INTERTEK MOODY MARINE LTD

Authors: Jake Rice, Don Bowen, Susan Hanna, Rob Blyth-Skyrme, Paul Knapman

MSC PRINCIPLE 1 EVALUATION OF THE

BERING SEA AND ALEUTIAN ISLANDS KAMCHATKA TRAWL FISHERY

Client: Alaska Seafood Cooperative

Certification Body: Client Contact: Intertek Moody Marine Ltd Jason Anderson Moody International Certification Alaska Seafood Cooperative 99 Wyse Road c/o Groundfish Forum Dartmouth 4241 21st Ave West Nova Scotia Suite 200 Canada Seattle B3A 15S Washington, 98199

Tel: +1 902 422 4511 +1 206 462 7682

Background Increasing interest in harvesting Kamchatka flounder ( evermanni), as a that is more acceptable to markets than (Atheresthes stomias) and is consequently of greater interest to harvesters and processors, caused a concern about managing both species in the and Aleutian Islands (BSAI) area under a single Acceptable Biological Catch (ABC). While Kamchatka flounder comprise only 7% of the composite Atheresthes biomass, it is geographically concentrated in the west and southern portion of the total eastern Bering Seas (EBS) and there has been a disproportionate harvest in recent years whereby the potential exists to overharvest Kamchatka flounder under combined management with arrowtooth flounder.

Beginning in 2011, the BSAI Kamchatka flounder stock was assessed separately from arrowtooth flounder and received an individual ABC and Total Allowable Catch (TAC). Although the initial stock assessment of Kamchatka flounder was largely descriptive, as is the case for a stock managed at Tier 5, the biological information on the stock has been improved substantially by directed sampling of surveys and commercial catches and more complete analyses of existing data. As a consequence, the stock assessment conducted in 2012 was substantially strengthened, and provides a strong basis for sustainable management of fisheries on Kamchatka flounder. While some aspects of the analytical formulation of the assessment need to be strengthened further in order to fully meet the requirements of a Tier 3 assessment, many aspects of the 2012 stock assessment are sufficiently well supported to be taken into account in the scoring of Kamchatka flounder.

MSC Requirements The separation of Kamchatka flounder from arrowtooth flounder for management purposes created several issues which need to be addressed within the MSC scheme requirements: the need for clarity in the status of existing product in the supply chain; the ongoing certification status of arrowtooth and Kamchatka flounder in the BSAI; the ability to have one or both species MSC certified and/or labelled.

The MSC directed Intertek Moody Marine to take account of the changes in the assessment of the arrowtooth and Kamchatka flounder stocks. It was agreed that the MSC would consider an evaluation of the Principle 1 aspects of the fishery - Principle 2 and 3 being the same for all the and having already been evaluated - and if there were no additional Conditions to that which already existed for the arrowtooth flounder fishery then the scope of the certification may be extended to include Kamchatka flounder.

Evaluation of Principle 1 Information Using information that was provided during the original assessment visit and then over the course of the two surveillance site visits, the status of Kamchatka flounder was evaluated against the same Principle 1 Performance Indicators (PI) and Scoring Guideposts (SG) as those used in the assessment of arrowtooth flounder that led to certification of the fishery in 2010.

Following the development of a Tier 3 assessment model for Kamchatka flounder, which was presented at the September 2012 meeting of the Bering Sea Plan Team, it can now be confirmed that the results of the Principle 1 assessment show that the Kamchatka flounder fishery is performing at the SG80 level across all Principle 1 Performance Indicators.

The assessment table on the following pages shows the surveillance teams scoring rationale and scores for each of the Principle 1 PIs, while the overall scores and determination are listed below.

Limit of Identification of Landings from the BSAI Kamchatka flounder fishery Traceability Traceability of product from the sea to the consumer is important so as to ensure that the MSC standard is maintained. There are several aspects to traceability that the MSC require to be evaluated: Traceability within the fishery; at-sea processing; at the point of landing; and subsequently the eligibility of product to enter the chain of custody. These requirements are assessed here.

Traceability Requirements Within the Fishery Existing fisheries management requirements include the clear identification of species, quantity, fishing method and area of capture by all vessels landing from the fishery. Catches of arrowtooth flounder and Kamchatka flounder are reported in logbooks, on landing tickets, processor check-in/check-out reports, product transfer reports and through daily radio hail-ins or via an electronic fish ticket system, “Elandings”, which is accessible and monitored by federal management staff on a daily basis. On board observers (30% - 200% coverage depending on the size of the vessel) also monitor, cross check and verify their reports with the vessels logbook. The amounts of Kamchatka and arrowtooth flounder are confirmed by observers on a haul-by-haul basis.

Cross referencing of VMS data with logbooks, observer and aerial and at-sea surveillance reports also ensures that fish is reported from the correct area of capture. Electronic landing reports are also filed by processors enabling cross referencing with landing statistics. Dockside sampling is conducted and shore based processors have 100% observer coverage thereby monitoring product origin and throughput at the processing facility.

