RAZOR FISHERY FROM PUBLIC CERTIFICATION REPORT

Client: COFRADÍA DE PESCADORES SAN MARTIÑO DE / FISHERMEN’S ASSOCIATION OF SAN MARTIÑO DE BUEU Avda. Montero Rios Edificio Lonxa 36930 Bueu – Pontevedra – Date 20 th December 2012 BUREAU VERITAS CERTIFICATION Le Guillaumet 60 avenue du Général de Gaulle 92046 PARIS LA DEFENSE Cedex - FRANCE Jacobo De Nóvoa Bureau Veritas Spanish Office Avda Finisterre 265 C 2ª Planta 15008 A Coruña, Spain [email protected]

Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 1 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

GLOSSARY

AGAMAR Asociación Gallega de Mariscadoras/es (Galician Association of Shell-fishermen) ASI Accreditation Services International BVC Bureau Veritas Certification CAB Conformity Assessment Body CIMA Centro de Investigacións Mariñas (Centre for Marine Research) CMRM Consellería do Medio Rural e do Mar (Department for the Countryside and Sea) CPUE Catch per unit effort index CSIC Centro Superior de Investigaciones Científicas (Centre for Advanced Scientific Research) DAFO debilidades, amenazas, fortalezas y oportunidades (SWOT: strengths, weaknesses, opportunities and threats) DOGA Diario Oficial de (Galician Official Gazette) DXIDP Dirección Xeral de Innovación e Desenvolvemento Pesqueiro (Directorate-General for Innovation and Fisheries Development) ETP Endangered, Threatened and Protected Species HS Harvesting Strategy IEO Instituto Español de Oceanografía (Spanish Institute for Oceanography) IPIMAR Instituto de Investigação das Pescas e do Mar (Institute for investigation of fisheries and the sea) INTECMAR Instituto Tecnolóxico para o Control del Medio Mariño (Institute for Marine Technology) JMP Join Management Plan MC Management committe MLS Minimum Landing Size MP Management Plan MSC Marine Stewardship Council NM Nautic milles NO Noroeste (Northwest) OIA Organización Internacional Agropecuaria (International Agricultural Organisation) PI Performance indicator PSA Productivity-Susceptibility Analysis PERMEX Permiso de explotación (Harvesting permit) RBF Risk-Based assessment Framework SEPRONA Servicio Protección de la Naturaleza (Service for the Protection of Nature) TA Technical Assistance UC Unit of Certification

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Table of Contents

1. Executive Summary ...... 5

2. Authorship and Peer Reviewers ...... 8

3. Description of the fishery ...... 10

3.1. Unit(s) of Certification and scope of certification sought ...... 10

3.2. Overview of the fishery ...... 11

3.3. Principle One: Target Species Background ...... 15

3.4. Principle Two: Ecosystem Background ...... 17

3.5. Principle Three: Management System Background ...... 19

4. Evaluation Procedure ...... 28

4.1. Harmonised Fishery Assessment ...... 28

4.2. Previous assessments ...... 28

4.3. Assessment Methodologies ...... 28

4.4. Evaluation Processes and Techniques ...... 29

5. Traceability ...... 36

5.1. Target eligibility date ...... 36

5.2. Traceability within the Fishery ...... 36

5.3. Elegibility to enter futher chains of custody ...... 37

6. Evaluation results ...... 39

6.1. Principle level scores ...... 39

6.2. Summary of scores ...... 39

6.3. Summary of Conditions ...... 40

6.4. Determination, Formal Conclusion and Agreement ...... 40

7. REFERENCES ...... 41

APPENDICES ...... 46

Appendix 1 Scoring and Rationales ...... 46 Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 3 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

Appendix 1.1. Performance Indicator Scores and Rationale ...... 46

Appendix 1.2. Risk Based Framework (RBF) Outputs ...... 103

Appendix 1.3. Conditions ...... 107

Appendix 2 Peer Review Report ...... 109

Appendix 3 Skateholders submissions ...... 141

Appendix 4 Surveillance frequency ...... 151

Appendix 5 Client agreement ...... 152

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1. Executive Summary

The audit team that will conduct the assessment process against the MSC standard is composed of the following members. On behalf of the accreditation body BUREAU VERITAS CERTIFICATION, as project coordinator Jacobo de Novoa , Director of Fisheries and Aquaculture, Bureau Veritas Agrofood ; Xaviere Lagadec , MSC Technical manager and Macarena García Silva as Technical assistant. The expert team that has been chosen on the basis of their experience in the areas of stock assessment, ecosystem interactions and fishery management, is Miguel José Baptista Gaspar , Principle 1 and 2 assessor, Antonio García Allut as Principle 3 assessor. In 2008 the “Cofradía de Pescadores San Martiño de Bueu” conducted a pre-assessment of the Razor Clam Fishery from Ria de Pontevedra (Galicia-Spain) against the MSC environmental standard for sustainable fishing with the Certification Body OIA. Considering the positive results they decided to start looking for funding to carry out the full assessment procedure. In this case they have chosen BUREAU VERITAS CERTIFICATION (BVC). Public notice regarding the launch of the MSC Certification Program for the razor clam of Bueu was given in September 2011. This was followed by a series of notices posted on the MSC website in order to report all phases that were taking place. First to be published was the tasks schedule, see Preliminary Assessment timeline , and the proposal and subsequent confirmation of the Assessment team . In the next stage of the assessment, Bureau Veritas announced the use of the default assessment tree contained within the MSC Certification Requirements V1.2. issued in January 2012 in the independent assessment of this Fishery. In addition, the need to consider some elements of the assessment under the MSC’s Risk-Based assessment Framework (RBF) , in particular the 1.1.1. stock status and 2.5.1. Ecosystems were identified. To start with the evaluation of the fishery compliance with the International Standard MSC, it was necessary to open an information search process regarding their 3 Principles. During the 10 th week of the year (6 th to 9 th March 2012) the Site Assessment with selected organisations or individuals with a direct interest in this fishery was announced. These visits were attended by Wetjens Dimmlich and Carolina Romero of Accreditation Services International (ASI) who supervised the tasks carried out by BVC. To outline the tasks carried out and those that are unresolved the current assessment timeline was published (Figure 1):

Figure 1. Assessment timeline (26 th January 2012)

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Prior to the site visit, the stakeholders involved in the fishery were contacted by telephone and subsequently by email in order to gather information on the fishery which had been previously identified as necessary by the experts (see subsection 4.4.1). After analysis by the audit team of all information gathered during the interviews and from the bibliographical consultation, it was concluded that the assessment tree should be revised. This modification was published on 24 th May 2012, see Revised Assessment Tree-Used of RBF . As has been announced, the assessment team only intend on assessing the Performance indicators 1.1.1 using the RBF. For those parts of the assessment involving the MSC’s RBF, the audit team used a stakeholder-driven, qualitative analysis during the site visit on the 26 th June . For the scoring meeting the audit team worked together on the 27 th and 28 th June at BVC office (, Spain). With regard to the analysis of the Project's strengths and weaknesses, we take a highly positive view of the fact that this very small scale fishery has taken the decision to undergo assessment against the MSC standard, firstly the pre-assessment and now the full assessment. The other strengths that support this assessment process are as follows: • The Fishermen are organised into well-established fisheries associations "Cofradías ". • There are no other fisheries targeting the sword razor clam. • The fishing technique used to catch arcuatus is by diving without any device to collect razor . This technique is extremely selective, since they are caught by hand, one by one. • The impact on the ecosystem is negligible. • There is an effective control and surveillance strategy in place. • The sword razor clam fishery Management Plan (MP) is common to the entire Ría de Pontevedra and is reviewed yearly in order to adapt the Harvesting Strategy (HS) to the status of the stock (based on the evolution of CPUE). • The HS included in the MP can be changed whenever necessary with the agreement of the Fishing Administration, in order to adapt the fishing effort to unpredictable factors, such as environmental conditions. • Once a year the Technical Assistance (TS) for the Management of Resources of the Cofradía de pescadores de Bueu write a report on the status of the fishery. This report is enclosed in the MP. • Communication and the relationship with public entities, such as the Consellería do Medio Rural e do Mar (CMRM) is efficient and very correct. Regarding the operability of the fishery, this is very well valued. • The product is of high quality and therefore has a high first sale value. Weaknesses • Lack of monitoring of razor clam stock (abundance, distribution, stock productivity, size structure, etc.). • Lack of knowledge on the impact of environmental factors on recruitment. • All catches are recorded at a checkpoint established at sea, however the catch on one of the extraction days is fiscally undeclared at first sale. • The prices have dropped dramatically since 2007.

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The assessment team and Certification Body Bureau Veritas concluded that the Razor Clam Fishery from Ría de Pontevedra, should be certified according to the Marine Stewardship Council Principles and Criteria for Sustainable Fisheries.

The CAB has set one condition for certification regarding the IP 3.2.3. Monitoring, control and surveillance mechanisms ensure the fishery’s management measures are enforced and complied with. To be awarded an MSC certificate for the fishery, the applicants must agree in a written contract to develop an Action Plan to meet the 'Condition' issued by the audit team.

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2. Authorship and Peer Reviewers

ASSESSMENT TEAM: Jacobo De Novoa , person in charge and coordinator of the fishery's assessment process. Oceanographer, PhD in Marine Biology and Aquaculture, Masters in Total Quality. He has been Director of the Department of Fisheries and Aquaculture at BUREAU VERITAS CERTIFICATION España since 2006. He is in charge of the technical implementation of all certification schemes for fisheries products in Spain, and MSC chief auditor. He is qualified to carry out pre-assessments and full assessments and has carried out assessments in several oceans around the world. He is also auditor for other standards such as Friend Of The Sea, IFS, BRC, Globalgap Aquaculture, ISO 22000 and many private standards relating to the fisheries sector (DOP Mejillón de Galicia, NATUR, Gamba de Palamós, PescadeRias, etc). As the Risk Based Framework (RBF) is needed for assessment, Jacobo de Novoa has participated in training through the MSC by means of CB Training in 2009 and 2011. To download a detailed CV click on the following link Antonio García Allut, Principal 3 assessor. Bachelor in Philosophy, University of Santiago de Compostela, Spain. PhD in Social Anthropology, University of Santiago de Compostela, Spain. Main research areas: traditional fisheries, fishery management, resources management and conservation, commercialization, organic traditional knowledge, participative methodologies, bottom-up process. He had been the main researcher of several projects related to the management of resources and fisheries in Galicia, seafood processing and the integration of organic traditional knowledge in fishery management systems. He was president of Lonxanet Foundations for Sustainable Fish; he has participated on the development of the marine reserve of Os Miñarzos (Lira, Galicia) and has experience working in Latin American countries. He is member of the Scientific Committee of the Maritime Museum of Galicia, Associate member of the ICSF (International Collective in Support of Fishworkers), member of Avina Foundation (sustainable development of Latin America), a fellow of Fundación Ashoka, etc. He has been working on most of this research and project activities after 1993, when he got his PhD on research about traditional fisheries and fishery management, aiming to look for better efficiency in the management of traditional fisheries.

To download a detailed CV click on the following link Miguel José Baptista Gaspar , Principle 1 and 2 assessor. He is a Senior Researcher at the Portuguese Institute for Fisheries and Sea Research (IPIMAR) of the National Institute of Biological Resources (INRB). In 1990, he completed a degree in marine biology and fisheries at the University of Algarve (Portugal) and undertook his PhD at the same university, where he studied several aspects related to the bivalve dredge fishery that occurs along the south coast of Portugal (biology and ecology of the target species, selectivity, and fishing gears impacts). After completing his PhD in 1997, he worked for IPIMAR as a fellowship researcher and became a permanent member of scientific staff in 1999. Currently, he is responsible for the management of the bivalve fishery in Portugal and heads the Invertebrate Small-scale Fisheries Research Group of IPIMAR. He has been the coordinator of several research projects regarding the ecological effects of artisanal fishing and other anthropogenic impacts on marine ecosystems, aiming to provide policy makers with the scientific information to

Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 8 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012 best manage the marine environment and fish stocks. Presently, he his coordinator of the European project “Sustainable development of artisanal fisheries in the Atlantic Area”. He is the author or co- author of more than 100 publications in international peer-reviewed journals and book chapters. He is a member of the editorial board of Scientia Marina. To download a detailed CV click on the following link

PEER REVIEWERS: Dr Andrew Brand , holds a PhD and has worked for the University of Liverpool for 40 years on the academic staff of the Port Erin Marine Laboratory, Isle of Man, retiring in 2006 as Director of the Laboratory. During this time he developed large, well-funded, research programmes on the biology, ecology, aquaculture and fisheries of bivalve molluscs, especially , and on the environmental impact of dredging. He has had extensive fishery management and environmental assessment consultancy experience, including contracts with government departments and industry, and has been a member of ICES Working Groups on herring, scallops and ecosystem effects of fishing. In addition to work in the Irish Sea, he has advised on scallops and fisheries management in Alaska, Argentina, Australia, Bermuda, Chile, Ireland, France and the Philippines. He is now an Honorary Senior Fellow of the University of Liverpool and works as an independent shellfisheries consultant. He has recent experience as an Assessor and Independent Reviewer for Marine Stewardship Council certifications for scallop, and fisheries in the Irish Sea, Faeroes, Denmark and Canada. Mr Bert Keus is an independent consultant based in Leiden, the Netherlands. He holds degrees in biology and law, and has previously held the position of Head of the Environmental Division of the Dutch Fisheries Board (Productschap Vis), and research fellow with the fisheries division of the Agricultural Economics Research Institute of Holland (LEI-DLO). During the years 2003 and 2004 he managed fishing and processing companies in the Gambia handling fish from industrial and artisanal fisheries, and he maintains his contacts with the Gambian seafood industry. In addition, he has a long association with shellfisheries, and is currently involved in the MSC assessment of the North Sea brown shrimp fishery, acting as technical advisor to this multi-stakeholder initiative, and sitting on the project’s management board. Through his work and several other MSC certifications he has become particularly familiar with the MSC certification process. Between the years 1998 and 2003 he was a member of the European Sustainable Uses Specialist Group (ESUSG), Fisheries Working Group of the IUCN.

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3. Description of the fishery

3.1 Unit of Certification and scope of certification sought

UNIT OF CERTIFICATION Target species : sword razor clam (“navaja”) - Ensis arcuatus Stock : Ría de Pontevedra (Galicia, NW Spain) Fishing method : Diving (no gear, fishing by hand). Fishing area : 27 FAO zone. North Atlantic. IX a CIEM area. Ría de Pontevedra and Ons and Onza islands (Galicia, NW Spain; 42, 25º - 42, 45º N latitude and 8, 69º - 8, 85º de W longitude), excluding Ría de Aldán, between 0 to 12 meters depth. Fisheries management : The fishery activities are managed by Galicia’s Regional Fisheries Government ( Consellería do Medio Rural e do Mar from Xunta de Galicia ). Fishers group : all the divers included in the MP of the razor clams fishery. Point of landing : San Martiño de Bueu fish auction (Lonja de San Martiño de Bueu).

