic trawl fishery. There are many similarities between the SPSG and the Information is sufficient to quantitatively estimate outcome status with respect to biologically based IPSG mackerel fisheries. Both fisheries target North East Atlantic mackerel and there limits with a high degree of certainty . are many other technical and economic similarities in relation to the operation of both Information is adequate to support a comprehensive strategy to manage bycatch, and evaluate with fisheries. IPSG skippers have corroborated the Scottish evidence with respect to levels a high degree of certainty whether a strategy is achieving its objective. of slippage and it is therefore considered highly likely that overall levels of slippage within the IPSG are also minor but nonetheless just as persistent as slippage levels in Monitoring of bycatch data is conducted in sufficient detail to assess ongoing mortalities to all the SPSG mackerel fishery. bycatch species. Much of the evidence in relation to slippage levels is based on anecdotal evidence and evidence gathered in other pelagic fisheries. Accordingly, the impact of the fishery on the main bycatch species can only be broadly interpreted for the purposes of MSC assessment of the IPSG mackerel fishery. However, there is a clear commitment to greater recording of data in relation to slippage as per the Seafood Environmental Management System. Incidences of slippage are recorded onboard each vessel in a Slippage Log. IPSG vessels generally assess the size (length frequency) and species composition (per-centage by weight) of the bulk catch by sampling catches alongside the vessel, before a decision is made to land or slip a haul. These data are recorded and can be made available to fishery managers. The use of catch sensors on trawl nets allows for approximation of total catch in the event that a haul is slipped.
2.3 ETP species
The fishery meets national and international requirements for protection of ETP 2.3.1 Status species. The fishery does not pose a risk of serious or irreversible harm to ETP 75 species and does not hinder recovery of ETP species.
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60 Known effects of the fishery are likely to be within limits of national and international requirements The known effects are likely to be within limits of national and international BIM 2006b, for protection of ETP species. requirements for protection of ETP species and are unlikely to create unacceptable 2007 impacts to ETP species. In general, interactions between North East Atlantic mackerel Known direct effects are unlikely to create unacceptable impacts to ETP species. fisheries and ETP species are considered very limited on the basis of evidence from Ross and skippers and from limited observer programmes within Ireland (BIM 2006b, 2007). An Isaacs, 2004 extensive review of the bycatch of cetaceans in pelagic trawls was carried out for Berrow et al Greenpeace in 2004 (Ross and Isaacs, 2004). The report considered published and (1998) anecdotal information. Within the North East Atlantic the report identified mackerel and WGMHSA horse mackerel pelagic trawling southwest of Ireland as a fishery where cetacean 2007 bycatch could be documented and the number of animals caught was reported as SGBYC 2008 being low. The Sea Mammal Research Unit has also undertaken an extensive observer programme and there is a good history of cooperation with this programme by Scottish SPSG vessels. The observer programme has shown that there is no evidence of any interaction with protected, endangered or threatened species. While inferences in relation to ETP bycatch can be made from findings within the SPSG and other reports, there is a lack of data in relation to ETP species interactions with North East Atlantic mackerel fisheries of the IPSG. ETP species known to occur in the northeastern Atlantic include a wide range of cetaceans including Common dolphin, Bottlenose dolphin, Atlantic White-sided dolphin and Minke whale. Two species of seal are known from these waters also – Common or Harbour seal Phoca vitulina and Gray Seal Halichoerus grypus . Other ETP species recorded in the north-eastern Atlantic include Basking shark Cetorhinus maximus and Atlantic Bluefin tuna Thunnus thynnus . The Wildlife Act 1976 and the Wildlife Amendment Act (2000) are the main statutes governing the protection of cetaceans in Ireland. The most important international legislation is the Habitats Directive. which was transposed into Irish law through the European Communities (Natural Habitats) Regulations 1997. Under the Habitats Directive Harbour porpoise and bottlenose dolphin are listed under Annex II and all cetacean species are listed under Annex IV, identifying them for protective measures. Ireland has also ratified the Bonn and Berne Conventions and the EC Directive on the Conservation of Natural Habitats and Migratory Species and the Wildlife Amendment Act (2000) also ratifies CITES. Ireland joined the International Whaling Commission on 2 January 1985 and Chaired the IWC between 1999 and 2000. Under existing legislation and in recognition of the importance of Irish waters for cetaceans, all Irish
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80 The effects of the fishery are known and are highly likely to be within limits of national and territorial waters were declared a sanctuary for whales and dolphins on 7 June 1991. international requirements for protection of ETP species. The Sea-Fisheries (Incidental Catches of Cetaceans in Fisheries) Regulations 2007 Direct effects are highly unlikely to create unacceptable impacts to ETP species. (S.I. No. 274 of 2007) give full effect to Council Regulation (EC) No. 812/2004 which lays down measures concerning incidental catches of cetaceans in certain fisheries. Indirect effects have been considered and are thought to be unlikely to create unacceptable impacts. In 2007 the European Court of Justice ruled that Ireland had failed to implement fully and adequately several provisions of the Habitats Directive in so far as these relate to the strict protection and monitoring of cetaceans in Irish waters (Case C-183/05). In addition Ireland was ruled against for failing to collect information in relation to cetacean abundance and distribution within its 200-mile exclusive economic zone.
100 There is a high degree of certainty that the effects of the fishery are within limits of national and international requirements for protection of ETP species. There is a high degree of confidence that there are no significant detrimental effects (direct and indirect) of the fishery on ETP species.
The fishery has in place precautionary management strategies designed to: - meet national and international requirements: - ensure the fishery does not pose a risk of serious or irreversible harm to 2.3.2 75 Management strategy ETP species; - ensure the fishery does not hinder recovery of ETP species; and - minimise mortality of, or injuries to, ETP species. 60 There are measures in place that minimise mortality, and are expected to be highly likely to achieve There is a partial strategy in place for managin g the fishery’s impact on ETP species. BIM, 2006a national and international requirements for the protection of ETP species.. Under the IPSG Seafood Environmental Management System there is a commitment to BIM 2006b, The measures are considered likely to work, based on plausible argument (eg general experience, minimising incidental bycatch and greater reporting of cetacean and ETP encounters 2007 theory or comparison with similar fisheries/species). using the onboard ETP species log. In order to manage bycatch of ETP species, highly WGMHSA experienced fishing skippers are in control of fishing operations and oversee a 2007 80 There is a strategy in place for managing the fishery’s impact on ETP species, including measures generally very experienced crew, while the availability of radio communications to minimise mortality, that is designed to be highly likely to achieve national and international between pairing vessels and the rest of the fleet ensures effective communications are SGBYC 2008 requirements for the protection of ETP species. available with respect to potential ETP interactions. There is an objective basis for confidence that the strategy will work, based on some information The National Seafood Strategy 2007-2013 (BIM, 2006a) has as a core theme the directly about the fishery and/or the species involved. adoption of an environmentally conscious, responsible and compliant approach to all There is evidence that the strategy is being implemented successfully. industry activities. The strategy is the basis of national policy in relation to the
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100 There is a comprehensive strategy in place for managing the fishery’s impact on ETP species, development of the fisheries sector in Ireland going forward. Key recommendations of including measures to minimise mortality, that is designed to achieve above national and the strategy that impact on ETP are: international requirements for the protection of ETP species. • Recommendation 8.3 Promote the introduction of Environmental The strategy is mainly based on information directly about the fishery and/or species involved, and a Management Systems. quantitative analysis supports high confidence that the strategy will work. • Recommendation 8.6 Promote the development and uptake of There is clear evidence that the strategy is being implemented successfully, and intended changes environmentally friendly and fuel-efficient fishing gear. are occurring. There is evidence that the strategy is achieving its objective. The strategy is based on some information about the fishery and species involved and there is some objective basis for confidence that the strategy will work. Ireland has transposed EU Regulation 812/2004 into Irish law through SI 274 of 2007. Under Article 6 member states are required to report annually on the implementation of the regulation and the annual report must include estimates of the overall incidental catches of cetaceans in each of the fisheries concerned. Ireland has reported on two occasions in the past (BIM 2006b, 2007). Reported incidence of bycatch in pelagic mackerel fisheries are nil, however this is based on very little observer effort. The stated minimum observer programme coverage for pelagic fisheries in Area VI, VII and VIII is 10% of fishing effort between at least 3 vessels for a minimum of two years commencing January 1 st 2005.
Relevant information is collected to support the management of fishery impacts on ETP species, including: - 2.3.3 Information / monitoring information for the development the management strategy; 75 - information to assess the effectiveness of the management strategy; and - information to determine the outcome status of ETP species. 60 Information is adequate to broadly understand the impact of the fishery on ETP species. Information is adequate to broadly understand the impact of the fishery on ETP WGMHSA Information is adequate to support measures to manage the impacts on ETP species species. The manner in which pelagic mackerel fisheries interact with ETP species is (2007) Information is sufficient to quantitatively estimate the fishery related mortality of ETP species. reasonably well understood, however there is a lack of data in relation to the 80 Information is sufficient to determine whether the fishery may be a threat to protection and abundance and distribution of most ETP cetacean species in Area VIa and VII b,c and SGBYC recovery of the ETP species, and if so, to measure trends and support a full strategy to manage VIIj,k. The European Court of Justice has judged Ireland to be in breach of several (2008 ) impacts. provisions of the Habitats Directive in so far as these relate to the strict protection and Sufficient data are available to allow fishery related mortality and the impact of fishing to be monitoring of cetaceans in Irish waters (Case C-183/05). In addition Ireland was ruled BIM 2006b, quantitatively estimated for ETP species. against for failing to collect information in relation to cetacean abundance and 2007 100 Information is sufficient to quantitatively estimate outcome status with a high degree of certainty. distribution within its 200-mile exclusive economic zone.
Information is adequate to support a comprehensive strategy to manage impacts, minimize The lack of published data and observer information in relation to cetacean distribution mortality and injury of ETP species, and evaluate with a high degree of certainty whether a and abundance does not support the estimation of mortality rate and injuries for ETP. strategy is achieving its objectives. As a consequence the impact of IPSG mackerel fishery cannot be fully quantified in Accurate and verifiable information is available on the magnitude of all impacts, mortalities and relation to ETP species. injuries and the consequences for the status of ETP species.