At-Sea Processing Product is generally landed as headed and gutted, frozen fillet blocks and individually frozen fillets. The landings are subject to the same reporting and monitoring requirements as indicated above. There is no known traceability risk factors associated with any of the at-sea processing operations.

Points of Landing The limit of identification of landings is the landing of arrowtooth flounder and Kamchatka flounder by the Alaska Seafood Cooperative member’s vessels at recognised ports where appropriate recording and monitoring of landings may take place. There are no known risk factors after the point of landing that may influence subsequent chain of custody assessments. Chain of custody should begin from the first point of sale.

Eligibility to Enter Chain of Custody The Alaska Seafood Cooperative is comprised of the following seven companies:  Cascade Fishing Inc.  Fishermen’s Finest Inc.  Iquique LLC  Jubilee Fisheries Inc.  O’Hara Corporation  Ocean Peace Inc.  United States Seafood LLC

The vessels of these companies are already eligible to sell MSC certified arrowtooth flounder, and will be eligible to sell MSC certified Kamchatka flounder if this variation request is granted.

Products, including those processed at sea, landed by any of the vessels owned by any of the Alaska Seafood Cooperative member’s vessels are eligible to enter further chains of custody. In order to sell product as being MSC certified, companies buying directly from this fishery are required to have chain of

custody certification, while land-based processing sites owned by companies of the Alaska Seafood Cooperative must also have a separate chain of custody certification if products from the fishery are to be sold as MSC certified.

Eligibility date In normal circumstances, eligibility to sell certified product may be extended for up to a maximum 6 months prior to the publication of the Public Comment Draft Report (PCDR) (MSC CR Section 27.6). In this case, and because no PCDR has been published in the course of pursuing this variation request, the eligibility date is set as being 6 months prior to the submission of this request. The client has confirmed that the members of the Alaska Seafood Cooperative wish to gain the maximum benefit from the eligibility date hence, the eligibility date extends back to 13th June 2012.

Conclusion and Certification Recommendation The assessment scores for the Bering Sea and Aleutian Island (BSAI) Kamchatka flounder fishery are:

P1: 85.6 P2: 86 (as for arrowtooth flounder) P3: 93 (as for arrowtooth flounder)

The BSAI Kamchatka flounder fishery therefore meets the MSC standard and can be certified with no conditions of certification.

Principle 1 A fishery must be conducted in a manner that does not lead to over-fishing or depletion of the exploited populations 33.3 and, for those populations that are depleted, the fishery must be conducted in a manner that demonstrably leads to their recovery. 1.1 (MSC Criterion 1) The fishery shall be conducted at catch levels that continually maintain the high productivity of the target 33.3 population(s) and associated ecological community relative to its potential productivity. 1.1.1 There should be sufficient information on the target species and stock separation to allow the effects of the fishery on the 16.7 stock to be evaluated. Weighting Commentary No weighting is applied to the MSC Principles – these are equally weighted and each must attain a weighted score of 80 or more for certification to be granted. The three MSC criteria are considered of equal importance. The four sub-criteria under 1.1 (MSC Criterion 1) and the Performance Indicators under sub-criterion 1.1.1 are also considered of equal importance; essentially representing a ‘logical sequence’ of issues. 1.1.1.1 Are the species readily identified as adults and juveniles? 14.6 80 60 Misidentification is possible and For many years Kamchatka flounder was recorded as part of the arrowtooth flounder catches, a practice followed even in research surveys increases recording errors of until 1991. It is possible to differentiate the two species reliably however, and this has been done in research surveys since 1991 and by catches, but this does not fisheries observers since 2007. Both species can be taken in individual catches, but because it is more acceptable to markets, and consequently compromise monitoring to of greater interest and preference to harvesters and processors than arrowtooth flounder, there is good reason to believe all reported landings unacceptable levels. Methods to of Kamchatka flounder are indeed that species. The price advantage is also an incentive to reduce the likelihood that Kamchatka flounder are improve identification are under landed as arrowtooth flounder. Industry reports that as markets for Kamchatka flounder become better developed, there is increasing care on development. fishing vessels to ensure Kamchatka and arrowtooth flounder are sorted accurately in catches, whether landed or discarded. Aside from 80 The target species is unlikely to be arrowtooth flounder, morphological and distributional differences mean that there is little likelihood that Kamchatka founder would be landed confused with any other species as any other flatfish species accepted by markets However, no documentation was provided on the accuracy of sorting the two species under and is recorded appropriately. operational fishing conditions, particularly in any catch that is discarded. Therefore a score of 80 was considered appropriate. A higher score 100 The species is readily identified by could be obtained if there were results provided of a study of the accuracy of separating all Kamchatka flounder from arrowtooth flounder fishers and by regulators and is during the sorting of commercial catches. recorded appropriately.