The CAB has reviewed the pre-assessment report (OIA 2009) and other information available concluding the suitability on choosing the Unit of Certification (UC) above, as being in conformity with the MSC Principles. As the UC must consider other eligible fishers, the other points of landing belonging to other fishermen’s associations ( Cofradías ) where the razor clam can be landed by the divers involved in this certification has to be considered. As all the divers are involved in the UC and they can land the razor clams on different points of landings other than the client’s one ( Cofradía de pescadores de San Martiño de Bueu ), it is necessary to consider these points of landings as other eligible fishermen. Divers belong to 7 different fishermen association, one is the client, Cofradía de pescadores de San Martiño de Bueu , and there are also: Cofradías de Portonovo, , Raxó, Pontevedra, Lourizán, and Marín. In conclusion and following the initial site visits and consultation with other divers and Associations, in accordance with MSC staff and the CB, the following conditions for participation in the certification were agreed and notified both to the stakeholders and publicly on the MSC website, see Certificate sharing notice : "All divers in the razor clam fishery, provided that they land at the Bueu landing point, have been included in the unit of certification. It was also informed that other unloading points should be included in the unit of certification as "other clients eligible for certification "” Through this notification the Unit of certification is clarified and all Cofradias at all points of landings of the area are eligible to access the certification, in accordance to the sharing arrangements defined by the client. All other Fishermen’s Associations (Cofradías de pescadores ) involved in the MP of this fishery ( Cofradías de pescadores de Portonovo, Sanxenxo, Raxó, Pontevedra, Lourizán, Pontevedra and Marín ) will be eligible to be covered by this MSC certificate. The Cofradía de Pescadores San Martiño de Bueu will accept new members and new designated landing facilities on the basis of an equitable sharing of costs associated with obtaining and maintaining the MSC certificate. There are no species or stock enhancement activities at this fishery, hence it is within the scope of the MSC fishery standard.

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3.2 Overview of the fishery

Sea/freshwater area The razor clam fishery assessment is carried out in the Ría de Pontevedra (Figure 2), which is one of the four main Rias in Galicia. It is located between 42.25 o and 42.45 o of latitude N and between 8.69 o and 8.85 o of length W, with a direction NESW, curving its axis towards the north as it approaches the Atlantic Ocean. The islands of Ons and Onza form the two mouths of the Ria , whereas at their head water from the Lérez river arrives, with an average volume of 14.8 m 3 s-1. Ría de Pontevedra is 23 km long, 7.7 km wide at the Southern mouth, and 3.5 km at the Northern one. It has a total surface area of 145 km 2, a maximum depth of 60 m and a water volume of 3,447 km 3.

Figure 2 Map showing the location of Ría de Pontevedra (Galicia, NW Spain) The hydrodynamics of the Estuary depend on river discharge, water bodies in the adjacent platform, solar radiation and the wind system (de Castro et al., 2000; Gomez-Gesteira et al ., 2001; Prego et al ., 2001). It is a partially mixed estuary whose partial stratification is maintained mainly by river discharge in winter and solar radiation in summer (Alvarez et al ., 2003). This situation results in a positive estuarine circulation system in two layers (this generates two waste streams: continental water tends to exit along the surface due to its lower density, while oceanic water masses that are cooler and more nutrient-rich penetrate along the floor of the estuary in the opposite direction resulting in a mixture of both - DOG no. 241/2004). Like the rest of the de Galicia (Galician Low Estuaries) (Dyer 1973, Beer 1983), circulation is enhanced by the upwelling associated with winds in summer (Dale et al. , 2004). These persistent northerly winds on the Galician platform that cause the upwelling occur mainly between May and October (Alvarez-Salgado et al ., 1993; FEUGA 2000) and lead to the entry of nutrients into the estuaries through the deep water. This accounts for the high productivity of the Galician Low Estuaries (Prego, 1990). Management operation Competences relating to fishery management belong to the Regional Government of Galicia ( Xunta de Galicia ). CMRM is in charge of developing the legal tools necessary to design a management model of the fishing resources. Regarding shell-fishing rights, the Galician coast is divided into territorial areas belonging to professional groups (associations of fishermen called “Cofradías”, product organizations, cooperatives, etc.), which have access to historical rights over the shellfish beds located in their territorial area.

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The fishermen's associations are corporations under public law with legal personality and capacity to fulfil the purposes and functions entrusted to them. They advise and cooperate with the Public administrations in promoting the sector and represent economic and collective interests. They fall under the supervision of the Public administration of Galicia. Among other functions, they can manage (under the supervision of the Administration) areas in the maritime and maritime-terrestrial zones through an administrative title issued by the relevant authority. This last function enables them to participate in the MPs. In the present case, there are 7 Associations (Fishermen's associations of San Martiño de Bueu, Lourizán, Marín, Pontevedra, Portonovo, Raxó and Sanxenxo) that share a single MP for the razor clam (Ensis Arcuatus ), pod (Ensis siliqua ) and grooved razor shell (Solen marginatus ) which develop within Ría de Pontevedra and the islands of Ons and Onza (Galicia, NW Spain - see Figure 2), excluding Ría de Aldán, given that the Association of Aldán has its own plan (Figure 3).

Figure 3. Production areas of Ria de Pontevedra. Source Joint management plan for the Razor clam, Pod razor shell and Grooved razor shell of Ría de Pontevedra - 2012 This fishery includes populations of three species: razor clam ( Ensis arcuatus ) pod razor shell ( Ensis siliqua ) and grooved razor shell ( Solen marginatus ). Of these species, only the razor clam is currently harvested. Therefore, the remainder of the document will focus on razor clam stock. The sword razor clam fishery ( Ensis arcuatus ) in the Ría de Pontevedra, by using diving techniques began in 1995, is one of the most valuable fisheries in this area, although it is small by comparison to most bivalve fisheries in other areas of Spain. As is mentioned above, the razor clam fishery in Ria de Pontevedra is based upon the harvest of only one species, the sword razor clam, Ensis arcuatus . This species is taken by hand by free-divers or by using “hookah” equipment, where air is supplied to divers through a hose connected to an air compressor placed on the deck of the fishing vessel. Fishing takes place in very shallow waters up to 12m in depth. Razor clams live burrowed in the sediment forming galleries that are open at the surface of sediment forming a keyhole called an “eye”. Having found the “eye” in the seabed or seeing the siphons projecting above the surface, the diver quickly pushes the thumb and forefinger into the sediment and the are grasped and pulled from the seabed with a gentle 180º twisting action (Gaspar et al. , 2011; Guerra & Sánchez, 2011). (Figure 4).

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Nowadays there are 43 fishermen, using 28 boats (the same as licences), qualified to fish for razor clams located in the area included in the JMP of Ría de Pontevedra.

Figure 4. Solenidae harvesting method in Galicia by free-diving: A) moment of diving, B) signs of a razor clam's siphons in the sediment and C) harvesting of the razor clam. © Pedro Ferreiro According to a FISMARE study (November 2010) on Change in the razor clam fishery in Ría de Pontevedra towards sustainable harvesting , the trend in catches since harvesting began has been on the increase due to the progressive expansion in the number of shell-fishermen and the number of working days per year (Figure 5). Both sales and catches have been increasing. However, while sales growth has been gradual, by observing the catch data recorded at the checkpoint a sharp rise is evidenced between 2006 and 2007. This coincides with the time a sea checkpoint began to be used during harvesting. This overall trend is also reflected in the sales income, growing in parallel with the increase in catches and also reflecting fluctuations in the price of the product at first sale.

Figure 5. Change in catches at the checkpoint, sales and total income over the recorded period. Source FISMARE

In accordance with the last data provided by the Xefatura Comercial of the CMRM in Figure 6 is expressed the change in catch data for the razor clam.

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70.000 60.000 50.000 40.000 30.000 20.000 10.000

Catches(kilograms) 0 2004 2005 2006 2007 2008 2009 2010 2011

Total Catches for Razor Clam

Figure 6. Change in total catches for the razor clam. Source data provided by the CMRM, XEFATURA COMARCAL-AREA DO MAR, PONTEVEDRA Figure 7 shows change in income at first sale for the target species included in the MP from 2004 up to 2011 (entire year).

900.000 800.000 700.000 600.000 500.000 400.000 300.000

euros(€) 200.000 100.000 0 2004 2005 2006 2007 2008 2009 2010 2011

Income Razor Clam

Figure 7. Change in income at first sale. Source: data provided by the CMRM, XEFATURA COMARCAL-AREA DO MAR, PONTEVEDRA

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3.3 Principle One: Target Species Background

3.3.1 Biology of the sword razor clam KINGDOM ia PHYLUM CLASS Bivalv ia SUBCLASS ORDER Veneroida FAMI LY GENUS Ensis SPECIE Ensis arcuatus (Jeffreys, 1865) COMMON Sp. - Navaja NAME En.-Sword Razor Clam Ga.- Navalla

Shell description: Thin and brittle shell, elongated, equivalve and inequilateral. The dorsal margin of the shell is almost straight and the ventral margin slightly curved. Both anterior and posterior margins are obliquely truncate. Sculpture of fine lines following the growth stages. The right valve has one cardinal tooth and one lateral tooth, subsequently elongated. The left valve has two, projecting, peg-like cardinal teeth and two, elongate, posterior laterals, one above the other. Adductor scars and pallial line is distinct. Anterior adductor elongate, dorsal, extending to behind ligament, posterior small, round, separated from pallial sinus . Shell colour: White or cream, with reddish or purplish brown streaks and blotches. The is glossy, light olive or yellow-brown, darker grey-green along posterior dorsal region. In the periostracum a diagonal line is distinguished dividing two different areas: dorsal, with horizontal lines, and ventral with vertical lines. White inner surfaces, tinted with pink or pale purple. Distribution and habitat: The sword razor clam Ensis arcuatus is a Northeast Atlantic temperate species that is distributed from Norway to Spain and along the British coast (Hayward & Ryland, 1998), where it lives buried in sand or coarse sand in low intertidal and subtidal areas at a depth of up to 40m (Tebble, 1966; Poppe & Goto). The foot is large, extended and adapted for burrowing which allows razor clams to burrow themselves very fast and very deep into the sediment (up to 60cm) (Gaspar et al. , 2011). Their short siphons indicate that their usual position in the sediment is close to the surface. Reproduction: Ensis arcuatus have separate sexes and are broadcast spawners, i.e. eggs and sperm are released into the water and fertilization is external. This species has a relatively short larval life and good Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 15 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012 larval survival rate, with metamorphosis occurring around 20 days after hatching at a length of 378.81+37.08 μm (da Costa et al ., 2008). The reproductive cycle of E. arcuatus is annual and comprises a rest phase that takes place during summer, followed by a rapid and intense process of gametogenesis beginning at the start of autumn, leading to successive spawning and restoration in winter and spring that last until June (Darriba et al ., 2004; Hernández-Otero et al. , 2011a). In Ría de Pontevedra, Hernández-Otero et al. (2011) reported slightly differences in the reproductive cycle of the razor clams that occur in the inner (Brensa) and middle (Bueu) beds of the Ria when compared with populations from Ons, a delay existing at the beginning of the reproduction and an extension of the gonadal restoration phase in this latter bed. This species in Ría de Pontevedra becomes sexually mature at a shell length of 79 mm, during the first year of life (Hernández-Otero et al. , 2012). Growth: Growth of Ensis arcuatus is faster during the first three years of life, declining when they are about four-six years old and growth almost stopping in subsequent years, reaching maximum size at the age of eight-nine years old. They attain the average population length within four-five years and present a maximum longevity of 12-13 years old (Hernández-Otero et al., 2011b, 2012). Hernández- Otero et al. (2011b, 2012) studied the age and growth of Ensis arcuatus from three razor clams beds (Brensa, Bueu and Ons) located in the Ría de Pontevedra. The growth pattern obtained for the three

sites studied were significantly different, with razor clams growing faster in Ons (VBGC: L t = 161.95 –0.45 (t + 0.52) – 0.42 (t + 0.38) (1- e ) than in Brensa (VBGC: L t = 150.04 (1 - e ). –0.40 (t + 0.23) Sword razor clams from Bueu showed the lowest growth rate (VBGC: L t = 140.44 (1 -e ). E. arcuatus of the Ría de Pontevedra reaches commercial size (100mm) in 1.6 years in the outermost bed (Ons), in 2.25 years in the inner bed (Brensa) and in 2.9 years in the middle bed (Bueu). Differences in growth rates may be related to differences in environmental parameters concerning sediment type and local hydrodynamics. Indeed, these authors observed that growth was correlated positively with salinity and negatively with temperature for all sites but no relationship was found with food concentration since any significant differences were observed in chlorophyll a concentration among beds. Regarding sediment, the Brensa bed is characterized by having a higher gravel percentage than the other two beds and the sediment is more compacted (higher mud percentage), that presents higher resistance to burrowing. This may also have a negative effect on growth since resistance to burrowing causes a loss of energy for growth. A greater growth rate observed at the outermost bed of Ons could be related to its most oceanic conditions, associated with lower residence time, and to finer and looser sediment (Hernández-Otero et al. , 2012).

3.3.2 Stock Status and Reference Points Most of the exploited bivalve populations, such as sword razor clams, in the Iberian Peninsula show large spatial and temporal fluctuations due to the fishing effort coupled with high variability in success of spatfall and recruitment (e.g. Kraan et al ., 2008; Beukema et al. , 2010). Indeed, dynamics of sword razor clams stocks are peculiar due to their short lifespan and high variability in

recruitment. Therefore, for most species, reference indicators such as B MSY or F MSY are not used to evaluate the status of the stocks. Moreover, since razor clams can burrow very deep into the sediment, up to 60 cm, the monitoring of its populations becomes extremely difficult. In this way, the monitoring of razor clams can be performed by divers using suction devices or by dredges. Both sampling techniques may have huge impacts on the ecosystem and therefore should be avoided, especially in the case of the Ria Pontevedra.

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3.3.3 History of fishing and management In Ría de Pontevedra, Solenidae fishery was initially performed by clam razor trawl net – fishing gear towed from a vessel. The reasons for the prohibition of this fishing gear was based mainly on the high mortality caused to the populations, the high rate of breakage of individual clams and the impact of the mechanical trawl on the structure and biological communities on the sedimentary floors (Fismare, 2010a). In 1995, Solenidae (sword razor clam - Ensis arcuatus -, pod razor shell – E. siliqua - and grooved razor shell - Solen marginatus -) fishing in Ría de Pontevedra began to be carried out using diving techniques. The first association to harvest the resource using this technique was Portonovo, which from 2000 was joined by the Associations of Raxó, Pontevedra and Lourizán. This resulted in a JMP. In 2002, the Associations of Marín and Bueu joined the plan which brought to an end the "Management Plan for razor clams with use of a trawl net " that was practised on the south bank of Ría de Pontevedra. Up to this date, production data, the number of active shell-fishermen, CPUE and income all saw gradual increases. Between December 2002 and March 2003 harvesting of the resource was suspended due to the accident involving the "Prestige" tanker. Once the danger had passed shell- fishing activity resumed (1 st of April 2003). The healthy functioning of this fishery was a major economic boost to the seafaring community of Ría de Pontevedra. Both harvesting and income arising from this activity showed continued growth, reaching during 2007 over 60 tons of razor clam sold at fish market and about € 800.000 annual turnover. (See Figures 6 & 7). This was the case until 2008. Since then, catches, income and the number of shell-fishermen attending the fishery daily have all declined, especially income. A MP is produced annually (Garazo, 2005; Miñambres, 2006, 2007; Macho, 2008; Ferreiro, 2009, 2010, 2011; Pastoriza, 2012) where a range of management measures and objectives for the fishery are set out. Management of the fishery is based on a combination of input and output controls. Such controls include: i) limited entry, given through fishing licenses; ii) minimum landing sizes; iii) daily quota per diver; iv) total number of fishing days per month; v) limited fishing hours per day; vi) closed season; and vii) rotational harvesting areas. These management restrictions help to limit the fishing effort, thereby sustaining the species and the supporting environment. Although there are no reference points for the fishery, these controls are used to maintain razor clams populations at adequate levels. The management strategy is reviewed on an annual basis and takes into consideration both CPUE and structure of the target species’ catches.