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2.4 Habitat
The fishery does not cause serious or irreversible harm to habitat structure, 2.4.1 Status considered on a regional or bioregional basis, and function, in relation to 95 ecosystem services. 60 The fishery is unlikely to reduce habitat structure and function to a point where there would be There is evidence that the fishery is highly unlikely to reduce habitat structure and FAO 2008 serious or irreversible harm. function to a point where there would be serious or irreversible harm. Pelagic pair 80 The fishery is highly unlikely to reduce habitat structure and function to a point where there would trawling does not have any impact on the pelagic environment. ACFM 2007 be serious or irreversible harm. (Book 9) Mackerel are a pelagic fish species meaning that they are most abundant in areas of 100 There is evidence that the fishery is highly unlikely to reduce habitat structure and function to a open ocean, where they tend to aggregate in large three-dimensional shoals above the point where there would be serious or irreversible harm. seabed. Mackerel are therefore most efficiently caught using mid-water trawls, which are used to fish in the water column and there is no requirement for fishing gear to make contact the seabed in order to catch fish. It is well known that even momentary encounters with the seabed can cause extensive damage to pelagic trawls. In pair trawling (2 vessels fishing together), the entrance of the net is kept open by each vessel towing one side (port or starboard) of the net, as the vessels maintain a minimum separation distance. There is no need for the use of trawl doors (which have potential to impact the seabed if contact is made) to spread the net. Large clump weights (up to 3 tonnes) may be used to submerge a pelagic trawl and to prevent the net rising as the it is towed at speeds of up to 5 knots. Weights are suspended forward of the net on the towing bridle and can be raised and lowered using the trawl winch. Weights do not intentionally contact the seabed during fishing. A score of 100 could be achieved if results of a system to record unexpected seabed interactions were available during future MSC audits.
There is a strategy in place that is designed to ensure the fishery does not pose 2.4.2 95 Management strategy a risk of serious or irreversible harm to habitat types. 60 There are measures in place, if necessary, that are expected to achieve the Habitat Outcome 80 There is a strategy in place that is designed to achieve the habitat outcome 80 level of WGMHSA level of performance. performance or above. The strategy is based on some information directly about the (2007) fishery and/or habitats involved, and there is some objective basis for confidence that The measures are considered likely to work, based on plausible argument (e.g. general experience, the strategy will work. There is some evidence that the strategy is being implemented theory or comparison with similar fisheries/habitats). successfully (e.g. the measures in the strategy are being followed and any intended 80 There is a partial strategy in place, if necessary, that is expected to achieve the Habitat Outcome 80 changes are occurring). level of performance or above. Measures to minimise seabed/ fishing gear interactions are in place across the fleet There is some objective basis for confidence that the partial strategy will work, based on some and include: information directly about the fishery and/or habitats involved. • the use of sophisticated electronics, including depth sounders, sonars and trawl monitoring systems. Scanning sonars on all vessels reveal seabed There is some evidence that the partial strategy is being implemented successfully. depth and topography for up to 1.5 miles ahead of the vessels, meaning that
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100 There is a strategy in place for managing the impact of the fishery on habitat types. there is sufficient advance warning of changes in depth or seabed obstructions to allow altering of course or raising of the gear. Rapid changes The strategy is mainly based on information directly about the fishery and/or habitats involved, and to the depth of the net can be made directly from the wheelhouse via the testing supports high confidence that the strategy will work. winches. All vessels use trawl-monitoring sensors. Sensors are attached to There is clear evidence that the strategy is being implemented successfully, and intended changes the net and wheelhouse monitors display data in relation to the spread and are occurring. There is some evidence that the strategy is achieving its objective. height of the net opening, depth of the footrope of the net and the clearance between the footrope and the seabed. • Maintaining good radio communications between both vessels • Use of highly experienced fishing skippers As part of the management strategy, the Seafood Environmental Management System records all encounters between fishing gear and the seabed. A score of 100 could be achieved if results of a system to record fishing gear/seabed interactions were available during future MSC audits.
Information is adequate to determine the risk posed to habitat types by the 2.4.3 Information / monitoring fishery and the effectiveness of the strategy to manage impacts on habitat 90 types. 60 There is a basic understanding of the types and distribution of main habitats in the area of the The nature, distribution and vulnerability of all main habitat types in the fishery area are WGMHSA fishery. known at a level of detail relevant to the scale and intensity of the fishery. Sufficient (2007) Information is adequate to broadly understand the main impacts of gear use on the main habitats, data are available to allow the nature of the impacts of the fishery on habitat types to be including spatial extent of interaction. identified and there is reliable information on the spatial extent, timing and location of WKREF 80 The nature, distribution and vulnerability of all main habitat types in the fishery area are known at a use of the fishing gear. The physical impacts of the gear on the habitat types have been (2007) level of detail relevant to the scale and intensity of the fishery. quantified fully. Sufficient data are available to allow the nature of the impacts of the fishery on habitat types to be The distribution of habitat types within the range of the fishery, with particular attention identified and there is reliable information on the spatial extent, timing and location of use of the to the occurrence of vulnerable habitat types, are not known. Changes in habitat fishing gear. distributions over time are not measured. Sufficient data continue to be collected to detect any increase in risk to habitat (e.g. due to changes in the outcome indicator scores or the operation of the fishery or the effectiveness of the measures). The Seafood Environmental Management System will provide data in relation to frequency and spatial occurrence of seabed/fishing gear interactions. 100 The distribution of habitat types is known over their range, with particular attention to the occurrence of vulnerable habitat types. Changes in habitat distributions over time are measured. The physical impacts of the gear on the habitat types have been quantified fully.
2.5 Ecosystem
The fishery does not cause serious or irreversible harm to the key elements of 2.5.1 80 Status ecosystem structure and function. 60 The fishery is unlikely to disrupt the key elements underlying ecosystem structure and function to a The fishery is highly unlikely to disrupt the key elements underlying ecosystem ICES, 2008b point where there would be a serious or irreversible harm. WGRED
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80 The fishery is highly unlikely to disrupt the key elements underlying ecosystem structure and structure and function to a point where there would be a serious or irreversible harm. (2008) function to a point where there would be a serious or irreversible harm. The mackerel stock biomass is within the Bpa reference point, which is considered 100 There is evidence that the fishery is highly unlikely to disrupt the key elements underlying adequate to protect the fishery from overfishing. ecosystem structure and function to a point where there would be a serious or irreversible harm. Ecosystem models such as the North Sea Multi-species VPA serve as the main tool used to assess the role of mackerel as a prey species in the wider ecosystem. Outside of the North Sea, elsewhere in the range of North East Atlantic mackerel, such well-developed models do not currently exist. Sufficient information is therefore available on the impact of removal of target stocks only in certain areas – and any impact currently appears to be negligible. In less well studied areas, West of Scotland and Ireland, there do not appear to be any significant ecosystem effects of the current levels of the removal of target species, and the current level of modelling with Ecopath with Ecosim do not indicate any unacceptable impacts. The implications of future environmental change (and variable recruitment) may be less well understood. (ICES, 2008b) Pelagic trawling for mackerel does not have a direct impact on the physico-chemical characteristics of pelagic habitats. There is evidence of negligible impact on pelagic habitat structure and function and no unacceptable impacts have been demonstrated for the benthic habitats. Fishermen also report almost zero interaction with seabed – this is credible as it would cause expensive damage to pelagic fishing gear and is therefore avoided.
There are measures in place to ensure the fishery does not pose a risk of 2.5.2 90 Management strategy serious or irreversible harm to ecosystem structure and function. 60 There are measures in place, if necessary, that take into account potential impacts of the fishery on The strategy comprises management measures that take into account available ICES ACFM key elements of the ecosystem. information and scientific advice on the impacts of the fishery on ecosystems. The 2007 measures have been identified, and are considered likely to work, based on plausible ICES (2008a) The measures are considered likely to work, based on plausible argument (e.g. general experience, argument (e.g. general experience, theory or comparison with similar WGMHSA theory or comparison with similar fisheries/ ecosystems). fisheries/ecosystems). There is some evidence that the strategy is being implemented (2007) 80 There is a partial strategy in place, if necessary, that takes into account available information and is successfully (e.g. the measures in the strategy are being followed and intended expected to restrain impacts of the fishery on the ecosystem so as to achieve the Ecosystem changes are occurring). Outcome 80 level of performance. The main impact of the western mackerel pelagic trawl fishery is the depletion of the target stock biomass. This impact is assessed as part of P1. Detailed management The partial strategy is considered likely to work, based on plausible argument (e.g. general strategies, including biomass and fishing mortality reference points, are in place to experience, theory or comparison with similar fisheries/ ecosystems). monitor and regulate this impact through ICES ACOM TAC recommendations for all There is some evidence that the measures comprising the partial strategy are being implemented spawning components of the North East Atlantic mackerel stock. TACs are also set successfully. annually for Area VI herring, which are occasionally caught as bycatch in the mackerel
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100 There is a strategy that consists of a plan , containing measures to address all main impacts of the fishery. While catches of Boarfish are being monitored, no TAC is in place for this fishery on the ecosystem, and at least some of these measures are in place. The plan and species. measures are based on well-understood functional relationships between the fishery and the Components and elements of the ecosystem. Habitat impacts are reasonably expected to be negligible as the fishery is conducted primarily in the water column. This plan provides for development of a full strategy that restrains impacts on the ecosystem to ensure the fishery does not cause serious or irreversible harm. As there are so few other impacts on the wider ecosystem, there are relatively few management strategies in place. However clear waste management protocols are in The measures are considered likely to work based on prior experience , plausible argument or place on all vessels in respect of domestic refuse, oil and engine room waste and information directly from the fishery/ecosystems involved. waste fishing gear and vessels are legally required to maintain a waste oil logbook. The management strategy includes a commitment to collecting data in relation to the There is evidence that the measures are being implemented successfully. fisheries environmental performance. Accordingly, all vessels in the IPSG have implemented specific provisions of the Seafood Environmental Management System in relation to the management of ship generated waste and the maintenance of slippage, ETP interaction, gear loss and seabed interaction logs.