1.1.1.2 Is the life history of the species understood and the spawning and nursery areas described? 14.6 80 60 There are gaps in information but the basis of the life The life histories of flatfish of the genus Atheresthes are generally well understood, and enough biological parameters of history is understood. Information is adequate to Kamchatka flounder are documented (maximum age, general age of maturity) such that the information is adequate to support a general population model, but some support a general population model. Sampling of commercial catches has documented that spawning occurs during assumptions are required. There is some information on winter in a fairly larger area of deeper waters along the Aleutian Islands and outer Bering Sea. Fisheries do not target the spawning and nursery areas. Kamchatka and arrowtooth founder during that period because of both difficulties in fishing those areas during winter 80 The life history of the species is clearly documented conditions, and the poorer quality of the flesh during and immediately after spawning. Less is known of the location of and understood. Information is adequate to support an nursery grounds, but they are thought to be also in deeper waters along the Aleutian Islands and outer edge of the Bering appropriate population model. Spawning and nursery Sea. Once Kamchatka flounder have reached a size that they are vulnerable to the survey gears, an age-dependent trend areas are adequately well described. in distribution from shelf to deeper spawning grounds has been found. A score of 80 had to be awarded. This score could 100 The life history of the species is clearly documented be revised upward if more complete information on spawning and particularly nursery grounds can be provided. and understood including behaviour and ecological interactions. Spawning and nursery areas are sufficiently well documented to support closed area / seasons where this is deemed necessary.

1.1.1.3 Is the geographical range of the target stock known and any seasonal migration described? 14.6 85 60 A management unit approximating the stock is used The geographic range of Kamchatka flounder in US waters is well described from research surveys and the range in with some biological justification. This is based upon a Russia is also well documented. Seasonal movements can be partially inferred from patterns of catches of Kamchatka sufficiently robust estimation of the geographical range flounder in commercial fisheries, suggesting that seasonal movements are gradual and not long-distance annual of the target stock. migrations. However research surveys are standardized in time so they provide little information on seasonal movements 80 A reliable estimate of the geographic range of the target and fishery catches provide only opportunistic coverage of the areas in which movements may be occurring. In addition, stock is available including seasonal patterns of the stock assessment unit treats the population as a whole, consistent with the absence of evidence of sub-stock structure movement and availability. Stock assessment and in US waters. A higher score could be obtained if more information could be provided on seasonal movements. management units are consistent with the majority distribution of the stock. 100 The complete geographic range of the stock, including seasonal patterns of movement/availability, is estimated and documented and is kept under review.

1.1.1.4 Is there information on fecundity and growth? 14.6 80 60 There is some appropriate information available on Little information is currently available on age or size-specific fecundity of Kamchatka flounder, but gonad sampling has fecundity and growth. commenced and adequate sampling will be completed in 2012 to allow age or size specific fecundities to be estimated. 80 Reliable estimates are available of fecundity at size In addition the size and age specific fecundity of the closely related arrowtooth flounder is well documented, and and/or weight and growth rates, and this information provides a general basis for assessment and management. Models of age-specific maturity based on the sampling forms an adequate time series. information available for Kamchatka flounder, and informed by the general shape of maturation schedules for other 100 There is comprehensive and reliable information on flatfish in the region with similar age structures, were used in the 2012 assessment and fit the available population data at fecundity at size, growth rates, and length and weight at an acceptable level. Adequate samples of size at age of Kamchatka flounder from standardized surveys and commercial age, and these are monitored over time to detect trends catches are available, with recent samples augmenting older data from past surveys. These samples are adequate to allow and shifts. estimation of growth rates and length and weight at age, and such estimates are available and have been included in the 2012 assessment. The information currently available is sufficient to allow a score of 80. When the laboratory processing of the gonad samples is complete so more accurate age-specific fecundities are available, and the growth data are fully incorporated in the assessment of this stock (planned for the 2012 revision) a higher score could be awarded.

1.1.1.5 Is there an understanding of the relationship of recruitment to parental stock? 14.6 80 60 Indices of recruitment levels and recruiting ages, and The information needed to estimate recruitment from age structured population analyses is available from surveys and corresponding spawning stock levels are available. catch monitoring, and the contrast in stock sizes in the time period covered by these data sources is adequate to explore 80 Adequate estimates of recruitment and spawning stock the relationships between recruitment levels and stock size. The information is fully adequate to support the current Tier are available. Sufficient years of data and contrast are 5 management regime. When the Tier 3 assessment is fully complete later in 2012, the results of the age-structured available to establish a general relationship between population analyses will provide adequate estimates of stock and recruitment, and be sufficient to support management stock and recruitment. regimes that take relationships of stock and recruitment into account. Based on the contents of the assessment already 100 The relationship between stock and recruitment is well available in Fall 2012, and assuming the revisions to the assessment will be completed on schedule, the information will understood with high statistical reliability. to meet the 80 score according to the MSC guidelines. The information could possibly support a slightly higher score, depending on the strength of the relationships between the spawning stock and recruitment estimated in the upcoming assessment, but even the fall 2012 information is sufficient to justify a score of 80.