3.4 Principle Two: Ecosystem Background

3.4.1 Ecosystem: general information In general the ecosystem is fairly well studied. Indeed, there is quite good information on both the abiotic and biotic part of the Ría de Pontevedra ecosystem, but information regarding trophic relationships between species that occur within the Ria is missing. The information that is available to describe the ecosystem is as follows :

Abiotic part: • Physical-chemical characterization of seawater of Ria Pontevedra (Encisa, 2004) • Hydrodynamics of the Ria de Pontevedra (including upwelling events) (e.g. Fraga, 1981; Cabanas et al. , 1982; Blanton et al. , 1987; McClain et al. , 1986; Tilstone et al ., 1994; Prego

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& Bao, 1997; deCastro et al. , 2000; Gómez-Gesteira et al ., 2001; Prego et al. , 2001; Álvarez et al ., 2003; Dale et al. , 2004; Fismare 2010a; González et al. , 2010). • Mapping of the razor clam beds. (Fismare, 2010b) • Sedimentary characterization of the razor clams beds (Encisa, 2004; Castaño et al. , 2010) Biotic part: • Description of the bivalve species associated with the sword razor clam beds. (Fismare, 2010b) • Description of the macrobenthic communities of the Ría Pontevedra. Influence of environmental parameters on the distribution of the main macrobenthic groups (Encisa, 2004) • ETP species are listed for Galicia (http://www.faunagallega.es.tl/# and http://www.medioruralemar.xunta.es/ .)

3.4.2 Retained and bycatch species Razor clams are individually gathered by hand, hence it is a target-specific fishery and therefore there is virtually no overlap with other commercial fisheries as there is no use of bait, no by-product from the fishery, virtually no bycatch or retained species and no other commercial fisheries in Ría de Pontevedra target razor clams. Due to the high selectivity of the fishery there is no need to implement a specific strategy for bycatch and retained species.

3.4.3 Endangered, Threatened and Protected Species (ETP) Among the species listed and taking into consideration the habitat and distribution of razor clams, the ETP species that are most likely to be affected by the fishery are the bivalve Eastonia rugosa , the sea fan Eunicella verrucosa , the reptiles Dermochelys coriacea and Carretta carretta , the pelagic seabird Puffinus mauretanicus , the bird Phalacrocorax aristotelis , and the marine mammals Eubalaena glacialis and Tursiopis truncatus . Notwithstanding this, since these species do not rely on razor clams for food, as well as the fact there is no bycatch or retained species, it is likely that the razor clam fisheries do not affect any of them. Although these species may live on, or travel through, areas used by razor clam harvester vessels, especially near Ons island, there would be a low risk of injury or disturbance to those species since no interaction between the commercial fishery and the ETP species listed is expected. To date, no interaction between ETP and razor clams vessels during transit between the port and fishing grounds or during harvesting operations has been reported. It is also important to underline that the study carried out by Fismare (2010b) to assess the condition of the razor clam populations within Ria de Pontevedra did not identify the bivalve Eastosina rugosa as a species that occupies the same habitat as Ensis arcuatus , indicating that the sword razor clam fishery does not affect that ETP species. In this fishery no fishing gears are used and therefore impact and/ or interaction on/with ETP species are unlikely to occur. Thus there is no need to implement a specific strategy for ETP species in this fishery.

3.4.4 Habitat To understand the impact that may be produced by fishing on the habitat, it is fundamental to know the location of fishing grounds in order to characterize the habitats where the fishery takes place. The sword razor clams beds in Ría de Pontevedra were characterized by Fismare (Fismare, 2010a, b)

Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 18 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012 and the results showed that sword razor clams occur in clean sandy or coarse-sand sediments. Reviews of the impact of fishing on soft sediments were done by e.g. Sebe & Guerra (1997), Jennings & Kaiser (1998), Kaiser et al. (2001) and Gaspar et al. (2011). The impacts reported by these authors include sediment re-suspension, changes in sediment granulometry due to the transport by currents of the fine fraction of the sediment, sediment fluidization, release of nutrients and/or contaminants to the water column, formation of trenches and changes in seabed topography. The severity of the impact on the sediment depends on i) the type of technique/ fishing gear used; ii) fishing effort; iii) amount of area disturbed; iv) local hydrodynamics; and iv) fishery management. The sword razor clam fishery occurs in the shallow waters up to 12m depth (Guerra & Sánchez, 2011). In this fishery no fishing gear is used. Sword razor clams are individually gathered by hand by divers in free-diving or using hookah. Razor clams are detected in the sediment through the typical hole formed in the sediment or through the siphons projecting above the surface. Once the razor clam is located the diver quickly pushes his/her thumb and forefinger into the sediment and the animals are grasped and pulled from the seabed with a gentle twisting action. This technique does not stir up sediment and although some sediment is disturbed only a tiny part is re-suspended and associated species are not affected by the fishery. Furthermore, since divers only harvest razor clams at a depth of up to 12m, only a part of the habitat is disturbed. Finally, the risks to protected areas and habitat from movement of boats would be negligible because of the small number of vessels and the lack of contact between vessels and the seabed.

3.4.5 Ecosystem impacts The information available is sufficient to infer the impact of razor clam fishing on the ecosystem. Gaspar et al . (2011) carried out a review of the literature concerning the environmental impact of bivalve fishing, with particular stress on techniques and gear used for razor clam fishing. The impact on sediment, associated biological communities, bycatch species and on target species of the several fishing techniques/gears used in razor clam harvesting were described and ranked. With this purpose, these authors applied a Delphi Survey technique and multi-criteria analysis based both on the results provided by the studies already undertaken and on the knowledge of experts. Each category was analysed separately and a qualitative classification was given to each one of the techniques or gear, with impact rated as high, moderate, low or negligible. Compared to other fishing methods (e.g. hydraulic dredging, mechanical dredging and clam kicking) the ecosystem effects of dive fisheries (such as the razor clam fishery) are benign (Jenkins, 2004). Indeed, the results of Gaspar et al. (2011) showed that of the fishing techniques and fishing gear used in subtidal areas, hand picking and salting were considered as having a negligible impact on the physical environment, on associate benthic communities, on bycatch (low impact) and on the target species (both below and above the MLS). Therefore, the ecosystem impact of hand-harvested methods (salting and hand-picking) was classified as low. Other techniques using rudimentary fishing gears (pincher tongs, clam gun or tube, double hook, metallic rod, shovel, grubber hoe and razor clam rake) were considered as having a moderate impact on the ecosystem, whereas clam “kicking”, razor clam dredges and hydraulic dredges were classified as high-impact fishing methods.

3.5 Principle Three: Management System Background

3.5.1 Area of operation of the fishery and under which jurisdiction it falls Management of the fishery falls under the jurisdiction of the Autonomous Government of Galicia (Spain-EU). Galicia is an autonomous community belonging to the Kingdom of Spain, a parliamentary monarchy and member of the EU since January 1986. Therefore, national and regional fisheries Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 19 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012 policies must conform to the legal framework for broader political management established by the EU. The Government of Spain transfers legal powers to Galicia on matters of fishing and shell fishing in inshore waters through Article 148.1.11 of the Spanish Constitution which is enshrined in the Statutes of Autonomy of Galicia in Article 28.5. Royal Decree 3318/82 on the transfer of functions and services of the State Administration to Galicia lists these competences that concern fishing and shell fishing. The Autonomous Government of Galicia, through the CMRM, its Secretariat and various directorate- generals and services, is empowered to establish/ implement the Fisheries Law of Galicia 11/2008 of 3 rd December, as amended by Law 6/2009 of 11 th December and monitors fisheries, through its instruments of management and control, in order to ensure their sustainability. The Fisheries Law of the Autonomous Government of Galicia is divided under fourteen headings integrating all functions, instruments and mechanisms that interact with each other in order to implement the management system and that affect both commercial fishing and other activities and users who could have a significant impact on fishery resources: Heading I, General provisions; Heading II, Conservation and management of fish and shellfish resources; Heading III, Sea fishing; Heading IV, shell fishing; Heading V, Marine aquaculture; Heading VI, The Galician fishing fleet; Heading VII, Fisheries sector organizations; Heading VIII, Trading; Heading IX, Sustainable development of fishing and shell fishing; Heading X, Research and technological development; Heading XI, Inspection and control, rescue and pollution; Heading XII, Training in sea fishing; Heading XIII, Registrations; and Heading XIV, The penalty system. Galician jurisdiction over fisheries is centred on the inshore waters along the Galician coast and on all those activities defined as "shell fishing", which operate both in inshore waters and the territorial sea of the State (up to 12 NM). The current Fisheries Law of Galicia defines shell fishing as "the exercise of harvesting activity, carried out on foot or from a vessel in the maritime or maritime-terrestrial (intertidal) zones, directed exclusively at, and with selective and specific fishing gear, the capture of one or several species of molluscs, crustaceans, tunicates, echinoderms and other marine invertebrates, for trading purposes." A definition similar to that proposed in the "Update to the National Strategic Plan for the European Fisheries Fund (2007-2013)." The case at hand, i.e. the Solenidae fishery, concerns an activity characterised as "shell fishing". As for the Solenidae harvesting areas, focusing on the fishery under assessment, these are located on the floors of Ría de Pontevedra (Pontevedra-Galicia-Spain) and those that surround the islands of Ons and Onza. The latter are situated in the mouth of the same estuary (See Figure 3). Figures 8 and 9 show the production areas from the 2012 MP for razor clams. The Production Zones are arranged among seven Harvesting Areas. Each is identified numerically and by place name (see caption on photos): from Area 1 (Portonovo) to Area 7 (Ons). In turn, the different Solenidae beds are located in each area and represented numerically and with the addition of the prefix PO corresponding to the abbreviation for Ría de Pontevedra, starting with PO1, PO2, ..., up to PO110.

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Figure 8. Razor clam harvesting areas in Ría de Pontevedra. Source: Joint management plan for the Razor clam, Pod razor shell and Grooved razor shell in Ría de Pontevedra – 2012

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Figure 9. Razor clam harvesting areas in Ría de Pontevedra. Source: Joint management plan for the Razor clam, Pod razor shell and Grooved razor shell in Ría de Pontevedra – 2012

3.5.2 Particulars of the recognised groups with interests in the fishery Groups recognised as having interests in the fishery are classified as groups belonging to the Autonomous and State Administrations as well as private groups and individuals with economic and social interests in the fishery. All organisations, institutions and individuals involved in the fishery are easily identifiable and are defined explicitly. There are a number of public institutions and agencies, linked to the Autonomous Government such as the CMRM and DXIDP with specific roles, functions and responsibilities, that act in an interrelated manner and ensure the sustainability of fisheries on a regulatory, administrative, monitoring and control basis ( Coast Guard and Fisheries Inspection Service, Checkpoint Water Bailiff), maritime safety ( Maritime Rescue ), workplace safety ( Maritime Authority ) and from the point of view of biological monitoring (TA; Area Biologists , Territorial Authority ), CIMA , and health aspects of water quality and food safety including microbiological and biotoxins monitoring of bivalve molluscs (INTECMAR ), etc.. In addition, there are other public institutions and agencies that work with these institutions, especially those linked to research such as Galician universities and state centres for marine research such as IEO , CSIC and other state agencies that complement the monitoring process for food safety, poaching, coastal and marine environmental impact, etc. such as SEPRONA. As far as the sector is concerned, the respective Associations, divers that make up the JMP and traders have all been identified. The fishermen's associations have a role, among others, to look after their members and ensure the fishery's sustainability with the objective of creating employment with decent economic conditions. A fishery in healthy condition also generates income for the associations as these are the organisations that manage the first sale of the catches through fish markets. The fishermen's associations are, in turn, represented by Federations with provincial jurisdiction (A Coruña, Lugo, Pontevedra), the latter by a Galician Federation with regional jurisdiction, which in turn is represented by the National Federation of Associations . In this regard the associations, through their various representations, have the function of safeguarding the interests of the fisheries sector at the local, provincial, regional and national levels.

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The divers, representing the productive and social elements of the fishery, are associated with the respective associations that make up the JMP. They are the stakeholders most directly involved and interested in the sustainability of the fishery under assessment. Finally, the traders with an interest in the Solenidae fishery have a key economic function. They are the ones that buy the product and set the prices at first sale (fish market). This is a key factor in understanding the fishery's ups and downs based on the fluctuation of prices.

3.5.3 Details of consultations leading to the formulation of the management plan and the decision-making process or processes, including the recognised participants Decree 423/1993 of 17 th December on consolidation of the current regulations on shell fishing, as amended by Decree 237/ 2002 of 11 th July , establishes that Solenidae harvesting is subject to the MP. The latter are designed with the aim of achieving better management and regulation of the fishery and enabling more efficient and sustainable harvesting. Decree 423/1993 (17 th December) regulates the MP and defines the maximum daily quotas per diver, maximum fishing days per year, number of shell-fishermen per fishery, opening and closing of areas, species, minimum sizes, trading, etc.. Decree 237/2002 (11 th July) , a modification of the previous one, converts these plans which initially lasted indefinitely into Annual Shellfish Management Plans. Each year an Order is published (the one for this year is the Order of 23 rd December/2011 ), establishing authorisations for specific production areas, activity days, probable times of harvesting, checkpoints, etc. This Order sets out the conditions that must be included in the MP so that, once approved and implemented, the sustainable harvesting of the resource is ensured. In late October, the Associations submit the MP to the CMRM with information included from the first three quarters of the current year to enable the CMRM to compare data with previous years. The mechanisms for designing the MP allow divers that are integrated into the Joint Plan to participate actively in the process and in managing the fishery. The MP has two distinct sections that are consistent with the fishery's objectives. A specific or technical section, which corresponds essentially to the biological and productive aspects of the fishery with the main objective of ensuring its sustainable harvesting. The general section of the MP, corresponding to the fishery's socioeconomic objectives which aim to provide a decent means of living for its members. The design of the specific section of the MP is the responsibility of the fishery's TA. It contains the management proposal based on available biological data as well as data collected from previous MPs. Mainly primary sources are used, such as the daily summary reports received from the fishery's checkpoint (water bailiff), as well as point sampling, sizes, change in CPUE (catch per unit effort) for the area harvested as well as information provided by the divers. This information is used to assess the fishery and defines the MP: probable beds, quotas per diver, harvesting days per year, etc. The MP's technical proposal is submitted to the Area Biologist for review/ modification. The MP's general section is proposed by the divers with support from the AT. Its ratification is the responsibility of the associations that are integrated into the PEC. It puts forward a socioeconomic proposal: number of licenses proposed, estimated annual production and income per license. Once the proposal has been made, the association delegated for signature (this rotates every two years) must ratify it.

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Once the Plan is approved by the Association in charge of its management, it is referred to the relevant Territorial Authority for review by the area biologist and later by the area biologists coordinator for Pontevedra province.