2.5.3 Information / monitoring There is adequate knowledge of the impacts of the fishery on the ecosystem. 90 60 Information is adequate to identify the key elements of the ecosystem (e.g. trophic structure and Information is ade quate to broadly understand the key elements of the ecosystem, ICES function, community composition, productivity pattern and biodiversity). however the relationships between mackerel and the wider ecosystem and its (2008a) Main impacts of the fishery on these key ecosystem elements can be inferred from existing quantitative role in the food web is not very well understood and there is no WGSAM information, but have not been investigated in detail . comprehensive model of the ecosystem in existence. (2007) 80 Information is adequate to broadly understand the functions of the key elements of the ecosystem. Berrow et al Mackerel feed on a variety of pelagic crustaceans and small fish including herring, (1998) Main impacts of the fishery on these key ecosystem elements can be inferred from existing sprat, sandeel and Noway Pout – particularly in the south of their range. Copepods FAO (2008) information, but may not have been investigated in detail . and Euphausids are also important components of the diet in the north. Mackerel represent an important prey for many predators, such as sea birds, marine mammals The main functions of the Components (i.e. target, Bycatch, Retained and ETP species and and sharks. Habitats) in the ecosystem are known . Main impacts of the fishery on these key ecosystem elements can be inferred from Sufficient information is available on the impacts of the fishery on these Components to allow some existing information, but have not have been investigated in detail. of the main consequences for the ecosystem to be inferred. The impacts of the fishery on target, bycatch, retained, ETP, habitats are identified Sufficient data continue to be collected to detect any increase in risk level (e.g. due to changes in and the main functions of these components in the ecosystem are known. Sufficient the outcome indicator scores or the operation of the fishery or the effectiveness of the measures). information is available on the impacts of the fishery on these components to allow
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100 Information is adequate to broadly understand the key elements of the ecosystem. some of the main consequences for the ecosystem to be inferred. Main interactions between the fishery and these ecosystem elements can be inferred from existing Levels of knowledge in relation to the impacts of the fishery on the ecosystem information, and have been investigated . components should improve overtime as more data become available, largely through improved onboard documentation and recording as well as through observer The impacts of the fishery on target, Bycatch, Retained and ETP species and Habitats are identified programmes. and the main functions of these Components in the ecosystem are understood . Sufficient information is available on the impacts of the fishery on the Components and elements to allow the main consequences for the ecosystem to be inferred. Information is sufficient to support the development of strategies to manage ecosystem impacts.
The fishery is subject to an effective management system that respects local, national and Principle 3 international laws and standards and incorporates institutional and operational frameworks that require use of the resource to be responsible and sustainable.
3.1 Governance and policy
The management system exists within an appropriate and effective legal and/or customary framework that: • Is capable of delivering sustainable fisheries in accordance with MSC Principles 1 & 2 3.1.1 Legal and customary framework 90 • Observes the legal rights created explicitly or by custom of people dependent on fishing for food and livelihood, and • Incorporates an appropriate dispute resolution framework. 60 The management system is generally consistent with local, national or international laws or The management system – both at EU and national level – is subject to law, observes EC (2371/2002) standards that are aimed at achieving sustainable fisheries in accordance with MSC Principles 1 and the legal and cultural rights of fishers and includes transparent mechanisms for 2. dispute resolution. All of this is conducted in a manner that is consistent with the WGWIDE 2008 objectives of MSC principles 1 and 2. Irish Gov Sea The management system incorporates or is subject by law to a mechanism for the resolution of legal At National Level, the Irish Government’s Sea fisheries and Management Jurisdiction disputes arising within the system. Fisheries and Act (2006) forms the basis for the implementation of the reformed EU Common Jurisdication Although the management authority or fishery may be subject to continuing court challenges, it is not Fisheries Policy. (2371/2002). The act establishes: Act 2006 indicating a disrespect or defiance of the law by repeatedly violating the same law or regulation • Licensing procedures necessary for the sustainability for the fishery. • Monitoring, control and surveillance procedures – formed the legal The management system has a mechanism to generally respect the legal rights created explicitly or platform the establishment of the Sea Fisheries Protection Agency st established by custom of people dependent on fishing for food or livelihood in a manner consistent (which came into force on 1 January 2007) end established the powers with the objectives of MSC Principles 1 and 2. to inspect throughout the supply chain.
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80 The management system is generally consistent with local, national or international laws or • Penalty procedures standards that are aimed at achieving sustainable fisheries in accordance with MSC Principles 1 and • Right of Appeal 2. Although the Sea Fisheries Jurisdiction Act (2006) includes a provision for an appeals The management system incorporates or is subject by law to a transparent mechanism for the officer, it is understood that this is still to be implemented, therefore it cannot be stated resolution of legal disputes which is considered to be effective in dealing with most issues and that is that the system has been tested and proven to be effective, however the mechanisms appropriate to the context of the fishery. of the district court would apply for minor infringements and these have been well tested and proven to be transparent and equitable. The management system or fishery is attempting to comply in a timely fashion with binding judicial A clear legal framework also exists for judicial decisions to be appealed against both at decisions arising from any legal challenges. national, and if necessary EU level. The European Court of Justice is the jurisdictional The management system has a mechanism to observe the legal rights created explicitly or institutional monitoring the observance of community law and the interpretation and established by custom of people dependent on fishing for food or livelihood in a manner consistent the application of European Treaties. Its areas of competence cover disputes between with the objectives of MSC Principles 1 and 2. member states, disputes between the Union and the member states, between the institutions and between private individuals and the Union (European Court of 100 The management system is generally consistent with local, national or international laws or Justice).Any binding decisions arising are complied with in a timely fashion. standards that are aimed at achieving sustainable fisheries in accordance with MSC Principles 1 and The system of industry representation (all RSW vessels are members of POs and 2. represented at the Pelagic RAC) and cooperation with managers (referred to later in The management system incorporates or is subject by law to a transparent mechanism for the P3) enables a proactive approach to be taken to avoid legal disputes. resolution of legal disputes that is appropriate to the context of the fishery and has been tested and proven to be effective . The management system or fishery acts proactively to avoid legal disputes or rapidly implements binding judicial decisions arising from legal challenges. The management system has a mechanism to formally commit to the legal rights created explicitly or established by custom on people dependent on fishing for food and livelihood in a manner consistent with the objectives of MSC Principles 1 and 2.
The roles and responsibilities of organisations and individuals who are involved in the management process are clear and understood by all relevant 3.1.2 85 Consultation, roles and responsibilities parties. The management system has effective consultation processes that are open to interested and affected parties. 60 Organisations and individuals involved in the management process have been identified. Organisations and individuals involved in the management process have been EC (2371/2002) Functions, roles and responsibilities are generally understood . identified. Functions, roles and responsibilities are explicitly defined and well The management system includes consultation processes that obtain relevant information from the understood for all areas of responsibility and interaction. The management system WGWIDE 2008 main affected parties, including local knowledge, to inform the management system. also includes consultation processes that regularly seek and receive relevant Irish Gov Sea 80 Organisations and individuals involved in the management process have been identified. information, including local knowledge. Fisheries and Functions, roles and responsibilities are explicitly defined and well understood for key areas of There is clear and evident division of responsibility between EU, ICES and national Jurisdication responsibility and interaction. institutions and authorities. Act 2006 The management system includes consultation processes that regularly seek and accept relevant information, including local knowledge. The management system demonstrates consideration of The North East Atlantic mackerel fishery is managed through the Common Fisheries the information obtained. Policy of the EU in accordance with the basic fisheries regulation (2371/2002) and the The consultation process provides opportunity for all interested and affected parties to be involved.
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100 Organisations and individuals involved in the management process have been identified. Coastal States agreement – a negotiated international agreement setting boundary Functions, roles and responsibilities are explicitly defined and well understood for all areas of rules by which annual setting of TAC’s and quotas may be achieved. responsibility and interaction. The management system includes consultation processes that regularly seek and accept relevant The core backdrop to the management of this fishery is the advice provided by the information, including local knowledge. The management system demonstrates consideration of ICES Advisory Committee (ACOM) which draws on the on-going work of international the information and explains how it is used or not used . scientists from relevant research laboratories and institutions (including the Marine The consultation process provides opportunity and encouragement for all interested and affected Institute in Ireland) on the stock biology and marine science through the mackerel parties to be involved, and facilitates their effective engagement. working group (WGMHSA). At the national level, national fisheries administrations and industry bodies (DAFF, Marine Institute, SFPA & BIM) are responsible for a range of management and regulatory duties, including management of fleet activity, management of national quota, monitoring and control of all fisheries occurring within national jurisdiction, collection, collation and transmitting of key fishery data, and undertaking at least a base range of scientific monitoring and development work. In all cases their functions, roles and responsibilities are explicitly defined and well understood There is effective industry representation through the Producer Organisations, which are in turn members of the Federation of Irish Fishermen (FIF). Industry representatives from each of the POs are represented at the Pelagic Regional Advisory Council (RAC), which has contributed to much improved industry / management / science communication and consultation, since the 2002 revision of the CFP. In the opinion of the assessment team, there does however remain some scope for improving the transparency within the management system to demonstrate how industry opinions, concern and information is used or not used.
The management policy has clear long-term objectives to guide decision- 3.1.3 Long-term objectives making that are consistent with MSC Principles and Criteria, and incorporates 90 the precautionary approach. 60 Long-term objectives to guide decision-making, consistent with MSC Principles and Criteria, and The are examples at all tiers of management of the North East Atlantic mackerel fishery EC the precautionary approach, are implicit within management policy. to indicate that decision-making must pursue explicit long term objectives, that are (2371/2002) 80 Clear long-term objectives that guide decision- making, consistent with MSC Principles and consistent with MSC Principles and Criteria, and to take a precautionary approach. ICES 9.4.2 Criteria, and the precautionary approach, are explicit within management policy.
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100 Clear long-term objectives that guide decision-making, consistent with MSC Principles and Criteria The reformed CFP aims to improve the basis of the decision-making process through (2008) and the precautionary approach, are explicit within and required by management policy. sound and transparent scientific advice and increased participation of stakeholders. The Common Fisheries Policy is designed to ensure sustainable exploitation of living aquatic resources, through the application of a precautionary approach to protect and conserve living aquatic resources, and to minimise the impact of fishing activities on marine eco-systems. It shall aim at a progressive implementation of an eco-system- based approach to fisheries management. It shall aim to contribute to efficient fishing activities within an economically viable and competitive fisheries and aquaculture industry, providing a fair standard of living for those who depend on fishing activities and taking into account the interests of consumers. At the coastal states level management of the fishery is based upon a clear harvest control rule (as assessed under P1). This clearly outlines specific management objectives (in the form of appropriate reference points) with regard to fishing mortality and Spawning Stock Biomass. This has been agreed by all parties, and has been evaluated by ICES as being in line with the precautionary approach. At National level, the Irish Government Policy, as well as promoting sustainable fishing and the precautionary approach, also includes a clear commitment to s long term social objectives, to support the sustainable development of the Irish rural economy.