1.1.1.6 Is information collected on the abundance/density of the stock? 14.6 90 60 Either fishery dependent or fishery independent indices Multiple indices from fishery catches and well-designed research surveys are available on the abundance and density of are available on the abundance of the stock biomass. the stock and the coverage is very good in the areas supporting the fishery. These sources are sufficient to support robust Qualitative information exists on the appropriateness of estimates of trends in abundance with high confidence. However, little information has been provided on the the indices as proportional indicators of stock size. uncertainties in the indices of abundance, or the degree to which the survey designs have been able to reduce 80 Fishery dependent and/or fishery independent indices uncertainties where they occur, although information on the nature and magnitude of these uncertainties will increase as are available on the abundance/density of the stock. more assessments suitable for Tier 3 management are completed. The range of the stock extends into Russian waters Uncertainties have been analysed and any uncertainties beyond the area covered by the survey, so the survey-based indicators of stock status probably underestimate total reduced so as to allow trends to be determined from the biomass by an unknown amount. However, management of the fishery is based solely on the estimates of stock size indices. Indices are suitable to provide a high degree of based on indicators in US waters, and consequently any uncertainty due to a portion of the stock remaining outside US confidence in the evaluation of stock abundance trends. waters does not increase risk to the stock, unless a large scale fishery in adjacent Russian waters were to develop, a 100 Multiple fishery dependent and/or fishery independent development that could not occur without the US authorities being aware of the new fishery. indices are available on the abundance/density of the stock with sufficient time series to allow trends in abundance to be understood clearly. Where fishery independent surveys are used (for juveniles and/or adults) the design of the survey is statistically rigorous and robust, Indices are consistent and there is clear evidence that they are proportional to the stock size. Uncertainties have been fully analysed.

1.1.1.7 Is information available on environmental influences on the stock dynamics? 12.5 80 60 Some relevant studies have been undertaken on the There have been few or no directed studies of the influence of physical factors on Kamchatka flounder, and only general effects of biological and physical factors which could studies have been made of predators on the species. However the predator diet data that are available indicate that affect the stock (including natural mortality). Research Kamchatka flounder are only rarely encountered in predator stomachs, although it is unclear if the analyses of stomach is encouraged and ongoing. contents have reliably separated Kamchatka flounder from the much more abundant arrowtooth flounder. Likewise the 80 There is knowledge of biological and physical factors impact of physical factors on related species of the genus Atheresthes have been conducted, and given the similarities in affecting distribution, survival and year class strength life histories allow some general inferences to be made, particularly in light of the low signal in annual recruitment sizes (including natural mortality). Some information is to the multi-aged spawning biomass. The low contrast in the annual year-class estimates currently available suggest there sufficiently robust for use in the stock assessment are no major environmental drivers causing large inter-annual variation in stock productivity, and low risk of abrupt and process. undetected declines in year-class strength. This evidence is being strengthened substantially by the greater quantitative 100 There is comprehensive knowledge of biological and content in the 2012 assessment results. The information previously available is sufficient for management of the fishery physical factors affecting distribution, survival and year using a Tier 5 harvest strategy, and the additional information in the 2012 assessment has been reviewed and, assuming class strength (including natural mortality). Key the requested revisions are completed, should be sufficient for a Tier 3 harvest strategy. Nonetheless, more directed information is sufficiently robust for use in the stock research on environmental impacts of stock productivity would be necessary to obtain a higher score. assessment process.

1.1.2 There should be sufficient information on the fishery to allow its effects on the target stock to be evaluated 16.7 Weighting Commentary All Performance Indicators within this sub-criterion are considered of equal significance. 1.1.2.1 Are all major sources of fishery related mortality recorded/ estimated, including landings, discards 25 95 and incidental mortality? 60 Sufficient information is available on the fishery to There is a very high level of observer coverage of the vessels participating in the BSAI flatfish fisheries, augmented by allow accurate estimates to be made of landings, full monitoring and sampling of landings. This would meet all the requirements for a score of 100, except for the lack of broken down as required for an evaluation to be made. certainty that all Kamchatka flounder are separated from arrowtooth flounder when large catches of the latter are taken. Estimates of discards and incidental mortality are available. 80 Landings are accurately recorded. Discards and incidental mortality are well estimated for the fishery. 100 Landings, discards and incidental mortality are accurately estimated and monitored.

1.1.2.2 Are fleet descriptions, fishing methods and gear types known throughout the fishery under 25 100 assessment? 60 Significant fishing methods and gear types are known All gear types and fishing methods are known and are regularly observed under normal fishing operations. Full for the fishery with some information on geographical information on fleet size, composition, and effort levels are recorded and updated regularly for use by management areas of use. Information is available on the size and authorities. composition of the fleets, but is not regularly updated. 80 Significant fishing methods and gear types are known and information is available on the geographical areas of use. Recorded information is available on the size and composition of the fleets. This is reviewed and updated at appropriate intervals. 100 All fishing methods and gear types employed in the fishery are known. In-situ observations are made of fishing practices. Comprehensive knowledge is recorded and regularly updated, on the size and composition of the fleets.