The Territorial Authority refers the MP to the Central Services of the Regional Government of Galicia which forwards it to the DXIDP for approval and/ modification. The proposal to increase the number of licenses can be put forward by either the divers or the CMRM. Proposals to increase the number of licenses are always based on the estimated state of the resource (feasibility study) and the extra effort that the fishery is able to support. The final decision rests with the CMRM. The MPs also include a financial plan, a penalty system, monitoring of harvesting and plan of actions to be taken to improve the fishery. Once the MP has been submitted, the CMRM, in order to safeguard the process, requests technical reports on key aspects of the fishery and, if appropriate, introduces the necessary improvements to ensure sustainable harvesting of the fishery. In cases of modification, an open dialogue is established between the CMRM and AT and the Management Committee (MC) for the JMP until final ratification is published in the DOGA. The MC's objective is to improve the decision-making capacity of its members in relation to requests for opening up harvesting areas, changing areas, organisation of surveillance and control, etc. Changes of representatives are communicated in writing to the Territorial Authority. The MC in turn has a representative from the shell-fishermen collective who acts as intermediary between them, the associations and the CMRM. Once the whole process is complete, a summary of the MP is published online: http://www.pescadegalicia.com/ The fishery is highly supervised and interactive by incorporating mechanisms and channels that enable participation by the divers in the design of the MP and in communicating with the Fisheries authorities.

3.5.4 Arrangements for on-going consultations with interest groups Decree 423/1993 (17 th December) on consolidation of the current regulations on shell fishing, as amended by Decree 237/2002 (11 th July), makes explicit the consultative character with regard to formulation of the MP. The technical and socioeconomic formulation of the MP requires a highly participatory system of consultation between all stakeholders: divers, checkpoint, AT, associations, Area Biologist, Territorial Authority, the DXIDP and CMRM. The process is transparent and incorporates both scientific and local knowledge. The institutions representing the productive sector (associations) receive information regarding the proposal for their approval. In a complementary manner, the Solenidae fishermen can request the authorities to refine any points that are insufficiently clear during a consultation period prior to approval of each MP. In short, the consultation process provides the incentive for all stakeholders to participate in a significantly open process.

3.5.5 Details of non-fishery users or activities, which could affect the fishery, and arrangements for liaison and co-ordination The fishery allows access exclusively to licensed divers belonging to the JMP under assessment. There are no other fisheries or other actors external to the fishing activity that interferes with the Solenidae harvesting. Impacts on the resource from other activities external to the fishery (tourism;

Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 24 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012 sport fishing; anchoring; poaching, etc.) are insignificant and do not affect the biodiversity of the habitat or the fishery's sustainability.

3.5.6 Objectives for the fishery The Fisheries Law of Galicia explicitly expresses that the main objective of fisheries management under the jurisdiction of the Autonomous Government of Galicia is the sustainability of the resource in order to sustain the local populations who depend on fishery resources. For the Solenidae fishery under assessment, as complete information on the stock is lacking, a management strategy for the fishery has been developed based on short-term objectives (the annual plans) and by using a precautionary approach for each management plan. From the socioeconomic point of view, the MP is designed to ensure that the fishery provides a decent annual income for its members and, as a minimum, maintains the same number of jobs in the fishery. The aim will be to improve or at least maintain the current status of the resource to facilitate the granting of new licenses and to increase the number of divers in the fishery. As for the goals from the point of view of biodiversity and ecology, the fishery has a very low environmental impact given the type of techniques used to harvest the resource. In this fishery, Solenidae harvesting uses a highly selective manual technique that allows them to be caught individually and alive. If they do not meet the correct regulatory size they can be returned to the substrate without damage. The degree of selectivity is very high. The fishery does not interfere with or impact on other species associated with the same substrate. Over 90% of catches correspond to the razor clam, with the remainder being the pod razor shell and grooved razor shell. Harvesting area VII (Ons), situated in the surroundings of the Atlantic Islands National Park of Galicia, under the jurisdiction of the Autonomous Community and regulated by Law 15/2002 of 1 st July , permits small-scale fishing activities to be carried out (Article VI) without coming into conflict with the JMP for Solenidae. From the point of view of scientific research, it would be of considerable value to the fishery's long- term objectives to improve the level of knowledge about the fishery through scientific research that is more appropriate to and geared towards the reality of the fishery, both by the CIMA and INTECMAR. Nonetheless, the MP seems to be a reliable instrument for achieving the fishery's objectives in terms of socioeconomic and environmental sustainability (resources). To promote these objectives, primarily those relating to the resource and improvement of the fishery, the CMRM sends out annual public calls for proposals to the associations in order to improve significant aspects of their fisheries. These public calls for proposals act as positive incentives that can help to improve the fishery's sustainability objectives. It is a fact that the associations integrated into the JMP have used this funding proactively by submitting proposals that focus on resolving specific and well-defined issues facing the fishery.

3.5.7 Outline the fleet types or fishing categories participating in the fishery While the Galician fisheries legislation allows small-scale vessels alternative access to up to five different fisheries, most divers in the JMP focus exclusively on the Solenidae fishery and do not alternate with other ones. To exercise the harvesting activity it is a requirement to hold a professional diving certificate in the appropriate categories, to have the appropriate harvesting permit (PERMEX) and to be integrated into the JMP for Solenidae in Ría de Pontevedra. All members of the Solenidae fishery meet these requirements. These PERMEX are granted to the vessels and are regulated by Decree 114/2007 (31 st

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May) that amends Decree 425/1993 (17 th December) on consolidation of the current regulations on harvesting permits for fishing and shellfishing activities. Vessels registered with the Joint Plan can hold between 1 and 3 licenses for Solenidae harvesting depending on their GRT and/or GTs. The criteria for allocation of licenses are set by the CMRM. Licenses are transferable only through the sale of the vessel. In the MP (2012) for the fishery under assessment, there are 43 harvesting licenses corresponding to 28 registered vessels: 18 vessels with 1 license (18), 8 vessels with two licenses each (16) and three vessels with three licenses each (9). The vessels are mostly constructed from fibre and are smaller than 10 GRT or 10 GTs. Ownership of the vessels is mostly individual with the vessel owner being directly involved in the activity as a diver. Vessel owners with two or more licenses hire as many divers as possible under their licenses to carry out the activity. As a general rule, income from a vessel's activity is distributed weekly. 20% of total income goes to the vessel with the remainder being divided evenly between each diver. The activity timetable is from 8:00 to 14:00 Monday to Friday. Direct control of the activity is implemented by the water bailiff at the checkpoint. All vessels are equipped with a space for the supply of surface air and comply with on board and workplace safety regulations stipulated by the Maritime Authority.

3.5.8 Details of those individuals or groups granted rights of access to the fishery, and particulars of the nature of those rights Access rights with respect to the shell-fishermen's resources are explicit and legally protected by the legal codification system (indefinite licenses renewable annually) that governs formal access to the fishery. Shell fishing is an activity in which access rights to resources have been regulated since the enactment of Decree 423/1993, through a clear legal framework, and therefore there are no customary rights of other potential users who may require access to the fishery. There are no such conflicts in the fishery under consideration.

3.5.9 Description of the measures agreed upon for the regulation of fishing in order to meet the objectives within a specified period. These may include general and specific measures, precautionary measures, contingency plans, mechanisms for emergency decisions, etc. The annual MP sets out the principal measures to regulate each of the fishery's species with the objective of ensuring the sustainability of the resource and the divers. In the case of the razor clam the following are defined: months of harvesting (10), activity days per month (20), timetable (from 8:00 to 14:00), daily catch limits per diver (15 kg), harvesting areas and months under fishing ban (2). The months under fishing ban are usually February and March on the basis that at this time the species may be undergoing its peak spawning activity. The MP also includes a series of actions to improve the Management Plan: removal of predators (starfish; algae); collection of samples for monitoring the fishery by the TA or for research centres (CIMA; INTECMAR); a schedule of activities to be carried out during the year, etc. The MP clearly sets out the water bailiff's functions (Checkpoint): conduct the daily monitoring of harvesting as per what is stipulated for checkpoints; perform internal and external monitoring of the resource and apply penalties if necessary; monitor and report compliance with the Safety Plan;

Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 26 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012 collect the samples requested by INTECMAR; inform the TA, associations and the CMRM with regard to changes from the main area to secondary area, or vice versa, due to reasons of poor visibility or any other incidence of the MP, etc..

3.5.10 Particulars of arrangements and responsibilities for monitoring, control and surveillance and enforcement The TA is in charge of monitoring the Solenidae fishery in Ría de Pontevedra, on the ground. It is responsible for monitoring the fishery. It transfers data on a monthly basis from the fishery to a virtual support via FTP for review and analysis by the Area Biologist and INTECMAR. The TA is assigned to the Joint Plan. The TA is based in the Fishermen's association of San Martiño de Bueu and drafts the MP's technical part. The Fisheries Surveillance and Inspection Agency performs its duties at sea and onshore, during transportation of the goods (formalised transportation paperwork is a requirement), in the landing zone in the port and during the auction of the catch at first sale (fish markets). Its presence is arbitrary or may follow on from explicit complaints. The Surveillance Agency also inspects the premises where Solenidae are sold (restaurants, etc). They may be prohibited from sale due to a period under ban, because the fishery has been shut down following an administrative order (toxins) or owing to a lack of the necessary documentation (traceability) to ensure safe human consumption. Some of these functions are complemented by SEPRONA's service. In addition, the fishery has a checkpoint. The checkpoint is implemented on board the specific Surveillance Service vessel for this fishery and is located within the harvesting area in use. Its functions are: to conduct daily monitoring of harvesting according to the methodology required by the associations recording vessel, crew present, kgs extracted per diver, sizes, time spent on harvesting per diver, etc.. It also must ensure that all vessels have passed through the checkpoint. It also produces a daily summary report with catch data for each diver which is signed by each of them.

3.5.11 Details of any planned education and training for interest groups There are training courses sponsored by the CMRM that are mainly intended for producers. Certification as " Specific Resources Collector using Diving Techniques ", which is provided for free by the CMRM, is a prerequisite for obtaining a licence. Professional diving qualifications, which are not usually free, can be validated through the previously mentioned certification as long as the diver demonstrates certified competence in some biological field (graduate in Biology, Marine Science, Aquaculture professional training or any other shell fishing certification provided by the CMRM).

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4. Evaluation Procedure

4.1 Harmonised Fishery Assessment

At the time of writing this document the fishery does not overlap with any other certified fishery or applicant.

4.2 Previous assessments

In 2008, the Fishermen's associations of San Martiño de Bueu, San Andres (Lourizán), Santa Maria del Puerto (Marín), San Telmo (Pontevedra), San Roque (Portonovo), San Gregorio (Raxó) and Santa Rosalía (Sanxenxo) of Galicia, commissioned a Pre-assessment from OIA. The UC identified in this pre-assessment coincides with the one defined in the current full assessment. It should be highlighted with respect to the latter assessment that, although the client is exclusively the Fishermen's association of San Martiño de Bueu, the UC brings together the 7 Associations listed in section 3.2. The harvesting method is carried out manually by diving and comes under a single MP for the razor clam with regard to the entire Ría de Pontevedra. The results from the pre-assessment were presented in the form of a SWOT analysis (strengths, weaknesses, opportunities and threats). At the time of making the Pre-assessment there was no specific format for the presentation of results. There now is one and the MSC Pre-Assessment Reporting Template document (Version 1.0, August 2011) must be observed. The technical report includes, in partial form, detailed information regarding the indicators for consideration by the OIA of the key issues in relation to the MSC Principles and Criteria. The tables presented in the report assess the responses obtained but are only to be used as guides, given that " the quantitative assessment of the fishery is conducted during the Full Assessment ". This is the first full assessment, so there are no conclusions reached.

4.3 Assessment Methodologies

The assessment process uses the MSC Certification Requirements, version 1.2-10 of January 2012 document. The format used for the pre-assessment report is the MSC Full Assessment Reporting Template, Version 1.2 – 10 th January 2012 . The assessment team has decided to use the Default Assessment tree (see Figure 10) for all performance indicators less than the IP 1.1.1. Stock status with assessment via the use of the risk- based framework (RBF). The reason stated by the assessment team for using the RBF for assessment of PI 1.1.1. is that “ there is limited information available about absolute size of the stock for this species (there is information for 2009). Some information about catch and stock size is not available. There are no clearly defined reference points for the stocks .”

Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 28 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

Figure 10. Default assessment tree structure for Principles 1, 2 and 3. MSC Certification Requirements, version 1.2

4.4 Evaluation Processes and Techniques

4.4.1 Site visits 31 st January 2012 saw the publication on the MSC website of the notice concerning the site assessment by the audit team to the fishery's stakeholders, see Announcement of site assessments marine stewardship council certification . The communication process with regard to the fishery's stakeholders was implemented as follows: Contact was first made by phone to explain the procedure for assessment against the MSC standard and our interest in their participation during this stage of information gathering, as stakeholder in the process. Once their participation was accepted, they were emailed about the proposed visit to their facilities (date and place) and the information that would be requested from them at such time. The information to be gathered during meetings would be mainly related to: the form of carrying out fishing activities, management plan, views about the state of the razor clam beds, compliance with the control system, etc. After confirmation of the date, time and place they were sent an official letter about the visit from the Bureau Veritas audit team and their participation as stakeholders in the fishery. This letter requested more detailed information in accordance with the agency and role of the recipient in question.

Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 29 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

The visits took place during the week of 5-9th April across different areas of the Galician territory (See Figure 11). The agenda was the following:

Monday, 5 th March 2012

8:00 – 18:00 Tasks team meeting. Place: Vigo

Tuesday, 6 th March 2012

Fishermen's association of San Martiño de Bueu 8:00 – 12:00 Place: Bueu Pedro Ferreiro, Technical of the fishermen association

Fishermen's association of San Cipriano of Aldan-hio Place: 12:30 – 13:30 Cangas Juan Manuel Gregorio, fishermen association president 14:30 – 15:30 Food

Fishermen's association of San Andrés de Lourizán 17:00 to 20:00 Place: Lourizán Maria Carmen Vázquez, fishermen association president

Wednesday, 7 th March 2012

Fishermen's association of "San Roque"de Portonovo Place: 17:30 – 20:00 Portonovo Jose Antonio Gómez, fishermen association president

Thursday, 8 th March 2012

Department for the Countryside and Sea Place: Pontevedra 9:00 – 11:30 Rosa Ramonell, Area Biologists Coordinator for Pontevedra Maria del Carmen García Alonso, Area Biologist for Ría de Pontevedra Deputy Directorate -General for Coastguards of Galicia Place: Santiago Lino Sexto, head of service 12:00 – 14:00 Secretariat-General for the Sea José Molares, Deputy Director for Planning and Marine Resources 14:30 – 15:30 Food AGAMAR 17:00 – 19:00 Place: Santiago Natalia Laiño, association president

Friday, 9 th March 2012

Centre for Marine Research (CIMA) Place: Vigo 9:00 – 11:00 Alejandro Guerra, Director of CIMA Alberto de Coo, scientist at CIMA

Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 30 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

University of Vigo 12:00 – 13:00 Place: Vigo Elsa Vázquez Otero, Professor of Zoology

Conference call wi th NGOs 13:00 – 15:00 Place: Vigo

Figure 11. Locations visited during the information gathering sessions The following is the list of participants in both site meetings as well as other contacts involving exchange of information via email. See Appendix 3

ORGANIZATION CONTACT ADDRESS Cofradía de Pescadores de “San Martíño” de Avda. Montero Ríos s/n 36930 Bueu Bueu (Fishermen’s Association) Pedro Ferreiro (PONTEVEDRA) Edif lonja Peirao de Aldán, 21 -OPORTO DE Cofradía de pescadores San Cipriano de Aldan- ALDAN - 36945 Cangas hio (Fishermen’s Association) Juan Manuel Gregorio (PONTEVEDRA) Cofradía de Pescadores de “San Andrés” de Areal, 6 - LOURIZAN - 36910 Lourizán (Fishermen’s Association) Maria Carmen Vázquez Pontevedra (PONTEVEDRA) Rafael Picó, 44 - PORTONOVO - Cofradía de Pescadores de “San Roque” de 36970 Sanxenxo (PONTEVEDRA) Portonovo (Fishermen’s Association) Jose Antonio Gómez Entrada al puerto Federación Gallega de Cofradías de Pescadores Benito González Department for the Countryside and the Sea Rosa Ramonell Rúa Fernández Ladreda 43, 4ª planta, Department for the Countryside and the Sea Maria del Carmen Garcia 36003 (PONTEVEDRA) Secretariat - General for the Sea José Molares Rua de Valiño número 71 CP 15703 Deputy Directorate - General for Countryside Santiago de Compostela and Sea Lino Sexto Oscar García AGAMAR Compostela Agamar Natalia Laiño R/ Miguel Ferro Caaveiro, Nº 12, 1º Joaquin Espinosa 15707Santiago de Compostela (A Elsa Vázquez Universidad de Vigo: Campus University of Vigo Juanjo Pasante Universitario C.P. 36.310 Vigo Gonzalo Macho Juan Freire Botana

Calle de la Maestranza, 9 15001 A Paulino Martínez University of Coruña Coruña Ana Insua

Jose Mora Alejandro Guerra Pedras do Coron s/n 36620 Vilanova CIMA Alberto de Coo de Arousa ONGs: WWF; ADEGA; Greenpeace; Oceana, Oficinas Bureau Veritas C/ Conde de Accion Costeira; Asociacion por la defensa de Torrecedeira 67/69. entresuelo VIGO la ria Table 1. Stakeholder contacts of the fishery The next site visit was conducted on 26 th June 2012 in order to perform the RBF. It took place at the premises of the Fishermen's association of San Martiño de Bueu throughout the entire morning. Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 31 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

Section 4.4.3. and Appendices 1.2 and 3 provide greater information on the procedure that took place during the day, the participants and results obtained.

4.4.2 Consultations The following stakeholders were interviewed during the site visits carried out in Galicia on the 6th to the 9th March 2012. FISHERMEN ASSOCIATIONS: Cofradía de pescadores San Martiño de Bueu (Fishermen’s Association) Cofradía de pescadores “San Cipriano” de Aldan-hio (Fishermen’s Association) Cofradía de Pescadores de “San Andrés” de Lourizán (Fishermen’s Association) Cofradía de Pescadores de “San Roque” de Portonovo (Fishermen’s Association) FISHERY MANAGEMENT BODIES Consellería do Medio Rural e do Mar (Department for the Countryside and Sea) Secretaria Xeral do Mar (Secretariat-General for the Sea) Subdirección Xeral Gardacostas de Galicia (Deputy Directorate-General for Coastguards)

AUCTIONS/ LANDING POINTS San Martiño de Bueu fish auction – Pontevedra Portonovo fish auction

SCIENTIFIC AND RESEARCH ORGANISATIONS University of A Coruña University of Vigo University of Santiago de Compostela INTECMAR CIMA

ENVIRONMENTAL PUBLIC AND NON-GOVERNMENTAL ORGANISATIONS AND OTHERS FISMARE, Innovation for Sustainability AGAMAR

The information obtained during meetings with stakeholders was significantly broad and variable depending on the persons interviewed. At the start of each meeting Jacobo de Novoa gave an introduction about the MSC and the assessment process to be used for the fishery. The Unit of Certification was clarified. The assistants then presented themselves and the meeting commenced. After presenting themselves, the MSC Principles experts asked pertinent questions about the doubts that arose from assessing the initial information and requested any other information or documentation that might be of assistance when scoring the fishery. The following is a summary of the issues covered: Fishermen's association • Design and communication process behind the Management of San Martiño de Bueu Plan for razor clams • Suggestions for improving the Plan • Monitoring of compliance and poaching Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 32 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

• Traditional rights • Contributions, sizes, harvesting process, predatory species • Technical assistance tasks • Fismare Study Association of Aldán • Formation of the Association • Communication on the certification process • Suggestions for improving the Plan • Monitoring of compliance and poaching • Specific legislation • Traditional rights Association of Louriz án • Design and communication process behind the Management Plan for razor clams • Quotas, sizes, status of stock • Monitoring of compliance and poaching • Study on population and recruitment in Lourizán (CIMA) • Technical assistance tasks • Impact on marine protected areas, predatory species Association of Portonovo • Design and communication process behind the Management plan for razor clams • Quotas, sizes, status of stock • Monitoring of compliance and poaching Department for the • Design and communication process behind the Management Countryside and Sea plan for razor clams • Times, quotas, checkpoints, number of fishermen • Technical assistance tasks • Figure "section agent" • Fismare Tasks • Monitoring of compliance and poaching • Fishery assessment in terms of sustainability Deputy Directorate - • Poaching control and monitoring actions General for Coastguards • Studies on biomass, status of stock • Profitability of the activity Secretariat-General for • Diving qualifications the Sea Agamar • Biology of the target species • Management plans • Distribution and abundance of the target species in Ria de Pontevedra • Stock status and reference points Centre for Marine • Razor clam predators Research (CIMA) • ETP species • Fishing impact University of Vigo • Biology and Ecology of the target species • Management plan • Distribution and abundance of the species in Ria de Pontevedra • Recruitment • Stock status and reference points • Fishing impact Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 33 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

4.4.3 Evaluation Techniques All communications regarding the assessment process were made by email to all stakeholders in the fishery as well as publicly through the MSC website, see Razor clam fishery of Ría de Pontevedra – MSC . The assessment process for the razor clam of Ría de Pontevedra was also published in the national and international press.

Figure 12. News regarding the fishery's assessment process After the team has compiled and analysed all relevant technical, written and anecdotal information, they scored the fishery against the Performance Indicators and Scoring Guideposts in the final tree. For a first approximation of the fishery's score a conference call was held on June 8 from 10 am to p.m. between the audit team. During this conversation there was a discussion about the scores relating to principles 1 and 2. On 27 th and 28 th June, all information having been collected and analysed, the audit team held a meeting to determine the final score for the assessment of the razor clam fishery of Ría de Pontevedra. In order for the fishery to achieve certification, none of the Performance Indicators can score below 60. In order to achieve a score of 80, all of the 60 scoring issues and all of the 80 issues shall be met and each scoring issue shall be justified by supporting rationale. Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 34 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

Used of the Risk-Based assessment Framework (RBF) The assessment team has previously confirmed the use of the default assessment tree contained within the MSC Certification Requirements V1.2 issued on 10 th January 2012 in the independent evaluation on this Fishery. The use of MSC’s Risk-Based assessment Framework (RBF) has also been announced to score a Performance Indicator for this assessment. Initially, the use of RBF on two performance indicators was considered, 1.1.1. on status of stock and 2.5.1. on ecosystem, due to the lack of relevant information, see Confirmation of assessment tree marine stewardship council certification , 6th March 2012. Subsequently, the auditors decided that there was no need for greater information regarding performance indicator 2.5.1 as the impact of this fishery on the ecosystem is minimal and therefore the use of RBF was unnecessary. The revised decisions tree was published in a notice on 17 th May 2012, see Revised Assessment Tree –use of RBF marine stewardship council certification . As the team has concluded that there is insufficient data to score the fishery using the default tree outcomes SGs, the RBF may be used. As is identified in table CC1: Restrictions on the use of the RBF (Annex CC) , the performance indicator for 1.1.1. stock status shall be done through a qualitative analysis (Scale Intensity Consequence Analysis – SICA) and then a semi-quantitative analysis (Productivity Susceptibility Analysis – PSA). See Appendix 1.2 Risk Based Framework (RBF) Outputs for the results on scoring for PI 1.1.1. According to the results presented in Appendix 1.2., the highest impact factor (the most vulnerable scoring element) with respect to the fishery relates to its own activity. With this in mind, the following tables were completed: Table 1.2.1. Principle 1 SICA Scoring Template Target Species and Table 1.2.2. Productivity-Susceptibility Analysis to obtain a score for PI 1.1.1 The audit team carried out a stakeholder consultation process to gather data and seek expert opinions. For this reason BUREAU VERITAS Certification invited the stakeholder of the fishery assessed by the Marine Stewardship Council to the Risk Based Framework meeting that was held on 26 th June starting at 9.30 in Cofradía de pescadores de San Martiño de Bueu facilities (Bueu- Pontevedra-Galicia) . See Figure 14.

Figure 13. Photos of RBF meeting days 26 th June 2012 See Section 8.3 for the list of participants at the RBF meeting and the interview protocol.

Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 35 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

5. Traceability

5.1 Target eligibility date

The Actual Eligibility Date for this fishery will be the 30 th of November 2012 . This means that any sword razor clam caught by the certified fleet following that date will be eligible to enter the chain of custody as certified product if and when certification is ultimately granted. The rationale for this date is that it was the date specified in the Final Report with the agreement of the applicant fishery. The CAB considered that on the certification date, the traceability and the segregation systems would be properly implemented so as to ensure that all the sword razor clam identified and sold as certified by the fishery originate from the certified fishery.

5.2 Traceability within the Fishery

5.2.1 Description of the tracking, tracing and segregation systems within the fishery The monitoring, control and surveillance system in place in the fishery comprises: - Checkpoint PHASE: all divers forming part of the UC make a mandatory stop at the checkpoint where the water bailiff performs the following functions: • Weigh the catch in situ • Apply a seal in the form of numbered flanges to avoid any risk of harvested product being substituted • Recording all catches per vessel and endorsing the point of sale certificate (Bueu) with the number of kgs caught that day or comparing sales from Bueu for the following day with catches from the previous day. - Transportation to point of sale PHASE: Producers transport the razor clam by sea (on their vessels) or land (in air-conditioned vehicles for the transportation of fresh produce). Transportation takes place once they have passed through the sea checkpoint. For land transportation, producers must obtain a document at origin which is certified at destination with regard to the source of the produce. - Product classification and packing PHASE: The Producers (shellfish divers) classify the razor clam and pack it in plastic boxes of up to 15 kilos. During classification damaged razor clams are removed (broken shell, mutilation of foot, etc.) which in general are very few. Classification involves distributing the produce among the number of boxes that producers consider appropriate by size. Typically, when working from the same harvesting bed there are small differences in size and classification is according to one size only. - Produce receiving PHASE: The classified and packed produce is received by market staff that weighs and enters it as lots into the computer system. The lots are traced from their origin. The auction staff ensures that during weighing the shellfish remain under hygienic sanitary conditions and comply with the rules on sizes. If any incident should occur the produce is removed from the process of first sale and returned to the sea or destroyed as appropriate.

Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 36 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

- Auction PHASE: The classified, packaged and labelled lots are put to public auction. Any authorised buyer can participate in the public auctions at the Fish Market (by registering in the Fish Market and meeting the relevant legal requirements). The process is carried out by electronic Dutch auction with buyers pausing it when they think the price is appropriate. During the pause, the buyers select which lots they wish to take. Any remaining unsold lots will be put back to auction until all the shellfish has been allocated. The shell-fishermen may recall the product if they consider that the price does not meet their expectations of fairness. In this case the shellfish is set aside from the auction and removed, enabling the shell-fishermen to take it to another point of sale, bring it back the next day or return it to the sea. - Shipping PHASE: Once the shellfish has been auctioned and allocated to the buyers it is shipped. During this process each buyer must declare the amount that they will take away to the authorised treatment plants. It is a sanitary condition that shellfish from areas of Class B water quality should pass through a treatment plant. Razor clams from areas of Class A water quality have to pass through an authorised shipping centre. To date, there are no areas of Class C water quality with beds in Ría de Pontevedra. - Billing PHASE: The product is billed to the buyers by the Fish Market which initially makes a purchase from the shell-fishermen in order to sell on to the buyers, taking a commission of 5% to cover the costs of the facilities.

5.2.2 Possibility of vessels fishing outside the unit of certification There is no such possibility because the fishing license (PERMEX) is only valid within the territory defined in the management plan and therefore the unit of certification.

5.2.3 Opportunity for substitution of certified fish with non-certified fish prior to and at the point of landing As specified in the first point, the water bailiff at the sea checkpoint seals the bags that contain the catches with a numbered flange. This phase is prior to transportation by sea and/ or land thereby avoiding any possible mixing of certified products with uncertified ones.

Neither at-sea processing activities nor transhipment activities are taking place in this fishery.

5.3 Eligibility to enter further chains of custody

As was explained in point 3.1 Unit of certification, there are other points of landing belonging to other fishermen’s associations (Cofradías) where the razor clam can be landed by the divers involved in this certification.

At the moment only the landing point for the Fishermen's association of San Martiño de Bueu forms part of the UC under assessment. Nevertheless, the Fishermen's associations of Portonovo, Sanxenxo, Raxó, Pontevedra, Lourizán and Marín, will be eligible to be covered by this MSC certificate If they accept the conditions established by the Client of this full assessment.

To conclude, the scope of the fishery certificate will comprised, all the divers included in the MP of the Razor Clam fishery using diving techniques are eligible to use the fishery certificate. For the time being there is just one landing point were the chain of Custody should commence following, at Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 37 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012 which point the product shall be eligible to carry the MSC logo (under restrictions imposed by the MSC Chain of Custody standard).

Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 38 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

6. Assessment results

6.1 Principle level scores

Final Principle Scores Principles Score Principle 1 – Target Species 86 .3 Principle 2 – Ecosystem 96,7 Princip le 3 – Management System 85 .6 Table 2 Final Principal Scores

6.2 Summary of scores

Principle Wt Component Wt PI No. Performance Indicator (PI) Wt Weight in Contribution to (L1 (L2) (L3) Principle Score Principle Score ) Either Either One 1Outcome 0,5 1.1.1 Stock status 0,5 0,25 100 25,00 1.1.2 Reference points 0,5 0,25 80 20,00 1.1.3 Stock rebuilding Management 0,5 1.2.1 Harvest strategy 0,25 0,125 90 11,25 1.2.2 Harvest control rules & tools 0,25 0,125 80 10,00 1.2.3 Information & monitoring 0,25 0,125 80 10,00 1.2.4 Assessment of stock status 0,25 0,125 80 10,00 Two 1Retained 0,2 2.1.1 Outcome 0,333 0,0667 100 6,67 species 2.1.2 Management 0,333 0,0667 100 6,67 2.1.3 Information 0,333 0,0667 100 6,67 Bycatch 0,2 2.2.1 Outcome 0,333 0,0667 100 6,67 species 2.2.2 Management 0,333 0,0667 100 6,67 2.2.3 Information 0,333 0,0667 100 6,67 ETP species 0,2 2.3.1 Outcome 0,333 0,0667 100 6,67 2.3.2 Management 0,333 0,0667 100 6,67 2.3.3 Information 0,333 0,0667 80 5,33 Habitats 0,2 2.4.1 Outcome 0,333 0,0667 100 6,67 2.4.2 Management 0,333 0,0667 100 6,67 2.4.3 Information 0,333 0,0667 85 5,67 Ecosystem 0,2 2.5.1 Outcome 0,333 0,0667 100 6,67 2.5.2 Management 0,333 0,0667 100 6,67 2.5.3 Information 0,333 0,0667 85 5,67 Three 1 Governance 0,5 3.1.1 Legal & customary framework 0,25 0,125 100 12,50 and policy 3.1.2 Consultation, roles & 0,25 0,125 100 12,50 3.1.3 responsibilitiesLong term objectives 0,25 0,125 80 10,00 3.1.4 Incentives for sustainable 0,25 0,125 85 10,63 Fishery 0,5 3.2.1fishing Fishery specific objectives 0,2 0,1 80 8,00 specific 3.2.2 Decision making processes 0,2 0,1 80 8,00 management 3.2.3 Compliance & enforcement 0,2 0,1 70 7,00 system 3.2.4 Research plan 0,2 0,1 80 8,00 3.2.5 Management performance 0,2 0,1 90 9,00 evaluation Table 3. Summary scores

Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 39 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

6.3 Summary of Conditions

Table 6.3: Summary of Conditions Related to Condition Performance previously raised Condition number Indicator condition? (Y/N/N/A)

By the second surveillance audit, the fishery under assessment and therefore all the divers which form part of the MP for the razor clam fishery of the Ría de Pontevedra, must eradicate the unregulated sale of one of the weekly quotas 1 and ensure that all catches are sold in the fish 3.2.3. N auction and are registered for tax purposes. By the third surveillance audit the fishery must also demonstrate that there is no evidence of systematic non-compliance and therefore a high degree of confidence.