The management system provides economic and social incentives for 3.1.4 Incentives for sustainable fishing sustainable fishing and does not operate with subsidies that contribute to 75 unsustainable fishing. 60 The management system provides for incentives that are consistent with achieving the outcomes The management system encourages incentives that facilitate and promote the EC expressed by MSC Principles 1 and 2. achievement of the outcomes expressed by MSC Principles 1 and 2, and seeks to (2371/2002) 80 The management system encourages incentives that are consistent with achieving the outcomes ensure that negative incentives do not arise expressed by MSC Principles 1 and 2, and seeks to ensure that negative incentives do not arise.
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100 The management system provides for incentives that are consistent with achieving the outcomes Since the 2002 revision of the CFP, subsidies that contribute to unsustainable fishing expressed by MSC Principles 1 and 2, and explicitly considers incentives in a regular review of have stopped. There is no support to increase capacity, or to compensate for low management policy or procedures to ensure that they do not contribute to unsustainable fishing catches. The industry does not pay directly for management or science therefore there practices. are possible sources of effective subsidy, albeit the fishery has passed in this case. Some NGOs have in the past questioned whether development support through the EC’s structural funding mechanisms to the fishery sector –the European Fisheries Fund (EFF) – constitutes continuing subsidy to the sector, but funding restrictions have been tightened with the last round of structural funding to ensure this is not the case. Other assistance is available to the fleet through national funding, in the form of BIM. However, all assistance identified by the team contributed to increased sustainability – for example through trialling separator grids to prevent the capture of juveniles, or in the development of on-board Environmental Management Systems. A preferential tax system is applied to diesel across all EU primary production sectors, which could be considered a subsidy relative to other economic sectors, but this is difficult to argue for fisheries as a whole as European countries apply a far higher level of taxation on fuel than any other economic block in the world (with the exception of Japan). No detrimental subsides, which contribute to unsustainable fishing practices have been identified for this fishery. Excess capacity (tonnage or VCUs) within a fleet has been described as an incentive to over-fish, in order to finance over-capitalisation. Undoubtedly, there is a large capacity, relative to the quota availability, within the Irish RSW fleet – illustrated by the fact that vessels can typically catch their full quota allocation within a relatively short fishing season at the start and end of the year. However, it is legitimately argued that new MCS systems ensure this does not lead to overfishing. Additionally, it is argued that large tonnage vessels are required to safely fish the northerly fishing grounds in the winter months. As there is no system of transferring quota allocations between vessels there is no incentive to reduce capacity – although this does maintain employment. It is therefore assumed, as an on-going requirement of MSC assessment, that the capacity within the Irish RSW fleet will remain the same or contract over time.
3.2 Fishery specific management system
The fishery has clear, specific objectives designed to achieve the outcomes 3.2.1 90 Fishery specific objectives expressed by MSC’s Principles 1 and 2. 60 Objectives , which are broadly consistent with achieving the outcomes expressed by MSC’s Short term objectives, within the management system are principally in the form of a ICES 9.4.2 Principles 1 and 2, are implicit within the fishery’s management system. TAC. This is set at the coastal states agreement and divided according to a principle (2008) 80 Short and long term objectives , which are consistent with achieving the outcomes expressed by of relative stability. These short term objectives in turn contribute to the longer term MSC’s Principles 1 and 2, are explicit within the fishery’s management system. management objectives identified in the agreed coastal states management plan
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100 Well defined and measurable short and long term objectives , which are demonstrably consistent (referred to in P1). These are clearly identified as target F and SSB. The quality and with achieving the outcomes expressed by MSC’s Principles 1 and 2, are explicit within the appropriateness of these reference points has improved in 2008. fishery’s management system. In the short term there appears to be a new management pressure which is yet to be resolved – namely the fishing by Iceland of the shared stock. It appears that there is every intention to bring Iceland into the coastal states management, although it is not yet clear how this will be resolved. This will be an important issue to examine during surveillance visits.
The fishery-specific management system includes effective decision-making 3.2.2 80 Decision-making processes processes that result in measures and strategies to achieve the objectives. 60 There are informal decision-making processes that result in measures and strategies to achieve There are established decision-making processes that result in measures and NEAFC the fishery-specific objectives. strategies to achieve the fishery- specific objectives. These use the precautionary 2008 Decision-making processes respond to serious issues identified in relevant research, monitoring, approach (see 3.1.3) and are based on best available information. evaluation and consultation, in a transparent, timely and adaptive manner and take some account of the wider implications of decisions. Clear explanations are provided in a transparent form, reflecting the outcome of monitoring, evaluation and review – in particular in the advisory work of ICES, which 80 There are established decision-making processes that result in measures and strategies to forms the principle source of information for management decisions. achieve the fishery- specific objectives. Decision-making processes respond to serious and other significant issues identified in relevant The principle management decision-making takes advice at the annual coastal states research, monitoring, evaluation and consultation, in a transparent, timely and adaptive manner meeting – this year held at NEAFC headquarters in London in October 2008. Decisions and take account of the wider implications of decisions. taken at this meeting have not always been strictly in line with the scientific advice – for Decision-making processes use the precautionary approach and are based on best available example in 2003 the TAC agreed at this meeting was roughly 8% higher than the information. scientific advice – however this has been much improved in recent years, suggesting Explanations are provided for any actions or lack of action associated with findings and relevant that best available information, relevant research and review are taken on-board.. recommendations emerging from research, monitoring, evaluation and review activity. 100 There are established decision-making processes that result in measures and strategies to The exact details of the decision making process which is used at the coastal states achieve the fishery-specific objectives. meeting is not always clear. Accounts of the meeting can be made available, but this Decision-making processes respond to all issues identified in relevant research, monitoring, falls short of formal reporting to all interested stakeholders in a way which describes evaluation and consultation, in a transparent, timely and adaptive manner and take account of how the management system responded to findings and relevant recommendations the wider implications of decisions. emerging from research, monitoring, evaluation and review activity. It should also be Decision-making processes use the precautionary approach and are based on best available noted that the management plan is not ratified by all countries which exploit NEA information. mackerel (Iceland). Formal reporting to all interested stakeholders describes how the management system responded to findings and relevant recommendations emerging from research, monitoring, evaluation and review activity.
Monitoring, control and surveillance mechanisms ensure the fishery’s 3.2.3 90 Compliance and enforcement management measures are enforced and complied with. 60 Monitoring, control and surveillance mechanisms exist and are implemented in the fishery under A comprehensive, sophisticated and robust system of monitoring, control and Irish Gov Sea assessment and there is a reasonable expectation that they are effective. surveillance is in place for the Irish RSW mackerel fishery. In the past it is recognised Fisheries and Sanctions to deal with non-compliance exist and there is some evidence that they are applied. that MCS has been insufficient but with the advent of the Sea Fisheries and Jurisdication Fishers are generally thought to comply with the management system for the fishery under Jurisdiction Act (2006) and the subsequent formation of the Sea Fisheries Protection Act 2006 assessment, including, when required, providing information of importance to the effective Agency, a substantial change has occurred and today there are significantly more SFPA pers management of fishery. fishery control officers, more sophisticated and strategic targeting of vessels, comms.
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80 A monitoring, control and surveillance system has been implemented in the fishery under improved coordination with the Irish Naval Service and, above all, 100% monitoring of assessment and has demonstrated an ability to enforce relevant management measures, landings. This has led to a sea change in industry attitude. Further improvements are strategies and/or rules. expected in the short term with the advent of electronic log books and quayside Sanctions to deal with non-compliance exist, are consistently applied and thought to provide CCTV. effective deterrence. A new system of sanctions to deal with non-compliance also exists. These are Some evidence exists to demonstrate fishers comply with the management system under consistently applied and demonstrably provide effective deterrence. It is notable that assessment, including, when required, providing information of importance to the effective no system of administrative penalties exist in Ireland, and all infringements lead to management of fishery. criminal proceedings. There is no evidence of systematic non- compliance. In consultations with senior SFPA officials it was stated that “hand on heart there is 100 A comprehensive monitoring, control and surveillance system has been implemented in the no way they could be cheating” – this can be interpreted as a high degree of fishery under assessment and has demonstrated a consistent ability to enforce relevant confidence that fishers comply with the management system under assessment. management measures, strategies and/or rules Sanctions to deal with non-compliance exist, are consistently applied and demonstrably provide effective deterrence. There is a high degree of confidence that fishers comply with the management system under assessment, including, providing information of importance to the effective management of fishery. There is no evidence of systematic non-compliance.
The fishery has a research plan that addresses the information needs of 3.2.4 85 Research plan management. 60 Research is undertaken, as required, to achieve the objectives consistent with MSC’s Principles ICES establishes study groups based on information requirements identified by WGWIDE 1 and 2. national delegates, including through industrial representations. Members of various 2008 Research results are available to interested parties. ICES Working Groups focused on such elements as climate change, plankton, multi- 80 A research plan provides the management system with a strategic approach to research and species fisheries (ecosystem), etc. all review research, identify research requirements reliable and timely information sufficient to achieve the objectives consistent with MSC’s and undertake appropriate work. There is good communication between Working Principles 1 and 2. Groups (via ACOM), and between researchers through their specialist interests. Research results are disseminated to all interested parties in a timely fashion.
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100 A comprehensive research plan provides the management system with a coherent and strategic Research / investigation is undertaken in relation to specific requirements, which approach to research across P1, P2 and P3, and reliable and timely information sufficient to generally come from the recommendations of the Stock Assessment Working achieve the objectives consistent with MSC’s Principles 1 and 2. Group.Members of the ICES community keep abreast of developments within the Research plan and results are disseminated to all interested parties in a timely fashion and are scientific community of relevance to the fishery under consideration. This ICES widely and publicly available . community is wider than Europe and includes relevant research elsewhere. Research contracts are let to other organisations, including Universities, (e.g. through the EC) to supplement scientific understanding relevant to the fishery and related ecosystem. The Irish Marine Institute is an integral player in this research community, contributing significant resources and expertise to relevant research. A considerable fund of relevant knowledge has been accumulated, over thirty years, from targeted research projects related to the triennial egg surveys (which the Irish Marine Institute is involved in). In this context the life history knowledge related to NEA mackerel is second to none. The information on fecundity, atresia, egg development, condition, maturity and the distribution of juveniles has all been carefully targeted at a better understanding of key life history stages. There are also the results of tagging studies and genetic studies clearly targeted at understanding stock identity and migration patterns. The results of relevant ICES research is disseminated to all interested parties in a timely fashion and are widely and publicly available.