1.1.2.3 Is gear selectivity known for the fishery? 22.8 80 60 Appropriate information is available on selectivity and The selectivity of the gears in this fishery are well known relative to the very similar arrowtooth flounder, but there is no qualitative changes in selectivity. evidence that targeted work has been done to ensure these selectivities apply fully to Kamchatka flounder. However, 80 Selectivities of gear types are well estimated by size. catchability of flatfish in these gears has been shown to be strongly related to morphology, and the morphological Information is sufficient to determine any changes in similarities of arrowtooth and Kamchatka flounder are sufficiently close that for many years these two species were selectivity over time. managed as a common unit, and it is only market conditions and not fishery performance that has led to the separation in 100 Full selectivities have been accurately estimated for all management. In the 2012 assessment prepared to support Tier 3 management of Kamchatka flounder, estimation of age gears, locations and times of fishing over time. and sex specific selectivities was undertaken. Strictly empirical estimates of the catch and survey selectivities were weak, but fits improved substantially with assumptions about dome-shaped selectivity based on knowledge of other flatfish fisheries in the region and consistent with age specific distributions from surveys and spatial distribution of harvests, The information necessary to detect changes in catchability over time is available from the surveys and observer-based catch monitoring, and although there is no evidence these data have been examined for such changes neither are there time trends in the model errors that would be consistent with a time trend in selectivities for either arrowtooth founder or Kamchatka flounder. If additional work is done to improve the estimation of Kamchatka flounder selectivities in the assessment model as part of Tier 3 assessments, then a higher score could be awarded

1.1.2.4 Is the target species taken in other fisheries in the area that are not subject to this certification, and are 25 100 such catches recorded or estimated? 60 There is an appropriate level of information relating to All the conditions for the SG100 are met: At the depths where Kamchatka flounder are taken, all fisheries (and other other fisheries in the area that are not subject to this sources of human-induced mortality) in the area that are not subject to this certification are identified and monitored. All certification, although these are not fully identified. The the catches are recorded and used in the stock assessment. Levels of IUU fishing are reliably estimated to be negligible catches are estimated in the stock assessments. Levels of IUU fishing are estimated, but with some uncertainty. 80 The main fisheries not subject to certification are identified. Significant catches of the target species (including IUU fishing) are either recorded or reliably estimated in the stock assessments in a precautionary manner. 100 All fisheries (and other sources of human-induced mortality) in the area that are not subject to this certification are identified and monitored. All the catches are recorded and used in the stock assessment. Levels of IUU fishing are reliably estimated to be negligible.

1.1.3 Appropriate reference levels have been developed for the stock 16.7 Weighting Commentary All Performance Indicators within this sub-criterion are considered of equal significance. 1.1.3.1 Are there appropriate limit and precautionary reference points based on stock biomass and fishing 100 80 mortality? 60 Limit and precautionary reference points have been set The stock has been managed under a Tier 5 control rule, so the key management benchmarks are an upper limit on based on justifiable and reasonable practice appropriate harvest based on natural mortality, and a reliable estimate of biomass from surveys. Both are reliably estimated from to the species. surveys supported by full catch monitoring, and the upper limit on harvest rate is directly linked to stock biology. 80 Appropriate limit and precautionary reference points Although a firm biomass limit reference point has not been set, by treating the survey based biomass estimates as are justified based on stock biology (e.g. a stock- absolute estimates of stock size, when catchability is not likely to be 1.0 for all ages and survey coverage of rough deep recruitment relationship) and are measurable given data bottom in some of the range of the stock is incomplete, the reference points that are estimated provide substantial and assessment limitations. precaution. In addition, the use of a multi-year running average in the harvest control rule is additional protection against 100 Appropriate limit and precautionary reference points an opportunistic high outlier in the survey catch series. are justified based on stock biology, uncertainty, variability, data limitations and statistical simulations of A higher score could be awarded when a firm biomass limit is set for the stock, to anchor the other reference these factors. benchmarks that are already in place. Such work would be expected to be a pre-requisite of moving the fishery to a Tier 3 harvest strategy, and would likely require a re-evaluation of the score awarded on this criterion. With completion of an age structured analytical assessment, in 2012, and assuming the necessary revisions are completed in this year, then the information needed for Tier 3 management will be available. Should the management authority decide to move to Tier 3 management for Kamchatka flounder then a precautionary biomass-based reference point will be used in management of this stock, justifying a score of 85 or 90, depending on the uncertainty associated with the reference point.