6.3.1 Recommendations As was indicated in point 3.3.2. Stock Status and Reference Points , reference indicators such as BMSY or FMSY are not used to evaluate the status of the stocks for this kind of bivalve populations, such as razor clams. Moreover, since razor clams can burrow very deep into the sediment, up to 60 cm, the monitoring of its population becomes extremely difficult. Therefore, a Proxy should be used and a reference point should be set in the future to assess the status of the razor clam stock of Ría Pontevedra. This recommendation would affect Principle 1, mainly the Performance Indicators PI 1.1.1. and PI 1.1.2.

6.4 Determination, Formal Conclusion and Agreement

The fishery assessed has achieved a score above 80 against each of the MSC Principles. Following this decision by the assessment team, and review by stakeholders and peer-reviewers, the determination will be presented to Bureau Veritas Certification's decision making entity that the Razor Clam Fishery from Ria de Pontevedra has passed its assessment and should be certified.

Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 40 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

REFERENCES

Álvarez, I., deCastro, M., Prego, R., Gómez-Gesteira, M., 2003. Hydrographic characterization of a winter-upwelling event in the Ria of Pontevedra (NW Spain). Estuarine, Coastal and Shelf Science 56: 869–876. Beukema, J.J, Dekker, R., Philippart, C.J.M., 2010. Long-term variability in bivalve recruitment, mortality, and growth and their contribution to fluctuations in food stocks of shellfish-eating birds. Marine Ecology Progress Series, 414: 117–130. Blanton, J. O., Tenore, K. R., Castillejo, F., Atkinson, L. P., Schwing, F. B., Lavin, A., 1987. The relationship of upwelling to mussel production in the Rias on the western coast of Spain. Journal of Marine Research 45: 79–90. Cabanas, J. M., Gonzalez, J. J., Iglesias, M. L., 1982. Physical chemical conditions in winter in the Ria of Pontevedra (NW Spain) and their influences on contamination. ICES-CM, E 53, 15 (International Council for the Exploration of the Sea). Castaño, M.A.N., Fidalgo, R.R., Rodríguez, A.M., 2010. Caracterización del sustrato sedimentario en los bancos de navaja, longueirón y longueirón vello en la Ría de Pontevedra. (Characterisation of the sedimentary substrate in beds of razor clam, pod razor shell and grooved razor shell in Ría de Pontevedra.) In: Evaluación de la pesquería de navaja de la Ría de Pontevedra hacia una explotación sostenible. (Assessment of the razor clam fishery in Ría de Pontevedra towards sustainable harvesting.) Estudio del entorno físico de los bancos de navaja en la ría de Pontevedra: hidrodinámica y caracterización de fondos sedimentarios. (Study of the physical environment of razor clam beds in Ría de Pontevedra: hydrodynamics and characterisation of sedimentary floors.) Informe técnico, Grupo Oceanografía Física de la Universidad de Vigo (Technical Report, Physical Oceanography Group, University of Vigo): 56-116. Constantino, R., Gaspar, M.B.,, Pereira, F., Carvalho, S., Cúrdia, J., Matias, D., Monteiro, C.C., 2009. Environmental impact of razor clam harvesting using salt in Ría Formosa lagoon (Southern Portugal) and subsequent recovery of associated benthic communities. Aquatic Conserv: Mar. Freshw. Ecosyst. 19: 542–553. Da Costa, F., Darriba, S., Martínez-Patiño, D., 2008. Embryonic and larval development of Ensis arcuatus (Jeffreys, 1865) (: Pharidae). J. Mollus. Stud. 74 (2): 103-109. Dale, A.W., Prego, R., Millward, G.E., Gómez-Gesteira, M., 2004. Transient oceanic and tidal contributions to water exchange and residence times in a coastal upwelling system in the NE Atlantic: the Pontevedra Ria, Galicia. Marine Pollution Bulletin 49: 235–248. Darriba, S., San Juan, F., Guerra, A., 2004. Reproductive cycle of the razor clam Ensis arcuatus (Jeffreys, 1865) in northwest Spain and its relation to environmental conditions. Journal of Experimental Marine Biology and Ecology 311 (1): 101–115 Darriba, S., San Juan, F., Guerra, A., 2005. Energy storage and utilization in relation to the reproductive cycle in the razor clam Ensis arcuatus (Jeffreys, 1865). ICES J. Mar. Sci. 62 (5): 886-896. Darriba, S.C., 2001. Biología de la navaja ( Ensis arcuatus Jeffreys, 1865) de la Ría de Vigo (N.O. de España: Crecimiento y reproducción. (Biology of the razor clam ( Ensis arcuatus Jeffreys, 1865) in Ría de Vigo (NW Spain: Growth and reproduction.) PhD Thesis, University of Vigo, pg. 297.

Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 41 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012 deCastro, M., Gomez-Gesteira, M., Prego, R., Taboada, J. J., Montero, P., Herbello, P., Perez-Villar, V., 2000. Wind and tidal influence on water circulation in a Galician Ria (NW Spain). Estuarine, Coastal and Shelf Science 51: 161–176. Ensica, J.M.P., 2004. Cartografía biosedimentaria y comunidades bentónicas de los fondos blandos submareales de las rías de Pontevedra y Aldán y la ensenada de La Lanzada. (Biosedimentary mapping and benthic communities of subtidal soft floors in Pontevedra and Aldan Estuaries and La Lanzada Inlet.) PhD Thesis, Santiago de Compostela University, pg.654. Fernández, M.M., 2005. Plan de explotacion conxunto da navalla, longueiron e longueiron vello da Ria de Pontevedra – 2006. (Joint management plan for the razor clam, pod razor shell and grooved razor shell in Ría de Pontevedra – 2006.) Fernández, M.M., 2006. Plan de explotacion conxunto da navalla, longueiron e longueiron vello da Ria de Pontevedra - 2007. (Joint management plan for the razor clam, pod razor shell and grooved razor shell in Ría de Pontevedra - 2007.) Fismare, 2010a. Estudio del entorno físico de los bancos de navaja en la ría de Pontevedra: hidrodinámica y caracterización de fondos sedimentarios. (Study of the physical environment of razor clam beds in Ría de Pontevedra: hydrodynamics and characterisation of sedimentary floors.) Informe técnico (Technical report), pg.126. Fismare, 2010b. Evaluación de la pesquería de navaja de la Ría de Pontevedra hacia una explotación sostenible: Estudio e integración de los aspectos biológicos e hidrodinámicos en su explotación: I. Elaboración de una cartografía digital de alta resolución de los bancos marisqueros de navaja y longueirón; (Assessment of the razor clam fishery in Ria de Pontevedra towards sustainable exploitation: Study and integration of biological and hydrodynamic aspects in their harvesting: I. Development of a high resolution digital mapping of shellfish beds of razor clam and pod razor shell;) II. Evaluación directa del estado de las poblaciones de navaja y longueirón en la Ría de Pontevedra. (II. Direct assessment of the status of razor clam and pod razor shell populations in Ría de Pontevedra.) Informe técnico (Technical report), pg. 168. Fraga, F., 1981. Upwelling off the Galician Coast, Northwest Spain. In F. A. Richards (Ed.), Coastal upwelling (pg. 176–182). Washington, DC: American Geophysical Union. Gaspar, M.B., Constantino, R., Guerra, A., Carvalho, S., 2011. Environmental impacts of razor clam fisheries. In: Razor clams: biology, aquaculture and fisheries (A. Guerra, C.L. Seijo, M. Gaspar, F. Da Costa, ed.), Xunta de Galicia: 227-270. Gómez-Gesteira, M., deCastro, M., Prego, R., Pérez-Villar, V., 2001. An unusual two layered tidal circulation induced by stratification and wind in the Ria of Pontevedra (NW Spain). Estuarine, Coastal and Shelf Science 52: 555–563. Gonzalez, J.M, Porto, G.R., la Granda, F., 2010. Estudio hidrodinámico de la ría de pontevedra para evaluar el acoplamiento físico-biológico en la fase larvaria. (Hydrodynamic study of Ría de Pontevedra to evaluate physical-biological attachment during the larval stage.) In: Evaluación de la pesquería de navaja de la Ría de Pontevedra hacia una explotación sostenible. (Assessment of the razor clam fishery in Ría de Pontevedra towards sustainable harvesting.) Estudio del entorno físico de los bancos de navaja en la ría de Pontevedra: hidrodinámica y caracterización de fondos sedimentarios. (Study of the physical environment of razor clam beds in Ría de Pontevedra: hydrodynamics and characterisation of sedimentary floors.) Informe técnico, Grupo Oceanografía Física de la Universidad de Vigo (Technical report, Physical Oceanography Group, University of Vigo): 7-55.

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Guerra-Díaz, A., Gabín-Sánchez, C., 2011. Commercial razor clam fisheries in Spain. In: Razor clams: biology, aquaculture and fisheries (A. Guerra, C.L. Seijo, M. Gaspar, F. Da Costa, ed.), Xunta de Galicia: 305-322. Hayward, P.J., Ryland, J.S., 1998. Handbook of the marine fauna of North-West Europe. Oxford University Press, Oxford. Hernández-Otero, A., Gaspar, M.B., Macho, G, Moura, P., Ferreiro, P., Martínez-Castro, C., Torres- Machado, A., Vázquez, E., 2011. Age and growth of the razor clam Ensis arcuatus (Jeffreys, 1865) from the Ría of Pontevedra (NW Spain). Congresso Latino-Americano de Ciências do Mar (XIV COLACMAR), 30 th October - 4th November 2011, cidade de Balneário Camboriú, Brazil. Hernández-Otero, A, Gaspar, M.B, Macho, G, Moura, P., Ferreiro, P, Martínez-Castro, C., Torres- Machado, A., Vázquez, E., 2011b. Age and growth of the razor clam Ensis arcuatus (Jeffreys, 1865) from the Ría de Pontevedra (NW Spain). XIV Congresso Latino-Americano de Ciências do Mar (XIV COLACMAR), 31 st October-4th November 2011, Santa Catarina, Brazil. Hernández-Otero, A., Ferreiro, P., Gaspar, M.B., Macho, G., Martínez-Castro, C., Moura, P., Nombela, M.A., Rosón, G., Torres-Machado, A., Vázquez, E., 2012. Growth, age and size at sexual maturity of the sword razor clam Ensis arcuatus (Jeffreys, 1865) from the Ría de Pontevedra (NW Spain). Hernández-Otero, A., Macho, G., Martínez-Castro, C., Torres-Machado, A., Ferreiro, P., Vázquez, E., 2011a. Gonadal macroscopic characteristics as a management tool in a razor clam fishery. : Foro Iberoamericano dos Recursos Marinhos e da Acuicultura (IV FIRMA), 27-29 th October, Viana do Castelo, Portugal. Hernández-Otero, A., Macho, G., Martínez-Castro, C., Torres-Machado, A., Ferreiro, P., Vázquez, E., s.d. Gonadal macroscopic characteristics as a management tool in a razor clam fishery, pg. 8. Hernández-Otero, E., Castro, C.M, Otero, A.H., Machado, A.T., 2010. Evaluación de la pesquería de la navaja ( Ensis arcuatus ) de la Ría de Pontevedra hacia una explotación sostenible: estudio e integración de los aspectos biológicos e hidrodinámicos en su explotación: Biología de la navaja. (Assessment of the razor clam ( Ensis arcuatus ) fishery in Ría de Pontevedra towards sustainable exploitation: study and integration of biological and hydrodynamic aspects in their harvesting: Biology of the razor clam.) Informe Técnico (Technical Report), Vigo, pg.66. Jenkins, G.P., 2004. The ecosystem effects of fishing: a review. Marine and Freshwater Research 55: 545-552. Kaiser, M.J., Collie, J.S., Hall, S. J., Jennings, S., Poiner, I.R., 2001. Impacts of fishing gear on marine benthic habitats. Reykjavik Conference on Responsible Fisheries in the Marine Ecosystem, pp 18. Kraan, C., Dekinga, A., Folmer, E.O., van der Veer, H.W., Piersma, T., 2008. Macrobenthic fauna on intertidal mudflats in the Dutch Wadden Sea: Species abundances, biomass and distributions in 2004 and 2006. NIOZ-Report 2007-2, pg. 40. McClain, C. R., Chao, S., Atkinson, L. P., Blanton, J. O., Castillejo, F., 1986. Wind driven upwelling in the vicinity of Cape Finisterre, Spain. Journal of Geophysical Research 91: 8470–8486. Otero, J.A., Solis, L., Alcalde, A., Barreiro, B., Martinez, B., Simón, A., Otero, X., Fernande, J. A., Silva Salvado, S., Garcia, O., Espinosa, J., De Coo, A., Fariña, J., García, A., 2012. Dinámica de poboaciones e xestión productiva en bancos naturales de navalla ( Ensis arcuatus , Jeffreys, 1865). (Population dynamics and productive management in natural beds of the razor clam ( Ensis arcuatus , Jeffreys, 1865).) Primeiros resultados en varias zonas de Galicia. (Initial results from several areas of Galicia.) Informe técnico (Technical report).