There is a system for monitoring and evaluating the performance of the fishery- 3.2.5 Monitoring and evaluation specific management system against its objectives. There is effective and 75 timely review of the fishery-specific management system. 60 The fishery has in place mechanisms to evaluate some parts of the management system and is Monitoring subject to occasional internal review. There is a comprehensive system of monitoring of information relevant for 80 The fishery has in place mechanisms to evaluate key parts of the management system and is management decision-making and stock assessment purposes. The monitoring subject to regular internal and occasional external review. programme in place principally focuses on landings from the fishery, i.e quota uptake.
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100 The fishery has in place mechanisms to evaluate all parts of the management system and is Due to the systems described in 3.2.3 this monitoring now forms a substantially more subject to regular internal and external review. accurate reflection of actual fishing mortality. Additional monitoring is also in place to provide sufficient information to support stock assessment purposes (for example length / weight monitoring). High quality, well-documented procedures exist to reduce harvest in light of monitoring results. These can be quickly implemented (near real-time recording of catch levels and quota uptake – and annual review of stock status). The CFP system allows the Commission to make a proposal to the Council for an immediate (in-year) reduction in quota. This system has been used previously for NEA mackerel in 2005 and has allowed for rapid recovery to specified levels. In addition both the Commission and national administrations have fast track closure procedures available. Review At EU level, the overarching CFP management system is subject to review. Resulting policies, operational plans and practices are subject to wide consultation before ratification, and prescribed monitoring and evaluation processes after ratification. These systems also include formal consultation and review processes involving all EC Member State fisheries administrations, and committees such as: • ACOM (the body through which ICES provides formal advice), • STECF (the committee by which the European Commission seeks expert opinion on fisheries), • ACFA (the EC Advisory Committee on Fisheries and Aquaculture) dealing with industry concerns at a European / “horizontal” level. ICES working group stock assessments are also subject to external review. ICES engage external scientists to undertake extensive review of its methodologies if considered necessary, but this has not been deemed necessary for the NEAn mackerel fishery. There is an implicit and incidental level of on-going review as a result of regular discussion, meetings and negotiation between a wide range of stakeholders. For example the Pelagic RAC, where a range of interested stakeholders come together, also provides some element of review. The principle weakness of the monitoring programme in place for this fishery is the relatively low observer coverage at sea – in particular to focus on those aspects covered in Principle 2, but additionally in corroborating management information. A condition is therefore applied to this performance criteria, although this is linked to conditions applied under P2
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IPSG Western mackerel pelagic trawl fishery
Appendix 4 – Peer review reports Peer Reviewer A General The report is well structured and easy to understand and follow particularly in relation to the clear reference of the text to specific performance indicators in the scoring. Most of my comments in relation to the narrative of the report are minor with what I hope are helpful suggestions for change. The report does suffer from a lack of relevant supporting diagrams which would be particularly helpful to the non-specialist reader. It would also serve to make the report much more interesting and informative for everyone. I will identify some suggested places where these could be added in my specific comments on the text. I do have more issues of substance when it comes to the scoring and scoring comments. In particular the justification for the scores would be more easily followed if the Assessment Team (AT) had specifically referred to which elements of the scoring guideposts had been achieved or partially achieved. In my opinion this is an implicit requirement under the new Fisheries Assessment Methodology guidelines produced by the MSC, which have not been strictly followed. You do note that from 2008 the ICES Working Group dealing with the NEA mackerel assessment has changed to the new WG on widely distributed stocks, WGWIDE. However there are a number of instances in the text and in the scoring comments where you have continued to refer to the 2008 WG as WGHMSA. These need to be checked and changed. FCI: Comment addressed. 1. Introduction This is a helpful exposition of what the report intends to achieve and the standard and style of the report in the context of the broad spectrum of potential readership. It makes clear that the process is one of ‘audit’ and that the resultant report is not a scientific paper underpinned by research, but an audit report. As the AT state there is a challenging balance to strive for without alienating any of the readership. That balance could have been better achieved with more illustrations. 2. The Fishery 2.2 The fishery and the composition of the fleet to be included in the certification is clearly defined. This is important and I will refer again to it in relation to Condition 5 which I regard as unnecessary. The members of the IPSG are required to conform to the guidelines and policies listed here. Are they required to formally sign up to and agree to abide by these policies or is it currently an informal arrangement? What is the record of compliance, how is it monitored and what if any are the sanctions for non-compliance? FCI: BIM have indicated that they intend to make the system fully accredited. It is too early to state what the record of compliance is but this will be a significant focus of surveillance visits. 2.3. Under gear description, do any of the mid-water trawls use a kite type device to maintain headline height and thus net gape? It would also be interesting to note the speed at which these trawls are normally towed. FCI: Further text added on kites and towing speed. The description of the fleet to be certified is also relevant to my comments later in relation to Condition 5. 2.4. The map in this section is pretty but adds nothing to the report in terms of understanding the distribution of mackerel in the North Atlantic. Apart from the poor format it has no key Food Certification International Public Comment Draft Report 81
IPSG Western mackerel pelagic trawl fishery therefore the colours are meaningless. There are much better pictures of the distribution and spawning areas of mackerel available to the AT and they should use one of them in place of this one. FCI: Diagram changed, and ICES diagram also added. The AT should note that ICES not only ‘regards the North Sea component as existing’ but its existence is confirmed by the triennial egg surveys which regularly locate spawning clearly confined to the old central North Sea spawning grounds. Spawning in the North Sea is also well separated both temporally and spatially from the western and southern components. FCI: Text amended to reflect reviewer’s comments In the context of the long varied and interesting history of mackerel fisheries in the North East Atlantic I found this whole section rather bland and uninteresting. Without making the report too long there is much more that could be said about the biology of the species and life history of mackerel which would be of interest to all the readership. Similarly the chequered history of the mackerel fisheries makes interesting reading and should be included here with some supporting Figures. This could include the expansion of purse seining related to the development of the power block, the subsequent collapse of the North Sea fishery and the eventual rise of the klondyke fishery in western waters. FCI: Although interesting, this historical information is not directly relevant to the assessment or the scoring of the fishery, and therefore, in the interest of brevity, is not included. 3. Target Stock Status and Harvest Controls. 3.1 Status of the stock In para. 2 you should explain that the 12% upward revision of the 2007 egg survey estimate was because the provisional estimate, demanded by the WG in 2007, was made shortly after the surveys had been completed and before all the relevant data, eg fecundity, atresia and maturity data had been fully analysed and verified. FCI: Appropriate text has been added. In para. 3 It would be useful just to note exactly what an F of 0.15 / 0.25 / and 0.42 mean in terms of the % of the specified age groups removed or surviving, annually. It is easier for the non specialist reader to understand the impact of fishing mortality if explained in that way rather than what is in effect the negative of the natural logarithm of the proportion of fish surviving fishing in a year. FCI: While to an extent this is true, it can become even more confusing in our opinion if the units are changed. The exploitation rate is reported as F in all literature and we do not feel it is appropriate to change this. Reporting percentage can also be misleading without taking account of natural mortality. In para. 5 It might be worth mentioning here that, with a high proportion of the NEA mackerel fisheries either MSC certificated or under assessment for certification, the performance / behaviour of these fleets, in terms of compliance with all regulations, should show a marked improvement. FCI: While hopeful, this is a presumption that we would prefer not to make at this stage. Figure 3 is not good and the caption accompanying it is poor. Most of that caption should be in the text somewhere, in particular the explanation of the change in status of the triennial egg survey. To mention this in a text caption without a full explanation of the reasons for the change is unsatisfactory. The Figure is typical of one straight from the assessment WG statistical package output and will only really be understood by those involved in the assessment process. Personally I think that the retrospective performance of the assessment in terms of SSB is better presented in table form in a report of this nature. All the relevant data, to produce that Table, are available in the WG reports.