1.1.4 There is a well-defined and effective harvest strategy to manage the target stock. 16.7 Weighting Commentary All Performance Indicators within this sub-criterion are considered of equal significance. 1.1.4.1 Is there a mechanism in place to contain harvest as required? 33.3 90 60 Mechanisms are in place to monitor and (if necessary) Mechanisms are in place to contain harvest as and when required to maintain (or allow the target stock to return to) reduce harvest, but do not fully contain harvest, or have productive levels. These include full monitoring of catches and real-time, in-season tracking of catches against TACs. not been tested. Measures provide a reasonable degree The management authority has the capability to close areas to fishing or close the entire fishery, as needed to ensure of confidence in stock management. catches do not exceed conservatively set quotas. The use of a cautious exploitation rate and a multi-year running average 80 Appropriate mechanisms are utilised to contain harvest for quota setting make the system robust to uncertainty in data inputs or stock biology. However the effectiveness of as and when required to maintain, or allow the target these measures has not been tested for Kamchatka flounder, although they have been tested for some other stocks more stock to return to, productive levels. These have been important economically than this fishery, and they are found to be effective. tested if/as appropriate for robustness against uncertainties in the assessment and management process. 100 Mechanisms are in place to contain harvest as and when required to maintain (or allow the target stock to return to) productive levels. Measures are robust to uncertainty in data inputs or stock biology. Specific measures to demonstrate effectiveness are in place and their robustness has been examined against a wide range of uncertainties.

1.1.4.2 Are clear, tested decision rules set out? 33.3 90 60 It can be demonstrated that decision making, though not The decision rule is clear, explicit, and fully tested for fisheries that are considered appropriate for management under a necessarily formally documented, is recorded, logical Tier 5 decision rule The biological characteristics of Kamchatka flounder and the quantity and quality of information and appropriate. Rules may not have been tested, but available on the species and stock makes Tier 5 management fully consistent with a precautionary approach. However appear appropriate for management. the robustness of the rule has not been tested for this particular species. Hence a score intermediate between 80 and 100 80 Clear decision making rules are used, are fully is appropriate. documented, but may not have been fully tested. Decision rules are reconciled with reference points and If the stock were to be advanced to a Tier 3 stock, the necessary testing of robustness of the harvest control rule to the with data and assessment limitations. specific biological and fishery parameters of Kamchatka flounder would probably be required by the management 100 Clear, documented and tested decision rules are fully authority. Such testing sometimes takes a couple of assessment cycles to complete, but much of the foundation work for implemented and have been fully reconciled with such testing has been developed for flatfish in the North Pacific. When the work is completed and implemented in reference points and the data and assessment management a higher score would be justified here as well. limitations, and have been periodically evaluated.

1.1.4.3 Are appropriate management tools specified to implement decisions in terms of input and/or output 33.3 90 controls? 60 Management tools exist within the fishery under Management tools based on full catch monitoring and catch tracking relative to TACs are specified to implement assessment to implement decisions of input and/or decisions on the level of input and/or output controls. Tools are responsive, relevant and timely. For some other species output controls. Evidence shows that tools are effective in the mixed flatfish fisheries the performance of the tools has been evaluated and evidence exists to show clearly that enough to achieve the minimum level of control the tools are effective in achieving relevant management objectives for these other cases. However the tools have not necessary to meet the main management objectives. been tested specifically for Kamchatka flounder so a score of 100 cannot be awarded, even though there is no a priori 80 Management tools have been specified to implement reason to expect the tools to perform more poorly for Kamchatka flounder than for other flatfish taken in the fishery. decisions on the level of input and/or output controls. Evidence exists to show clearly that tools are appropriately effective in achieving relevant management objectives. 100 Management tools have been specified to implement decisions on the level of input and/or output controls. Tools are responsive, relevant and timely. Performance of the tools has been evaluated and evidence exists to show clearly that the tools are effective in achieving relevant management objectives.

1.1.5 There is a robust assessment of stocks. 16.7 Weighing Commentary All Performance Indicators within this sub-criterion are considered of equal significance. 1.1.5.1 Are assessment models used and are they appropriate to the biology of the target species and the type 20.0 80 of fishery? 60 Robust assessment models are used. These are generic Age structured assessment models are used, based on general stock biology, surveys, and catch monitoring. Major and do not account for specific characteristics of either criteria are related to the species and/or the fishery. The assessment formulations and parameters have been estimated for the biology of the species or the nature of the fishery. this stock, and model fit will be acceptable when the requested revisions are complete. With the assessments prior to 80 Adequate assessment models are used. Major criteria 2012 a score of 80 was justified and cold support Tier 5 management. Assuming the revised assessment is accepted by are related to the species and/or the fishery, but there the review process and management authority, and management moves to Tier 3, then a score of 85 will be warranted. are some areas of the assessment that are generic. The past assessment approach takes some account of uncertainty in the survey catches, which are a key component of 100 Adequate assessment models are used and capture all the assessment model, and the age structured model takes account of uncertainties in the catch data and many of the life major features appropriate to the biology of the species history parameters in the model. and the nature of the fishery and the nature of the management questions being asked.