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Pastoriza D.M., 2011. Plan de explotacion conxunto da navalla, longueiron e longueiron vello da Ría de Pontevedra – 2012. (Joint management plan for the razor clam, pod razor shell and grooved razor shell in Ría de Pontevedra – 2012.) Peña, V., Bárbara, I., 2007. Los fondos de maërl en Galicia. (Maërl beds in Galicia.) Algas 37, Boletín Informativo de la Sociedad Española de Ficología (Newsletter of the Spanish Society for Phycology), pg. 18. Prego, R., & Bao, R. (1997). Upwelling influence on the Galician coast: silicate in shelf water and underlying surface sediments. Continental Shelf Research 17: 307–318. Prego, R., deCastro, M., Gómez-Gesteira, M., Taboada, J. J., Montero, P., Pe´rez-Villar, V., Dale, A., 2001. Micro-scale hydrography of the Pontevedra Ria NW Spain. Journal of Geophysical Research 1069: 19845–19857. Poppe, G.T., Goto, Y., 1993. European seashells. Vol. II (Scaphopoda, Bivalvia, Cephalopoda). Verlag Christa Hemmen, Germany. Rice, J.C., Connolly, P.L., 2007. Fisheries management strategies: an introduction by the Conveners. ICES Journal of Marine Science 64:577-579. Rivero, G.M, 2007. Plan de explotacion conxunto da navalla, longueiron e longueiron vello da Ria de Pontevedra – 2008. (Joint management plan for the razor clam, pod razor shell and grooved razor shell in Ría de Pontevedra – 2008.) Sebe, M.P., Guerra, A., 1997. Análise das artes dedicadas à extracción de solénidos (navalla, longueirón e longueirón vello). (Analysis of the fishing gear dedicated to the harvesting of Solenidae (razor clam, pod razor shell and grooved razor shell).) Xornadas técnicas sobre o desenvolvemento productivo do marisqueo a pé (Technical seminars on the productive development of shellfishing on foot), Santiago de Compostela, 13th and 14 th March, Spain. Tebble, N., 1966. British bivalve seashells. A Handbook for Identification. British Museum, Edinburgh, pg. 212. Tilstone, G. H., Figueras, F. G., Fraga, F., 1994. Upwelling–downwelling sequences in the generation of red tides in a coastal upwelling system. Marine Ecology Progress Series 112: 241–253. Velasco, P.F., 2008. Plan de explotacion conxunto da navalla, longueiron e longueiron vello da Ria de Pontevedra – 2009. (Joint management plan for the razor clam, pod razor shell and grooved razor shell in Ría de Pontevedra – 2009.) Velasco, P.F., 2009. Plan de explotacion conxunto da navalla, longueiron e longueiron vello da Ria de Pontevedra – 2010. (Joint management plan for the razor clam, pod razor shell and grooved razor shell in Ría de Pontevedra – 2010.) Velasco, P.F., 2009. Plan de explotacion conxunto da navalla, longueiron e longueiron vello da Ria de Pontevedra – 2010. (Joint management plan for the razor clam, pod razor shell and grooved razor shell in Ría de Pontevedra – 2011.)

LEGAL REFERENCES Artículo 148.1.11 de la Constitución española (Article 148.1.11 of http://noticias.juridicas.com/base_datos/A the Spanish Constitution) dmin/constitucion.t8.html Estatutos de Autonomía de Galicia en el artículo 28.5 (Statutes of http://noticias.juridicas.com/base_datos/D Autonomy of Galicia in Article 28.5) erogadas/r0-ga-l8-2004.html

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Ley de Pescade Galicia del 11/2008, del 3 de diciembre, http://www.xunta.es/Doc/Dog2009.nsf/Fic modificada por la Ley 6/2009 del 11de diciembre (Fisheries Law haContenido/39DB6?OpenDocument of Galicia 11/2008 of 3 rd December, as amended by Law 6/2009 of 11 th December) General fishing and shellfishing Management Plan: http://www.xunta.es/Doc/Dog2002.nsf/Fic haContenido/B646?OpenDocument Decreto 423/1993, 17 de diciembre, por el que se refunde la normativa vigente en materia de marisqueo, modificado por el Decreto 237/2002, de 11 de julio (Decree 423/1993 of 17 th December on consolidation of the current regulations on shellfishing, as amended by Decree 237/2002 of 11 th July) Orden del 23 diciembre/2011 que regula y define las condiciones http://www.xunta.es/dog/Publicados/2012 para presentar el Plan de Explotación (Order of 23 rd /20120102/AnuncioCA06-271211- December/2011 that regulates and defines the conditions for 10441_es.html submitting the Management Plan) Ley del régimen sancionador 11/2008, 3 diciembre (Penalty http://noticias.juridicas.com/base_datos/C system law 11/2008 of 3 rd December) CAA/ga-l11-2008.t14.html Decreto 114/2007, (de 31 de mayo), de modificación del Decreto http://www.xunta.es/Doc/Dog2007.nsf/Fic 425/1993, (de 17 de diciembre) (Decree 114/2007 (31 st May) , haContenido/1CADA?OpenDocument amending Decree 425/1993 (17 th December) ) Decreto 210/2000, (de 21 de julio) (Decree 210/2000 (21 st July)) http://www.xunta.es/Doc/Dog2000.nsf/F ichaContenido/11EE2?OpenDocument

Orden de 31 de marzo de 2011 por la que se modifica la Orden de http://www.xunta.es/Doc/Dog2011.nsf/Fic 26 de octubre de 2004 ( Order of 31 st March 2011 , amending the haContenido/12CD2?OpenDocument Order of 26 th October 2004) Decreto 97/2005, (de 17 de abril) (Decree 97/2005 (17 th April)) http://www.xunta.es/Doc/Dog2005.nsf/Fic haContenido/D206?OpenDocument Decreto 15/2011, del 28 de enerode la Ley de Pesca de Galicia http://www.xunta.es/Doc/Dog2011.nsf/Fic (Decree 15/2011 of 28 th January the Fisheries Law of Galicia) haContenido/65FE?OpenDocument Decreto 419/1993, de 17 de diciembre , modificado por el Decreto http://www.xunta.es/Doc/Dog2006.nsf/Fic 101/2006, de 8 de junio (Decree 419/1993 (17 December) , as haContenido/13F3A?OpenDocumen amended by Decree 101/2006 of 8 th June ) UE 853/2004, del 29 de abril (EU 853/2004 of 29 th April) http://eur- lex.europa.eu/LexUriServ/LexUriServ.do?ur i=CONSLEG:2004R0853:20070101:ES:PDF

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APPENDICES

Appendix 1 Scoring and Rationales

Appendix 1.1. Performance Indicator Scores and Rationale Evaluation Table PI 1.1.1 The stock is at a level which maintains high productivity and has a low probability PI 1.1.1 of recruitment overfishing SG Issue Met? Justi fication/Rationale (Y/N) 60 a NA It is likely that the stock is above the point where recruitment would be impaired.

80 a NA It is highly likely that the stock is above the point where recruitment would be impaired.

b NA The stock is at or fluctuating around its target reference point.

100 a NA There is a high degree of certainty that the stock is above the point where recruitment would be impaired. This PI was scored using the Risk-Based Framework (RBF). A SICA workshop was held in Bueu on the 19 th June 2012. See Appendix 1.2 Risk Based Framework (RBF) Outputs. The SICA and PSA were carried out See Appendix 1.2.1 and 1.2.2. for the results b NA There is a high degree of certainty that the stock has been fluctuating around its target reference point, or has been above its target reference point, over recent years .

References

Stock Status relative to Reference Points

OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 1.1.2

PI 1.1.2 Limit and target reference points are appropriate for the stock

Met? SG Issue Justification/Rationale (Y/N) 60 a NA Generic limit and target reference points are based on justifiable and reasonable practice appropriate for the species category. See 80a)

80 a NA Reference points are appropriate for the stock and can be estimated. According to the MSC Certification Requirements , when PI 1.1.1 is scored using the RBF, this PI is given a default score of 80. b NA The limit reference point is set above the level at which there is an appreciable risk of impairing reproductive capacity. As above c NA The target reference point is such that the stock is maintained at a level

consistent with B MSY or a measure or surrogate with similar intent or outcome. As above

d NA Key low trophic level species, the target reference point takes into account the ecological role of the stock. As above

100 b NA The limit reference point is set above the level at which there is an appreciable risk of impairing reproductive capacity following consideration of precautionary issues .

c NA The target reference point is such that the stock is maintained at a level

consistent with B MSY or a measure or surrogate with similar intent or outcome, or a higher level , and takes into account relevant precautionary issues such as the ecological role of the stock with a high degree of certainty.

References

OVERALL PERFORMANCE INDICATOR SCORE: 80

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 1.1.3

PI 1.1.3 Where the stock is depleted, there is evidence of stock rebuilding

Met? SG Issue Justification/Rationale (Y/N) 60 a NA Where stocks are depleted rebuilding strategies which have a reasonable expectation of success are in place. According to the MSC Certification Requirements guidance, PI 1.1.3 shall only be scored when the Principle 1, Stock Status PI 1.1.1 indicates that a stock is depleted, that is “is consistently below the target reference point, and which may be approaching the point at which recruitment is impaired”, which is not the case of the razor clam. Moreover as RBF was used for PI 1.1.1. this PI is not scored. b NA A rebuilding timeframe is specified for the depleted stock that is the shorter of 30 years or 3 times its generation time. For cases where 3 generations is less than 5 years, the rebuilding timeframe is up to 5 years.

c NA Monitoring is in place to determine whether they are effective in rebuilding the stock within a specified timeframe.

80 a NA Where s tocks are depleted rebuilding strategies are in place.

b NA A rebuilding timeframe is specified for the depleted stock that is the shorter of 20 years or 2 times its generation time . For cases where 2 generations is less than 5 years, the rebuilding timeframe is up to 5 years.

c NA 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 a NA Where stocks are depleted, strategies are demonstrated to be rebuilding stocks continuously and there is strong evidence that rebuilding will be complete within the specified timeframe .

b NA The shortest practicable rebuilding timeframe is speci fied which does not exceed one generation time for the depleted stock.

References MSC CR and Guidance

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PI 1.1.3 Where the stock is depleted, there is evidence of stock rebuilding

Met? SG Issue Justification/Rationale (Y/N)

OVERALL PERFORMANCE INDICATOR SCORE: NA

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 1.2.1

PI 1.2.1 There is a robust and precautionary harvest strategy in place

Met? SG Issue Justification/Rationale (Y/N) 60 a Y The harvest strategy is expected to achieve stock management objectives reflected in the target and limit reference points. See 80 a) b Y The harvest strategy is lik ely to work based on prior experience or plausible argument. See 80 b) c Y Monitoring is in place that is expected to determine whether the harvest strategy is working. See 80 b) 80 a Y The harvest strategy is responsive to the state of the stoc k and the elements of the harvest strategy work together towards achieving management objectives reflected in the target and limit reference points. There is a well -developed strategy that is reviewed on an annual basis in order to produce the Management Plan (Garazo, 2005; Miñambres, 2006, 2007; Macho, 2008; Ferreiro, 2009, 2010, 2011; Pastoriza, 2012) for the razor clam fishery in Ria de Pontevedra and for all 7 “Confradías” of the Unit of Certification which is validated by the fishing administration of Galicia. The strategy is based on fishery-dependent data, namely on fishing

effort and catches (CPUE) and structure of the catches. Since B MSY and F MSY cannot be used as reference points in most bivalve species, such as the case of sword razor clams, it is fundamental to decide which proxy, and respective limits should be used to evaluate the stock status in the razor clam fishery. However, taking into consideration the life cycle and population dynamics of the target species and the historical data on landings it is reasonable to assume that the harvest strategy is achieving the objective of maintaining the stock at a point that does not hamper the maintenance of the population at sustainable levels. The main components of the harvesting strategy are: i) limited access rights, given through fishing licenses; ii) minimum landing sizes; iii) daily quota per diver; iv) total number of fishing days per month; v) limited fishing hours per day; vi) closed season; and vi) rotational harvesting areas. b Y The harvest strategy may not have been fully tested but monitoring is in place and evidence exists that it is achieving its objectives. There is a monitoring program in place that aims to collect daily information on CPUE and the structure of the landings. The harvest strategy has been shown to result in maintenance of the sword razor clam population at healthy levels.

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PI 1.2.1 There is a robust and precautionary harvest strategy in place

Met? SG Issue Justification/Rationale (Y/N) 100 a N The harvest strategy is responsive to the state of the stock and is designed to achieve stock management objectives reflected in the target and limit reference points. Since there are currently no target levels for the sword razor clam stock, it was decided to adopt the precautionary principle and therefore this PI issue was not met. b N The performance of the harvest strategy has been fully evaluated and evidence exists to show that it is achieving its objectives including being clearly able to maintain stocks at target levels. As above

d Y The harvest strategy is periodically reviewed and improved as necessary. The harvesting strategy is periodically reviewed and is improved as necessary. As was mentioned previously, there is a monitoring program in place that aims to collect daily information on CPUE and the structure of the landings which annual trends to be followed and daily quotas and the fishing effort to be changed, if necessary. It is important to underline that in recent years, efforts have been made in order to improve data collection on the razor clam fishery, namely regarding the determination of the fishing effort. Therefore, CPUE, instead of being determined for fishing days, is determined based on diving time. Garazo, 2005; Miñambres, 2006, 2007; Macho, 2008; Ferreiro, 2009, 2010, References 2011; Pastoriza, 2012

OVERALL PERFORMANCE INDICATOR SCORE: 90

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 1.2.2

PI 1.2.2 There are well defined and effective harvest control rules in place

Met? SG Issue Justification/Rationale (Y/N) 60 a Y Generally understood harvest rules are in place that are c onsistent with the harvest strategy and which act to reduce the exploitation rate as limit reference points are approached. See 80 a) c Y There is some evidence that tools used to implement harvest control rules are appropriate and effective in controlling exploitation. See 80 c) 80 a Y Well defined harvest control rules are in place that are consistent with the harvest strategy and ensure that the exploitation rate is reduced as limit reference points are approached. According to Rice & Conn olly (2007), harvest control rules (HCR) are defined as being the adjustment of a management measure based on the evaluation of an indicator against an established reference point. As noted previously, there is a need to establish which proxy should be used in the sword razor clam fishery in order to evaluate the status of the stock. Nevertheless, the team considered the harvest control rules to be well defined and consistent with the harvest strategy. b Y The selection of the harvest control rules takes into account the main uncertainties. The exploitation strategy adopted each year ( Garazo, 2005; Miñambres, 2006, 2007; Macho, 2008; Ferreiro, 2009, 2010, 2011; Pastoriza, 2012) can be changed as necessary by reducing the fishing effort both in terms of fishing days per month and area, and number of divers as well as by adjusting daily quotas. Furthermore, fishing can be stopped or controlled when prices decrease below a level that is considered unprofitable. c Y Available evidence indicates that the tools in use are appropriate and effective in achieving the exploitation levels required under the harvest control rules. Both length frequency structure of the catches and CPUE have remained relatively stable in recent years, indicating that the system implemented is appropriate and effective. 100 a N Well defined harvest control rules are in place that are consistent with the harvest strategy and ensure that the exploitation rate is reduced as limit reference points are approached. Since there are currently no target levels for the sword razor clam stock, it was decided to adopt the precautionary principle and therefore this PI issue is not met.

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PI 1.2.2 There are well defined and effective harvest control rules in place

Met? SG Issue Justification/Rationale (Y/N) b N The design of the harvest control rules takes into account a wide range of uncertainties. The team believes that harvest control rules does not take into account a wide range of uncertainties, namely the effects of environmental changes on the sword razor clam stock. c N Evidence clearly shows that the tools in use are effective in achieving t he exploitation levels required under the harvest control rules. Since there are currently no target levels for the sword razor clam stock, it was decided to adopt the precautionary principle and therefore this PI issue is not met. Garazo, 2005; Miñambres, 2006, 2007; Rice & Connolly, 2007; Macho, References 2008; Ferreiro, 2009, 2010, 2011; Pastoriza, 2012

OVERALL PERFORMANCE INDICATOR SCORE: 80

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 1.2.3

PI 1.2.3 Relevant information is collected to support the harvest strategy

Met? SG Issue Justification/Rationale (Y/N) 60 a Y Some relevant information related to stock structure, stock productivity and fleet composition is available to support the harvest strategy.