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A Figure showing the historic SSB back to around 1980 should be included in this section. You should also move Figure 4 into this section and refer to it accordingly. You should include the whole time series back to 1977 for the egg survey as it has been such a robust measure of stock status and so important in the historic management of the western component. FCI: While we agree the technical aspects of this point are difficult to follow, the issue is important background to the stock assessment and its reliability. We do not believe a table would make it easier to understand and we were unable to find such a table in the WGWIDE 2008 report. While the quality of the figure is not excellent, it is readable. The caption has been improved, linked to text in the report and moved to the stock assessment section. Figure 4 has been moved to the section dealing with the egg survey. The egg survey data further back do not appear to have been used in the stock assessment and were not available from the WGWIDE 2008 report. 3.2 Reference points Your definition of Bpa, with which I agree, makes it a ‘target reference point’, namely a point which management recognises as the level below which the stock should not fall. A trigger reference point would be appropriate if the stock was being managed below this point (as in the case of North Sea herring at present) in which case the ‘trigger point’ would represent a level above which F could be increased. FCI: No, it is not a target reference point, which is the point around which the stock should be maintained. There is no target reference point but there is a target region. However, we agree that ICES handling of various points is not as clear as it could be. 3.3 Rebuilding status You should mention here that one of the important factors responsible for the recent increase in SSB has been the recent good year classes in particular the 2002 year class. In doing so you should refer to a Figure showing the historic pattern of year classes back to 1972. That Figure can either be in this section or in section 3.7 stock assessment. FCI: Text has been added. 3.4 Harvest strategy In para. 1 you should make it clear that discarding as slippage is mainly a feature of the purse seine fisheries. You should also clarify here that discarding is not illegal, other than in the Norwegian sector, and that it does not have to be recorded. FCI: Without better observer coverage, we are not comfortable allocating mortality due to slippage to any particular fleet. The Icelandic catch problem is not one to be dismissed in a single sentence. In 2008 they took over 100,000t in an unregulated area which was not part of the TAC allocation. Furthermore they have already declared an intention to take an even bigger unregulated catch in 2009. This major concern needs to be reflected in the scoring comments. This also affects the tone of the comments about the control of the TACs in paragraphs 2 and 5. FCI: Some changes have been made to the text. It is necessary that Iceland TAC be integrated into the overall management control and we are understand that negotiations are planned. The text has been amended to reflect this issue a little better, however this issue is being addressed by the management authority and will be monitored during the surveillance visits. If the European TAC is set ignoring what Iceland plans to catch, clearly it will be impossible to meet the target fishing mortality. Para.8 Again you should note that most of the slippage is by purse seiners. FCI: See comment above. Para. 12. Another opportunity to refer to the Figure showing recruitment back to 1972, and much more explicit than simply saying that the stock currently shows increased recruitment Food Certification International Public Comment Draft Report 83
IPSG Western mackerel pelagic trawl fishery variability. You should also consider putting the stock and recruitment scatter plot in here and explaining it. FCI: This level of detail is addressed by the stock assessment reports available over the internet. In our view, this level of detail is moving out of the scope of this report. Table 3, at the end of this section, should have the actual F as the last column. This is a very important omission from this Table. FCI: Estimated fishing have been added, but it should be noted these are not provided in the management suggesting that these are not used as an indicator of management performance. It does suggest that fishing mortality target is being exceeded. 3.6 Information monitoring Para.2. In section 2.1 you describe the unit of certification covering the whole range of the NEA mackerel stock. In this paragraph you have confined the fishery to ICES Sub-areas IV, V, VI &VII. Principle 1 concerns the whole distribution area in any case and administratively the certification would almost certainly have to do the same. FCI: The unit of certification refers to the catches to which this certification applies. Para. 4. The species is actually ‘highly migratory’ rather than ‘relatively migratory’. Tagging has shown movement of individuals from southern Biscay to the Norwegian Coast. FCI: We do not believe that this species is classified as “highly migratory” and would prefer not to use this term. Total catch In para.1 add a final sentence “Such area misreporting threatens the recovery of the North Sea component”. FCI: Text added as suggested. Para. 2. You should mention the most recent North Sea egg survey describing the results and the current estimate of SSB. FCI: A sentence has been added under the abundance index section. Discarding of mackerel in herring fisheries is reported as extremely low (HAWG, 2008). FCI: Text has been added. Abundance index The triennial egg survey dating back to the first in 1977, deserves better coverage in terms of the narrative in this section. The Survey over the years has been a major success story in terms of international cooperation both in planning and execution of the surveys. As a consequence the survey has provided a robust fishery independent estimate of SSB for over thirty years. The survey has also generated a wealth of research work related to the biology of mackerel, all carefully targeted at improving the precision of the SSB estimate. Such research is very relevant to the scoring comments and score in performance indicator 3.2.4. It is also worth noting that the survey is also used for horse mackerel stock assessment and has been used for specific projects on other species such as hake and sardine. FCI: While no doubt the egg survey is valuable as a research tool, it is less clear that it is a good abundance index. Use of the index as an absolute measure gave very poor assessment results: the survey updates only every three years, the working group appears to have little faith in estimates prior to 1992 and the index itself offers little contrast for the assessment (See Fig. 3 in the report). The level of detail suggested here is outside the scope of this report. 3.7 Stock Assessment I have no problem with the content of this section but oh for some illustrations!! A picture paints a thousand words and how dull this section is without them. I suggest Figures for the historic landings data, recruitment pattern, fishing mortality (could be superimposed on the landings
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IPSG Western mackerel pelagic trawl fishery data) and historic SSB if not already inserted elsewhere. FCI: Two illustrations have been moved close to this section. 4. Environmental elements 4.1. Slipping The skippers suggestion / observation re. the possibility that survival of slipped fish appears to be high is entirely related to ‘lightly pursed’ catches from which the fish are seen to swim away. As far as pelagic trawls are concerned the slippage mortality is almost certainly 100% because the fish have been compacted together in the codend and thus irreversibly damaged. FCI: Text amended to clearly reflect that slippage results in substantial (in effect total) mortality. 5. Administrative context 5.2. Roles and responsibilities Scientific advice Move the last sentence of the penultimate paragraph, about the WG change from WGMHMSA to WGWIDE, to the start of this section. You could also mention the other stocks now covered by the same WG to help explain the logic for the change. FCI: Amended as suggested. 5.3. Monitoring control and surveillance. It would be useful to explain more detail of the port weighing procedures for catches pumped ashore from RSWs. This is not obvious to the general reader, and it is also different in different countries. You should also explain the accuracy and precision of the procedure and how water content is taken into account. This is an area where as much as a 10% difference in the catch / landings data can occur legally. FCI: Amended as suggested. 5.4. Compliance This is an honest assertion of the problems which have occurred in the recent past and how management has tackled them. It is good to see this information clearly explained in the report. 6. Background to the evaluation It is clear that the AT have met and consulted with a wide and appropriate range of stakeholders. As a result all the relevant issues have been addressed in the report and scoring. 6.6. A minor point but there is one of the instances where the 2008 WG report is referred to as WGMHMSA instead of WGWIDE – there are others! FCI: Amended. 7.2 Scoring This contains a useful summary of the scores and details of why each the 8 PIs score less than 80. 8.0 Certification Recommendation 8.3 Conditions With the exception of Condition 5 they are all appropriate reasonably well crafted and generally should leave the client in no doubt as to what is required of them in terms of an action plan. I have a few specific comments. Condition 1. What is the client going to do with the samples which they take from slippage events? This requirement should be simply added to the request to the Marine Institute regarding what they would require of the fleet. FCI: sentence added to clarify, as suggested.
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Condition 2. The wording of the suggested action is very muddled and here the client will be confused about what they have to do regarding an Action Plan. There should be a clear instruction within their code of conduct to ban slippage and discarding other than for an established safety / emergency reason. FCI: Rephrased and clarified, however, this condition does not go so far as calling for a ban on slippage. Condition 5. This condition is not necessary. Any certification would be awarded to a specified fleet and the certification controlled under the requirements of the chain of custody regulations. Under the terms of the certification the fleet cannot be added to without the express permission of the Certification Body with the agreement of the MSC. FCI: Whilst this condition is not typical, and arguably unnecessary, it remains as a result of a particular issue of concern, discussed by the assessment team at length during the site visit and scoring, in relation to the use of off-register tonnage. Condition 6. It is not clear who is expected to provide and fund the additional observer coverage. It is expensive and as far as I am aware there is currently no national programme to provide additional extensive observer coverage of the Irish pelagic fleet. If they are scientific observers it needs to be made clear in the condition that access to the vessel / trip must not be denied without justifiable reason. All refusals must be reported to the Certification Body. FCI: The question of funding of observers is beyond the remit of the assessment team. A sentence has been added to reiterate that access to scientific observers must not be denied without reasonable justification. 7.0 Scoring For those performance indicators (PIs) where there is no comment, I am satisfied both with the scoring comments and the score. 1.1.1. The SSB has been close to but above the Bpa target reference point since 2005 and is forecast to increase as a result of good recent recruitment. Therefore this PI meets all the SG 80 criteria and the second element of the SG 100 and the score should therefore be increased to 90. FCI: Scoring above 80 implies a “high degree of certainty”. Given the various issues outlined in this report (uncertain total catch, an infrequent biomass index etc.) as the only index of abundance, “highly likely” seems a more appropriate term. 1.2.3. Some of the information on the stock is comprehensive for example the knowledge of distribution, life history, spawning, fecundity and other biological data related to the triennial egg surveys. The international biological sampling programme is comprehensive and more than complies with the minimum requirements under the EU directive. Generally all the SG 80 criteria are met although there are some weaknesses. To balance that some of the 100SG criteria are met justifying a score of 80/85. FCI: To score higher than 80 it must meet all the 80 criteria and it does not. 2.1.1 This does not achieve any of the 100 SG criteria but does meet all the 80 SG criteria therefore a score of 80 only should be given. FCI: The additional 5 points reflect the fact that there is a very low number and volume of other species caught. For the ‘main’ species – Western Horse Mackerel, the term high degree of certainty applies. 2.2.1 The comments here are related to mackerel which are covered in P1.2.2 and 1.2.3. This PI concerns the other species taken in the mackerel fishery eg. Blue whiting, horse mackerel and herring. The difference between the 80 and 100 SGs is between ‘highly likely’ and ‘high degree of certainty’. The AT should err on the side of caution and award a score of no more than 85. FCI: Text adjusted to clarify that bycatch (slippage) of mackerel is dealt with under P1. Small reference to mackerel is however still included to illustrate that undersize mackerel is the
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IPSG Western mackerel pelagic trawl fishery main cause of slippage and slippage due to the presence of other species is rare. This rarity is reflected in a score of 90. 2.2.3 This score is justified in relation to the observer coverage and self sampling and recording in the Irish pelagic fleet compared with some other European fleets. 2.3.1 The specific problem related to the Irish pelagic fleet rightly justifies a score below 80 generating the relevant condition. 2.4.1 Well reasoned justification for reducing the score to below 100. 2.5.1 You conclude that the fishery is highly unlikely to disrupt key elements of the ecosystem and therefore meets the SG 80 criteria. However you do present some evidence for this and in particular you mention the modelling with Ecopath and Ecoism neither of which indicate any unacceptable impacts. Therefore some elements of the SG 100, which requires evidence, are met which justifies a score 90. FCI: It is indicated both in ICES reports and in consultation with the Marine Institute that the level of ecosystem modelling is less sophisticated and West of Scotland and Ireland than it is further East, particularly in the North Sea. The assessment team concluded that the evidence was insufficient for a confident conclusions to be drawn. 3.1.2 Quite clearly the scoring comments justify a score above 85. I suggest that most of the elements of SG 100 are met justifying a score of 95. FCI: The existing text explains the limitations and adequately justifies the existing score. 3.1.3 There is only a subtle difference between the SGs 80 and SGs 100. Long term objectives are either ‘explicit’ or are ‘explicit and required by management policy’. Firstly the TACs set do not take into account unrecorded mortality. The TACs in recent years have been based on the highest ranges of the options provided by scientists rather than the precautionary levels advised. The precautionary approach has been explicit in the advice but not required and not followed by management policy. Furthermore the current policy internationally has some problems in relation to the ongoing unregulated catches by Iceland. As a consequence all these factors do affect the score for this PI which should be reduced to 85/90. FCI: Score reduced to 90. 3.1.4 The comments in this section fully support all the elements of SG 80 and therefore this is the score for this PI. As a consequence no condition should be raised in relation to this PI. This is dealt with under the comments on Condition 5 above. FCI: The assessment tree should have the flexibility to accommodate concerns and issues which arise during the consultation and site visit. It was felt this PI was the most appropriate place to address the issue of excess capacity. 3.2.1 This PI combines requirements related to both Principle 1 and Principle 2. For Principle 1 it meets all the SG 100 criteria but for Principle 2 it only meets the SG 80 criteria. This is because the specific objectives are less well defined for the non target and ETP species. As a precautionary measure a lower score of 80/85 should be given to this PI. FCI: Given the low level risk associated with P2 issues – habitat, retained, ecosystem, ETP and bycatch (particularly given slippage of mackerel comes under P1), it is reasonable that the score should be more weighted toward P1 issues. 3.2.2 It is worth noting here that the management plan is not ratified by all countries which exploit NEA mackerel (Iceland) which helps to justify the low score. FCI: Comment added. 3.2.3 There is evidence that the monitoring of landings and misreporting has improved but they still remain a matter of concern to the assessment working group. This ongoing concern should be reflected in the score for this PI. All the elements of SG 80 are clearly met but most of the SG 100 criteria describe a situation which does not yet exist for the NEA mackerel. A score of
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80/85 only can be justified. FCI: A score of 90 is justified given the comprehensive system of MCS and the high degree of confidence on the part of the SFPA that fishermen are complying. 3.2.4. I completely disagree with the comments in the final paragraph regarding the ad hoc nature of the research strategy. On the contrary a considerable fund of relevant knowledge has been accumulated, over thirty years, from targeted research projects related to the triennial egg surveys. In this context the life history knowledge related to NEA mackerel is second to none. The information on fecundity, atresia, egg development, condition, maturity and the distribution of juveniles has all been carefully targeted at a better understanding of key life history stages. There are also the results of tagging studies and genetic studies clearly targeted at understanding stock identity and migration patterns. This clearly justifies a score well above the SG 80 criteria as many of the SG 100 criteria are met justifying a score of 90. FCI final paragraph reference to ad hoc removed and further text added. Score adjusted to 85.