1.1.5.2 Does the assessment take into account major uncertainties in data and have assumptions been 20.0 80 evaluated? 60 Major uncertainties are identified. Some attempt has The previous assessments fall slightly short of the SG 80 level of performance, which require that the assessment been made to evaluate these in the assessment. addresses all significant uncertainties in the data and functional relationships and evaluates the assumptions in terms of 80 The assessment takes into account major uncertainties scope, direction and bias relative to management-related quantities. While the previous assessment model has been in the data and functional relationships. The most shown to meet sufficient levels of precision and accuracy to allow the management process to achieve its objectives for a important assumptions have been evaluated and the Tier 5 stock, the assessment model did not consider all significant sources of uncertainty in the data and certainly not in consequences are known. the functional relationship. However an improved assessment, including more sources of information and better 100 The assessment addresses all significant uncertainties in information on the stock biology was reviewed in fall of 2012, and a revision will be completed before the end of 2012. the data and functional relationships and evaluates the When that assessment is accepted, it will be possible to re-evaluate this criterion and draw new conclusions about the assumptions in terms of scope, direction and bias extent to which the assessment considers the major uncertainties relevant to application of the Tier 5 or Tier 3 harvest relative to management-related quantities. The strategy, and the degree to which the assessment evaluates the assumptions as per the guideline. Based on the assessment assessment model has been shown to meet sufficient tabled in fall 2012 a score of 80 is already warranted, and it could possibly improve slightly, depending on the levels of precision and accuracy to allow the performance of the assessment model when all revisions have been completed. management process to achieve its objectives.

1.1.5.3 Are uncertainties and assumptions explored and reflected in management advice? 20.0 80 60 Major uncertainties are recognised and are reported in The major uncertainties and assumptions that would affect the performance of the current Tier 5 management approach management advice, as well as possible implications of are addressed in the management advice and through the appropriate decision rules to address those limitations. In those uncertainties on the management advice. particular, the .75 * M is well established as a precautionary exploitation rate in the source of uncertainties about the 80 Major uncertainties and assumptions are addressed in biology of a moderately long-lived target species in a fishery, and the multiyear running average of absolute survey the management advice and through the appropriate biomass estimates is adequately robust and conservative to uncertainties about annual stock sizes (whose survey CVs decision rules to address those limitations. have been estimated and are moderate at most). 100 All significant uncertainties and assumptions are If the age structured assessment model is accepted by the review process and management authority for 2013 addressed and reflected in the management advice, management then the improved model will more fully explore the uncertainties and assumptions in the assessment including appropriate decision rules. model and interpretation, and will justify an upward revision of the score on this criterion to 85.

1.1.5.4 Does the assessment evaluate current stock status relative to reference points and make forecasts for 20.0 80 the future? 60 The stock status is estimated relative to reference The previous assessment makes an evaluation of the stock status relative to the reference points, but the reference point points. for exploitation rate rather than for biomass has been the main feature in the annual evaluations of stock trends and 80 The assessment makes an evaluation of the stock status management effectiveness. Short term forecasts have been made in setting the harvest advice for the coming year and, relative to the reference points. Both short and medium again these are more important for management than any medium term forecasts that might be made. However, because term forecasts are made. a seven-year running average has been used in estimating the annual biomass status and trend, if medium term forecasts 100 The assessment makes a reliable probabilistic have not been reported, it is because they would not be of much relevance to management, rather than because they evaluation of the stock status relative to the reference would be impossible or difficult to do. points and projects these into the future over A complex age structured assessment model has been reviewed in fall 2012, and is expected to be revised before the end appropriate timescales. 2012. The model is supported by more complete information of stock biology, will provide improved short and medium term forecasting ability, and will allow the stock to move to a more demanding tier of management. Assuming the revisions to the model requested in the fall are completed, then the assessment model will have improved forecasting ability, which would justify revising the scoring on this criterion to 85. Higher scores would require testing of the reliability of the forecasts from the assessment model

1.1.5.5 Does the assessment include the consequences of current harvest strategies? 20.0 85 60 The assessment makes an appropriate initial The assessment exceeds the SG 80 standard of including robust approximation of the consequences of annual catches approximation of the consequences of current harvest consistent with the current harvest strategy. Uncertainties in the model are adequately considered in harvest strategy strategies. evaluations, but in past years this has been largely though the robustness of the Tier 5 management approach and the use of multi-year running means from surveys. To this point, little is done (or required) regarding multi-year forward 80 The assessment includes a robust approximation of the projections of stock trajectories under various scenarios about harvests and stock dynamics, so a score substantially consequences of current harvest strategies. higher than the SG 80 would not be warranted. However the availability of an improved assessment model will provide Uncertainties in the model are adequately considered in increased potential for forward projections under alternative management scenarios. If this potential used in future harvest strategy evaluations. assessment and management then a revision of the score on this criterion would be justified. 100 The assessment includes the consequences of current harvest strategies, forecasts future consequences of these and evaluates stock trajectories under decision rules.