Peer Reviewer B This review is in three parts, commenting on the presentation, accuracy and interpretation of the information and evidence used as a basis for the assessment of the above fishery, on the scoring table, and on the overall recommendation for certification including the suitability of the attached conditions. Throughout, I have identified the section(s) of the report at which my comments are aimed, and have not commented where I am content with the information provided or the conclusions reached. Presentation My main concern with the presentation of information in this report is that there is an unevenness of detail in some of the sections, which may lead to confusion for the reader. This is most apparent in Section 3. Target stock status & harvest controls, where the information on the methods and data used to evaluate stock status varies from extremely succinct to very technical, and where I have suggested editorial improvements on the draft text. FCI: The report intends to provide more details on features of the fishery, management that may affect the scoring. Many of the gaps in information that occur earlier in the report may benefit from a little more detail and referral to this section. The comments on the scoring table, and in the accompanying section 7.2 are, however, readily understandable. The clarity of the report would also be helped if the fishery proposed for certification (the UoC) is clearly distinguished from the rest of the Irish fleet using mid-water trawls and/or RSW when fishing for mackerel, at appropriate points in the text. 2. The Fishery 2.1 The unit of certification: it would be useful to indicate clearly in a chart showing the ICES sub-areas and divisions the actual area utilised by the UoC when fishing for mackerel. This area appears to be EU waters in ICES Sub-areas VI, VII and VIII and Division Vb; and International waters in sub-areas XII and XIV and Division IIa. FCI: Chart of ICES areas added. A glossary of acronyms would be useful at this stage. FCI: Not considered relevant to scoring, and the authors have sought to limit the number of acronyms and introduce each one in full. 2.2 The Irish Pelagic Sustainability Group: It is curious that there is no mention of sustainability in the IPSG Quality, Environmental and Sustainability Policies. This could read as a manifesto to exploit resources fully, efficiently and with the greatest financial return (in the short-term), but not necessarily to ensure that the resources are not depleted. FCI: This is an issue for the IPSG to address. This does not materially affect the scoring.
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2.3 Fishing Fleet & Fishing Method: Something more is required here on mesh sizes, in the cod-end and wings, and whether escape gaps (e.g. for dolphins) are fitted or have been trialled. Also, what is the configuration for pair trawling, and how many of the 22 UoC vessels do this? FCI: note added that there are currently 7 pairs in the fleet – configuration is simply 2 vessels and one net. There are no escape gaps for dolphins as this is not thought to be an issue, however the level of information to determine this is addressed in the scoring of ETP species. 2.4 Target species: What does the map show? NE Atlantic mackerel do not extend to the shores of America. There are better distribution charts available. FCI Map changed and header added. Lifecycle: Not only has the pattern of the southerly migration of the western components changed in both timing and route, so have the overwintering grounds, which should be mentioned since they are important for the mackerel fishery. Similarly, the distribution of juveniles should be mentioned here, with reference to the “mackerel box” implemented to protect juveniles (inferred later, but not explained). Diet: It might be instructive to say something here about seasonal changes in fat content and lack of feeding in winter. FCI: Not relevant to scoring – as indicated this is not intended to be a comprehensive literature review of the species, but links are provided for readers wishing to go into further detail. 2.5 Catches and landings: you mention that Irish pelagic vessels landed mackerel illegally into Scottish ports over the period 2000 to 2005, but why was this illegal and were any vessels from the UoC involved? How much does the “repayment” of over-quota fish represent, is it taken from the national quota, and does it impinge on the UoC? Some comment on whether landings by the Irish RSW fleet (including the UoC?) into Lerwick, Peterhead or Fraserbugh and Norway are monitored would be useful in relation to these “illegal” landings. FCI: Text amended to clarify. 3. Target stock status & harvest controls (P1) 3.1 Status of the Stock: Though an explanation of the basis for this assessment is provided later, at 3.7, a summary of the types of data ICES use (catch & fishing effort, egg survey estimates of SSB), their reliability in indicating stock trends and sustainability, and how the results relate to biological reference levels (biomass and fishing mortality) would be useful here. Much of the later discussion would benefit from The ICES graphs showing biomass, recruitment and F trends presented here. If you need to introduce limit reference points (Flim and Blim), target F regions, and the precautionary levels (Fpa and Bpa) at this stage, an explanation (or reference to the material section in this report) is required for most of your anticipated readership. In fact, it would be better to present section 3.2 Reference Points, before the stock's status (now at 3.1) is discussed. FCI: The current structure follows the scoring table, which keeps the report focused on issues pertinent to the assessment. Some background knowledge of the meanings of these terms has to be presumed to keep the report to reasonable length. I consider that Figure 3, showing the retrospective bias in estimates of SSB, is superfluous and potentially confusing at this stage, and should be omitted. It merely illustrates one of the frailties of the ICES assessment models that is common to many stocks. FCI: The figure has been moved to the stock assessment section – the caption has been corrected as referring to it as retrospective bias is not correct. The issues that this figure illustrates contribute to the scoring associated with stock status and stock assessment.
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Table 2 Reference points used for the stock assessment. Note that Bpa is not Bloss raised by 15%, since 1.15 x 1.67 = 1.92 and not 2.3. FCI: The text has been corrected. It would be more conventional to caption Figure 4 (and other tables and figures) thus: “The stock assessment estimate of biomass (Model SSB) and the underlying egg survey estimates for NE Atlantic mackerel rescaled to the biomass estimated in the stock assessment, 1992- 2007 (from WGMHSA, 2007).” Then to present your interpretation in the text along the lines of “Although the stock assessment estimate of biomass shows a recovery 2002-2005, the underlying egg survey estimates are relatively flat and show little change. The apparent recovery in the assessment is based on the reduction in legal landings and a large recruitment of the 2002 year class. Given that the mortality due to illegal landings and slippage is highly uncertain, any actual recovery in the stock is unproven.” FCI: The caption has been tidied up. 3.4 Harvest Strategy: There are several points that are a little unclear in this section, which I have indicated in the report text. My main concerns are: are Iceland's increased catches included in the TAC? Have landings been reduced to be more in line with the TAC in recent years? Has biomass recently increased due to recruitment of the large 2002 year class, rather than to reductions in reported catches in 2003 onwards? Is slippage recorded in the UoC, if not routinely across all fleets? And does the potential prohibition on carrying equipment on vessels which might permit discarding mackerel apply to the IPSG vessels? FCI: The text has been clarified with respect to these issues, some of which are dealt with under other sections than the harvest strategy. IPSG vessels are not permitted to carry on board grading equipment which may facilitate discarding and high-grading. You state that “Stock projections are regularly conducted under the harvest control rule to check its performance under uncertainty. The projections fall well short of management strategy evaluation as there is no attempt to apply the harvest control rule as it is implemented, including, for example, the TAC overshoot or slippage.” What does this mean? FCI: The text has been clarified. Much of section 3.4 suggests that there is considerable uncertainty in both the management of the fishery and the status of the stock. Is this really the case, given that most of the relevant scores are 80 or above? FCI: The natural focus of the report is on the problems which materially affect the score. In some cases, such as the change in stock size estimates in 2004, it is indicated that uncertainty has been reduced. 3.6 Information and Monitoring Total Catch: It is unclear what the implications of the TAC payback (due to previous misreporting) are for the UoC. Does the “clear evidence of corrections due to misreporting in the stock assessment” mean that the ICES WG corrects for misreporting in the mackerel assessment? FCI: The reduced catches as a result of payback are used in the stock assessment and the working group uses revised catch figure based on various sources of information, including but not limited to the official figures reported by the countries. This is clearly documented. If the results of Simmonds (2007) analysis (which appears not to have been peer-reviewed) suggests that the estimate of unaccounted mortality is around 2.4 times the catch, either F on mackerel is well above Flim, or the stock's biomass is grossly under estimated. How does this square with the ICES advice on sustainability, or the estimates of discarding/slipping presented below? It is well known that egg-abundance-based stock estimates are often very difficult to reconcile with fishery-based assessments, and mackerel appears to be no exception. FCI: Simmonds presented to the Working Group his results which were not used in the stock assessment. He used various independent sources of information to independently assess Food Certification International Public Comment Draft Report 90
IPSG Western mackerel pelagic trawl fishery what catches might be and produced estimates at the extreme upper end of what might be the case. However, this independent information did not rule out significant unrecorded catches which overall contributes to the uncertainty in the fishery. Adding in catches will just increase the biomass estimate since F will be bound up with the age and size composition. The concern is uncontrolled changes in IUU catches, which could undermine the stock assessment as well as management control. Catch Sampling: Though “selectivity” at age is estimated within the stock assessment, this is not selectivity in the sense that fish can or can't escape through meshes, but is the estimated relative F on each age group. It does not necessarily follow that better biological sampling of the catches will enable selectivity to be estimated by size, sex and maturity (especially as sex and maturity stage are not implicit in the current assessment). FCI: It is true that increased biological sampling will improve selectivity estimates, but it helps reduce sample error, and arguably is important in VPA assessment approaches which assume catch-at-age is known precisely. 3.7 Stock Assessment: You suggest that, other than low SSB, the causes of low recruitment are not well understood, but there has been no low SSB associated with low recruitment in the time series. What is the ongoing research into recruitment? If ICES has not found a use for the S-R relationship, either in the assessment or stock projections, why should it affect Biomass reference points? FCI: There is a clear distinction between problems with estimation (lacking data) and the actual S-R relationship which is known to exist. The research is outlined in the report; however it is unlikely that data will be collected that would allow, by itself, a full S-R relationship to be estimated from a recruitment / SSB time series, but it is used to estimate two out of the three parameters. The current S-R relationship is an implicit Beverton and Holt type model for which the asymptote and variance have been estimated and are used in the stock projections. The point where the curve turns downwards to pass through the origin (where zero SSB = zero recruitment) is not known, but guessed at being at or below the limit reference point. Estimation of this point where the curve declines would lead to a revision of the limit and precautionary reference points. 4. Environmental Elements (P2) 4.1 Slipping: you note that the target species fishing procedure requires the use of electronic equipment to identify target shoals (surely, they already do this to the best of their ability) and of jigging machines/handlines (to do what, test for mackerel size? - few other species will be caught). What is the evidence that these procedures have “greatly improved the selectivity of the fishery”? FCI: text amended to indicate that improvements are probable rather than proven. 4.2 Discarding: You state that “discarding of fish (after it has been brought on-board) is illegal in the mackerel fishery”, but other mackerel fisheries using mid-water trawls discard substantial quantities of mackerel, chiefly because the fish are smaller than the MLS or market requires (at about 30 cm). What is the relevant legislation? 4.4 Ecosystem impacts: Are there any MPAs or SACs in the area in which this fishery operates? FCI: vessels do not fish within 12nm of the coast and nets do not come in contact with the seabed, therefore of little relevance. 7. Scoring Appendix 3 and supporting comments in section 7.2 I have a problem with only two of the marks given (against 2.3.2 and 2.3.3), but would like to draw attention to some of the scoring comments.
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1.2.3. Information/monitoring. You state that biological sampling covers overall 85% of international mackerel landings, and 94% of the Irish fleet landings, but what about the IPSG fleet? FCI: Information not made available to the assessment team, however the 85 and in particular the 94% referred to here are indicative of the likely level of sampling of the IPSG fleet. 2.1.1. Status of retained non-target species. Though retained catches of herring taken in the IPSG fishery for mackerel are considered negligible, and the UoC appears not to be contributing appreciably to the risks highlighted by ICES in relation to Area IV herring, is there any information on slippage of herring catches by the UoC? FCI: No specific information about the slippage of herring in the UoC, however conditions 1 % 2 are intended to address this. 2.2.1. Discarded species, status. This section is not about the target species, mackerel, and information in the first two paragraphs would more usefully be included in section 1.2.3, as appropriate. As in other mackerel fishery MSC assessments, there is scope for confusion over what constitutes bycatch, discards and slippage, and this needs to be clarified. To my mind, bycatch is whatever is caught that is not a target species (there may be more than one target species at any one time), slippage is release of fish from the net without the catch being brought on board (and may apply to part of a catch when onboard processing or storage capacity is exceeded), and discards are anything (including target species) that is returned to the water having been onboard the fishing vessel. FCI: Point noted; text referring to mackerel removed and clarified. 2.2.2. Management strategy: The comments against 2.2.1 are relevant here. In particular, are communications that enable the fleet to collectively avoid particular areas where bycatch is more likely to occur aimed at avoiding undersized or unmarketable mackerel rather than other potential bycatch species (which are more likely to be identified acoustically)? Also, there is no previous mention of the use of flexible sorting grids in the description of the gear used by the IPSG vessels. FCI: Reference to flexible sorting grids has been added to section 2.3 of the main report. Slippage reduction measures are aimed at reducing slippage of both undersize mackerel and other bycatch species. 2.2.3 Information / monitoring: The comments against 2.2.1 are also relevant here. Though you note that incidences of slippage are recorded onboard each vessel in a Slippage Log, and that IPSG vessels record data on the size and species composition before a decision is made to land or slip a haul a catch (which can be made available to fishery managers), why has this information not been made available for this report? FCI: The IPSG Environmental Management System has been implemented as part of the MSC process and the data are not yet available for review or analysis. This data should however be available at the time of the surveillance audit. 2.3.2 Management Strategy: You earlier note that no incidences of cetacean bycatch have been reported for the IPSG fishery, the Seafood Environmental Management System of which is committed to greater reporting of cetacean and ETP encounters using the onboard ETP species log. Though the European Court of Justice ruled that Ireland had failed to implement adequately several provisions of the Habitats Directive in relation to the protection and monitoring of cetaceans in Irish waters, does this apply to the IPSG mackerel mid-water trawl fishery? This also applies for 2.3.3 Information/monitoring, where it appears that the UoC is being penalised for Ireland's lack of published data and observer information in relation to cetacean distribution and abundance. If there is no bycatch in the UoC, how can it be a problem? Marks of 75 seem unduly harsh. FCI: It is not anticipated that improved monitoring will reveal a problem with ETP species, however, the assessors were of the view that there was currently insufficient evidence to confidently state that there was no issue. As a result a more Food Certification International Public Comment Draft Report 92
IPSG Western mackerel pelagic trawl fishery precautionary score, which would trigger a condition and action by the client was felt to be reasonable and appropriate. 2.5.1 Ecosystem status: You imply that there is a lack of evidence for any significant ecosystem effects of the removal of mackerel to the West of Scotland and Ireland, whereas the precautionary approach requires that greater caution should be taken in stating that there is negligible impact in the absence of evidence to the contrary. However, a score of 80 is probably correct. 2.5.2 Management Strategy: Though the main potential impact of the western mackerel pelagic trawl fishery is the depletion of the stock biomass, which appears not to have occurred, what about the impact of slipped (dead) mackerel on trophic functioning? FCI: This has not been studies or raised by the ICES WG as an issue of concern. Impacts are likely to be localised, minor and reversible. 3.1.4 Governance and policy (incentives/subsides): You state that the IPSG fleet has considerable capacity, relative to the available mackerel quota, but are there any other species – blue whiting, herring, scad – targeted by the UoC, seasonally? FCI: The measure of capacity relative to catching opportunities is an approximate estimation, however it is recognised that mackerel is by far the most important fishery for the Irish RSW fleet. 3.2.4. Research plan. If IMI is involved in the triennial egg survey, this should be mentioned. FCI: text added. 8. Certification recommendation I agree with your assessment that the overall Performance of the fishery has passed in relation to MSC Principles 1, 2 and 3, and that the Irish Pelagic Sustainability Group western mackerel fishery be certified according to the MSC Principles and Criteria for Sustainable Fisheries. The Conditions and actions required seem proportionate (though I have doubts about the ETP species requirements) and reflect the concerns raised in the report. Two comments: Under Condition 1: Record all incidences of slippage, you suggest that the IPSG should consult with the Marine Institute as to what information is required. I'm not sure that “condition of the school” will provide an indication of likely mortality; better, perhaps to include the conditions under which slipping took place. This also applies to comments under Condition 2: Reduce slippage to minimum, where “recording mortality” is not possible (for slipped mackerel), but recording the quantities slipped, how long the catch had been in the net and the sea conditions at the time should enable potential mortality to be estimated. FCI: In consultation with the Marine Institute it was suggested that the best thing was for the client to liase with the Irish scientists to determine what data is of most value and how to go about recording this. For this reason the assessment team have not sought to be too prescriptive. Under Condition 5: Capacity, I suggest that the UoC has a large fishing capacity compared to the available resource (i.e. the relevant part of the Irish mackerel quota, not the mackerel stock), and that a condition of certification is that no additional capacity be added to UoC --- unless it is clearly demonstrated that this is linked to an equal removal of Capacity from the rest of the Irish RSW pelagic fleet. FCI: Noted.
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IPSG Western mackerel pelagic trawl fishery
Appendix 5 – Client action plan The Irish Pelagic Sustainability Group (IPSG) is committed to ensuring that they fish the NEA mackerel fishery responsibly. In response to the conditions and recommendation raised during the assessment, the IPSG have developed the following action plan. Condition 1. Record all incidences of slippage IPSG will consult with the Marine Institute regarding updating the slippage record format within the vessels Environmental Management System and the protocol for retaining samples onboard. Vessels will be made aware that if possible, a sample of slipped fish should be retained for the Marine Institute. Slippage records will be recorded from the start of the certification. These records will be collated and passed onto the Marine Institute before the first annual surveillance audit. Condition 2. Reduce slippage to a minimum Crew onboard the IPSG vessels will be made aware of the strategy to reduce slippage and their obligations as part of the Environmental Management System from the start of the certification. Condition 3. Annual verification available that the fishery makes no contribution to the overshoot of the TAC The IPSG will provide evidence to the Certification Body that they fish within their annual quota allocation at each surveillance audit. This evidence will be verified by monitoring and surveillance data from the Irish Sea Fishery Protection Authority. Condition 4. Interactions with ETP species The IPSG will have made contact with the appropriate authorities and the Irish Whale and Dolphin Group by the first surveillance visit. The ETP species interaction log will be collated and made available to the appropriate authorities by the second surveillance audit. Condition 5: Capacity The IPSG will not increase pressure on the mackerel fishery by increasing the fleet size. If any “off register” capacity becomes available, the Certification Body will be made aware of the situation and all national and EU law will be adhered to. Condition 6: Monitoring / observer coverage The IPSG will request that DAFF, the MI and BIM engage in talks to determine the level of observer coverage and develop an observer protocol for use onboard the pelagic vessels by the first surveillance visit. Observer trip reports and data will be collated for review by the Certification Body and the MI. Recommendations The IPSG will seek to liaise with DAFF to clarify the appeals process and keep all skippers up to date with progress. The IPSG will also endeavour to contribute to the debate on the control system in the reform of the CFP in 2012.
Agreed by (Mr Ted Breslin) on behalf of IPSG
Food Certification International Public Comment Draft Report 94