1.1.6 The stock(s) is/are at appropriate reference level(s). 16.7 1.1.6.1 Is there evidence that stock status is consistent with that providing long-term productivity? 100 90 [Score ≥80: Criterion 1.1 is complete and Criterion 1.2 does not apply. Score 79 or less: Answer Criteria 1.2 in addition] 60 The stock has a high probability of being above its limit With a Tier 5 management strategy, the longer term average biomass is de facto a target reference point, and any reference point biomass limit appropriate for the management framework (which does not require one, as the harvest control depends on 80 The stock has a high probability of being above its limit a conservative F reference point and trends in biomass indices) should be well below the long term average biomass and reference point and the stock is at, or fluctuating very likely somewhere in the lowest quartile of historical observed biomasses. For the longest survey index of the stock around, it’s precautionary/target reference point. size (Bering Sea shelf) the 2011 index is slightly down from the values from the 2010 survey, but 7 of the 8 largest 100 The stock has a high probability of being consistently at estimates in the survey series are in the most recent 7 years. For the two survey series of the slope and Aleutian Islands, or above its precautionary/target reference levels. where depth and habitat may be the more preferred habitat of the stock, the time series are shorter and surveys are biannual with some gaps, but the recent survey biomass estimates in these surveys are also the highest in the time series. A score of 100 was not awarded because there is not a basis to conclude that the stock will be consistently at or above its target and precautionary levels. However the exploitation rate is sufficiently low that stock fluctuations are more likely to be due to longer term trends in stock productivity, and the patterns of causes of such trends are not documented.

1.3 (MSC Criterion 3) Fishing is conducted in a manner that does not alter the age or genetic structure or sex composition to a degree that impairs 33 reproductive capacity. 1.3.1 Fishing activity maintains the age, genetic structure or sex composition of the stock to a degree that does not impair 100 reproductive capacity. Weighting Commentary All Performance Indicators within this sub-criterion are considered of equal significance. 1.3.1.1 Is the age/sex/genetic structure of the stock monitored so as to detect any impairment of reproductive 50 85 capacity? 60 There is some information available on the sub- Estimates are available of the sex and size structure, based on adequate sampling and verification for this stock, and the population/sex/age structure of the stock, and the relationship of these to reproductive capacity, and monitoring is continuing to collect such information on a time scale relationship of these to reproductive capacity. Some appropriate to the species and fishery. The fishery and survey monitoring is very good, such that these estimates are monitoring of age/sex and/or sub-populations is considered reliable enough to approach the SG100, however, the relationship of age and sex composition to stock conducted and evaluated periodically. productivity is inferred from the broad representation of mature ages in the spawning biomass and above average or 80 Estimates are available of the sex and size structure, better recruitment to the stock in recent years. More direct studies of this relationship were undertaken in 2012 and are based on adequate sampling and verification for this planned for 2013. Also the genetic substructure of this stock has not been studied, such that the lack of impact of the stock, and the relationship of these to reproductive fishery on stock structure is inferred from the broad distribution of catches in the stock range, the contiguous distribution capacity. Genetic or sub-population studies have been of the stock in survey catches through the range of the stock, and the low exploitation rate posing little risk of carried out as appropriate. Monitoring is continuing to fragmentation of population structure. At this time a score only somewhat above the SG 80 is appropriate, but when the collect such information on a time scale appropriate to additional work on stock fecundity at age is completed, a somewhat higher score is like to be appropriate. the species and fishery. 100 There is comprehensive and reliable information on the sub-population /sex / age structure of the stock, and the relationship of these to reproductive capacity as well as evaluations of the implications of shifts in these parameters on productivity and management quantities. Population structure is well estimated with only insignificant errors. Genetic studies have been conducted.

1.3.1.2 Does information indicate any changes in structure that would alter reproductive capacity? 50.0 80 60 Changes in stock structure have been detected but there Baseline and subsequent routine stock structure analyses have not been conducted for this species that would permit is no evidence of negative effect on recruitment of the structural change to be observed. However, the distributions of catches in surveys and commercial fisheries provides no stock. indication of either discontinuities that would imply separate stocks of the species, nor any noteworthy changes in the Or potentially adverse changes in structure are range of the species, that would suggest loss of stock sub-structure. identified and remedial measures are in the process of implementation over defined timeframes. Any changes in growth or size composition within part or all of the area may affect reproductive capacity, however, no 80 Evidence exists that the fishery has not caused changes temporal change in growth or size composition of the population has been reported to date. The majority of changes in in stock structure that would affect recruitment. the age composition of the stock are more likely attributable to the modest increase in stock productivity in the 2000s, as Or potentially adverse changes in structure are clearly documented in the 2012 assessment, and not to any depletion of older ages by the low fishing mortality. Also, although identified and effective remedial measures are in place. seasonal selectivities are fitted, they are treated as constant over the period of the assessment model suggesting a fairly 100 Data strongly indicate a robust age, sex and genetic stable size/age structure in terms of proportions at age. structure in the stock, such as would maintain reproductive capacity. While biomass and recruitment trends are positive, the stock-recruitment relationship is not well defined (low contrasts in data).

All the indicators of reproductive capacity are indirect, but none suggest that reproductive capacity of the stock has been altered detrimentally. The score would have been higher if there was a direct evaluation to show that the fishery had no harmful effects on stock structure in relation to reproductive capacity.