See 80 a)

b Y Stock abundance and fishery removals are monitored and at least one indicator is available and monitored with sufficient frequency to support the harvest control rule. See 80 b) 80 a Y Sufficient relevant information related to stock structure, stock productivity, fleet composition and other data is available to support the harvest strategy. The sustainable exploitation of fishing resources implies the implementation of harvesting strategies that must be supported by both technical and scientific information. In the case of the sword razor clam there is various information regarding the biology of the species that enabled the introduction of certain technical measures to manage the fishery, such as MLS and seasonal closures. Various fishery data (CPUE and size structure of the catches) is collected on a daily basis which allows to indirectly follow the evolution of the stock. This information can be summarised and is essential for the management of the fishery. All divers operating on the fishery are licensed within the fishery management system. No other divers can enter the fishery. The ecology of the species is known and the environmental conditions of Ria Pontevedra are well understood (see indicator 2.5.3). b Y Stock abundance and fishery removals ar e regularly monitored at a level of accuracy and coverage consistent with the harvest control rule , and one or more indicators are available and monitored with sufficient frequency to support the harvest control rule. Fishery removals are regularly mon itored at a level of accuracy and coverage consistent with the harvest control rule. Indeed, all fishery removals are controlled in situ on a daily basis. Data includes fishing date, amount of razor clams caught per diver (in weight), fishing effort per diver (diving time) and fishing area. On the landing site, information on the size structure of the catch is collected. These size checks at fish market are performed around 3 times per month. Usually, one a few days after opening up a new area, another in the middle of the month and another towards the end of it to compare change in average size. Some independent fishery data on the abundance, distribution and population structure is also available. Nevertheless, this data is not collected on a regular basis which is justified, on the one hand, by difficulties in sampling Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 54 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

PI 1.2.3 Relevant information is collected to support the harvest strategy

Met? SG Issue Justification/Rationale (Y/N) razor clams due to their ecology and burrowing behaviour and, on the other hand, because of the dynamics of the species. These difficulties can be surpassed, since in the present fishery, trends on abundance can be indirectly assessed through catch-per-unit effort. Indeed, CPUE is appropriate to evaluate changes in catch because it can be used as an indicator of relative stock abundance. c Y There is good information on all other fishery re movals from the stock. All divers operating in the fishery are licensed within the fishery management system. No other fisheries target sword razor clams in Ria de Pontevedra. Some fisheries such as dredge fishery for clams may damage sword razor clams, but this is considered insignificant due to the low number of sword razor clams in the catch and the fact that this fishery only overlaps with the razor clam fishery near the lower depth limit of the species. Recreational fishing for personal use may sporadically take place but the stakeholders considered it negligible. It is believed that monitoring and enforcement operations relevant to IUU fishing are adequate to provide good information on the extent of this. Moreover, illegal fishery is not relevant considering the low number of sanctions applied in recent years. 100 a N 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 related to the current harvest strategy, is available. The team considered that a “comprehensive range” of information would imply better information, than is currently available, on the stock and environment. b N 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 inherent uncertainties in the information [data] and the robustness of assessment and management to this uncertainty. Although CPUE is determined on a daily basis and structure of the catches are performed around 3 times per month (see 80b), the team believes that there is not a good understanding of uncertainties inherent in the information. Darriba, 2001; Darriba et al. , 2004, 2005; Fernández, 2005, 2006; Rivero, References 2007; da Costa et al ., 2008; Velasco, 2008, 2009, 2010; Fismare, 2010a, b; Hernández-Otero et al ., s.d., 2010, 2011; Pastoriza, 2011.

OVERALL PERFORMANCE INDICATOR SCORE: 80

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 1.2.4

PI 1.2.4 There is an adequate assessment of the stock status

Met? SG Issue Justification/Rationale (Y/N) 60 b NA The assessment estimates stock status relative to reference points .

c NA The assessment identifies major sources of uncertainty.

80 a NA The assessment is appropriate for the stock and for the harvest control rule. When PI 1.1.1 is scored using the RBF, this PI is given a default score of 80. c NA The assessment takes uncertainty into account. As above e NA The assessment of stock status is subject to peer review. As above 100 a NA The assessment is appropriate for the stock and for the harvest control rule and takes into account the major features relevant to the biology of the species and the nature of the fishery.

c NA The assessment takes into account uncertainty and evaluates stock status relative to reference points in a probabilistic way.

d NA The assessment has been teste d and shown to be robust. Alternative hypotheses and assessment approaches have been rigorously explored.

e NA The assessment has been internally and externally peer reviewed.

References

OVERALL PERFORMANCE INDICATOR SCORE: 80

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.1.1 The fishery does not pose a risk of serious or irreversible harm to the retained PI 2.1.1 species and does not hinder recovery of depleted retained species Met? SG Issue Justification/Rationale (Y/N) 60 a Y Main retained species are likely to be within biologically based limits (if not, go to scoring issue d below). See 100 b)

c Y If main retained species are outside the limits there are measures in place that are expected to ensure that the fishery does not hinder recovery and rebuilding of the depleted species. See 100 b)

d Y If the status is poorly known there are measures or practices in place that are expected to result in the fishery not causing the retained species to be outside biologically based limits or hindering recovery. See 100 b)

80 a Y Main retained species are highly likely to be within biologically based limits (if not, go to scoring issue c below). See 100 b) c Y If main retained species are outside the limits ther e is a partial strategy of demonstrably effective management measures in place such that the fishery does not hinder recovery and rebuilding. See 100 b) 100 a Y There is a high degree of certainty that retained species are within biologically based limits and fluctuating around their target reference points. See 100 b) b Y Target reference points are defined and retained species. According to the MSC certification requirements , retained species are those that are caught alongside the target species and which are retained and sold, or have a market value. This is a very selective fishery where no fishing gear is used. Indeed divers pick razor clams with their hands and therefore only the target species is caught. Generally, there are no retained species, main or otherwise, in this fishery.

References Gaspar et al. , 2011; Guerra & Sánchez, 2011

OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.1.2 There is a strategy in place for ma naging retained species that is designed to ensure PI 2.1.2 the fishery does not pose a risk of serious or irreversible harm to retained species Met? SG Issue Justification/Rationale (Y/N) 60 a Y There are measures in place, if necessary, that are expected to mai ntain the main retained 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. See 100 d) b Y The measures are considered likely to work, based on plau sible argument (e.g., general experience, theory or comparison with similar fisheries/species). See 100 d) 80 a Y There is a partial strategy in place, if necessary , that is expected to maintain the main retained 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. See 100 d) b Y There is some objective basis for confidence that the partial strategy will work, based on some information directly about the fishery and/or species involved. See 100 d) c Y There is some evidence that the partial strategy is being implemented successfully. See 100 d) 100 a Y There is a strategy in place for managing retained species. See 100 d) b Y Testi ng supports high confidence that the strategy will work, based on information directly about the fishery and/or species involved. See 100 d) c Y There is clear evidence that the strategy is being implemented successfully. See 100 d) d Y There i s some evidence that the strategy is achieving its overall objective. As outlined in PI 2.1.1 there are no retained species, main or otherwise, in this fishery and therefore the team agreed that there is no need to implement a management strategy for retained species. References

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There is a strategy in place for ma naging retained species that is designed to ensure PI 2.1.2 the fishery does not pose a risk of serious or irreversible harm to retained species Met? SG Issue Justification/Rationale (Y/N)

OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.1.3 PI 2.1.3 Information on the nature and extent of retained species is adequate to determine the risk posed by the fishery and the effectiveness of the strategy to manage retained species Met? SG Issue Justification/Rationale (Y/N) 60 a Y Qualitative information is available on the amount of main retained species taken by the fishery. See 100 d) b Y Information is adequate to qualitatively assess outcome status with respect to biologically based limits. See 100 d) c Y Information is adequate to support measures to manage main retained species. See 100 d) 80 a Y Qualitative information and some quantitative information is available on the amount of main retained species taken by the fishery. See 100 d) b Y Information is sufficient to estimate outcome status with respect to biologically based limits. See 100 d) c Y Information is adequate to supp ort a partial strategy to manage main retained species. See 100 d) d Y Sufficient data continue s to be collected to detect any increase in risk level (e.g. due to changes in the outcome indicator score or the operation of the fishery or the effectiveness of the strategy) See 100 d)

100 a Y Accurate and verifiable information is available on the catch of all retained species and the consequences for the status of affected populations. See 100 d) b Y Information is sufficient to quantitativel y estimate outcome status with a high degree of certainty. See 100 d) c Y Information is adequate to support a comprehensive strategy to manage retained species, and evaluate, with a high degree of certainty , whether the strategy is achieving its objective. See 100 d)

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PI 2.1.3 Information on the nature and extent of retained species is adequate to determine the risk posed by the fishery and the effectiveness of the strategy to manage retained species Met? SG Issue Justification/Rationale (Y/N) d Y Monitoring of retained species is conducted in sufficient detail to assess on - going mortalities of all retained species. As already mentioned , there are no species retained in this fishery and therefore there is no need to gather any type of information related to this issue. References

OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.2.1 The fishery does not pose a risk of serious or irreversible harm to the bycatch PI 2.2.1 species or species groups and does not hinder recovery of depleted bycatch species or species groups Met? SG Issue Justification/Rationale (Y/N) 60 a Y Main bycatch species are likely to be within biologically based limits (if not, go to scoring issue b below). See 100 a) b Y If main bycatch species are outside biologically based limits there are mitigation measures in place that are expected to ensure that the fishery does not hinder recovery and rebuilding. See 100 a)

c Y If the stat us is poorly known there are measures or practices in place that are expected to result in the fishery not causing the bycatch species to be outside biologically based limits or hindering recovery. See 100 a)

80 a Y Main bycatch species are highly lik ely to be within biologically based limits (if not, go to scoring issue b below). See 100 a) b Y If main bycatch species are outside biologically based limits there is a partial strategy of demonstrably effective mitigation measures in place such that the fishery does not hinder recovery and rebuilding. See 100 a)

100 a Y There is a high degree of certainty that bycatch species are within biologically based limits. According to the MSC certification requirements , bycatch species are those species that are caught alongside the target species that are not retained and that are discarded as well as those that die because of unobserved fishing mortality. As outlined before, this is an extremely selective fishery that only collects the target species. Although, occasionally undersized razor clams can be harvested and discarded, fishing razor clams does not appear to have negative consequences for the target species, as individual ones are taken by hand and no physical damage is caused to the animals (Constantino et al. , 2009). Moreover, since undersized individuals are discarded immediately and in situ they can re-burrow almost immediately and therefore no mortality by predation is expected. Thus, overall there are no bycatch species, main or otherwise, in this fishery. References Constantino et al. , 2009; Gaspar et al. , 2011; Guerra & Sánchez, 2011.

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The fishery does not pose a risk of serious or irreversible harm to the bycatch PI 2.2.1 species or species groups and does not hinder recovery of depleted bycatch species or species groups Met? SG Issue Justification/Rationale (Y/N)

OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.2.2 There is a strategy in place for m anaging bycatch that is designed to ensure the PI 2.2.2 fishery does not pose a risk of serious or irreversible harm to bycatch populations Met? SG Issue Justification/Rationale (Y/N) 60 a Y There are measures in place, if necessary, which are expected to maintai n main bycatch species at levels which are highly likely to be within biologically based limits or to ensure that the fishery does not hinder their recovery. See 100 d)

b Y The measures are considered likely to work, based on plausible argument (e.g. general experience, theory or comparison with similar fisheries/species). See 100 d)

80 a Y There is a partial strategy in place, if necessary, for managing bycatch species at levels which are highly likely to be within biologically based limits or to ensure that the fishery does not hinder their recovery. See 100 d)

b Y There is some objective basis for confidence that the partial strategy will work, based on some information directly about the fishery and/or the species involved. See 100 d ) c Y There is some evidence that the partial strategy is being implemented successfully. See 100 d) 100 a Y There is a strategy in place for managing and minimising bycatch. See 100 d) b Y Testing supports high confidence that the strategy wi ll work, based on information directly about the fishery and/or species involved. See 100 d) c Y There is clear evidence that the strategy is being implemented successfully. See 100 d) d Y There is some evidence that the strategy is achieving i ts objective. As outlined in PI 2.2.1, there are no bycatch species in this fishery and therefore the team agreed that there is no need to implement a management strategy for bycatch. References

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There is a strategy in place for m anaging bycatch that is designed to ensure the PI 2.2.2 fishery does not pose a risk of serious or irreversible harm to bycatch populations Met? SG Issue Justification/Rationale (Y/N)

OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.2.3 Information on the nature and the amount of bycatch is adequate to determine the PI 2.2.3 risk posed by the fishery and the effectiveness of the strategy to manage bycatch Met? SG Issue Justification/Rationale (Y/N) 60 a Y Qualitative information is available on the main bycatch species affected by the fishery. See 100 d) b Y Information is adequate to broadly understand outcome status with respect to biologically based limits See 100 d) c Y Information is adequate to support measures to manage bycatch. See 100 d) 80 a Y Qualitative information and some quantitative information is available on the amount of main bycatch species affected by the fishery. See 100 d) b Y Information is sufficient to estimate outcome status with respect to biologically based limits. See 100 d) c Y Information is adequate to support a partial strategy to manage main bycatch species. See 100 d) d Y Sufficient data continue to be collected to de tect 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 effectively of the strategy). See 100 d)

100 a Y Accurate and verifiable information is available on the amo unt of all bycatch and the consequences for the status of affected populations. See 100 d) b Y Information is sufficient to quantitatively estimate outcome status with respect to biologically based limits with a high degree of certainty . See 100 d) c Y Information is adequate to support a comprehensive strategy to manage bycatch, and evaluate , with a high degree of certainty , whether a strategy is achieving its objective . See 100 d) d Y Monitoring of bycatch data is conducted in sufficient detail to assess on - going mortalities of all bycatch species.

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Information on the nature and the amount of bycatch is adequate to determine the PI 2.2.3 risk posed by the fishery and the effectiveness of the strategy to manage bycatch Met? SG Issue Justification/Rationale (Y/N) As already mentioned the available information clearly shows that there are no discarded species in this fishery and therefore there is no need to gather any type of information related to this issue. References

OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.3.1 The fishery meets national and international requirements for the protection of ETP species PI 2.3.1 The fishery does not pose a risk of serious or irreversible harm to ETP species and does not hinder recovery of ETP species Met? SG Issue Justification/Rationale (Y/N) 60 a Y Known effects of the fishery are likely to be within limits of national and international requirements for protection of ETP species. See 100 a)

b Y Known direct effects are unlikely to create unacceptable impact on ETP species. See 100 b) 80 a Y The effects of the fishery are known and are highly likely to be within limits of national and international requirements for protection of ETP species. See 100 a) b Y Direct effects are highly unlikely to create unacceptable impact on ETP species. See 100 b) c Y Indirect effects have been considered and are thought to be unlikely to create unacceptable impacts. See 100 c) 100 a Y There is a high degree of certainty that the effects of the fishery are within limits of national and international requirements for the protection of ETP species. The team did not find any report on the oc currence of ETP species in Ria Pontevedra. Moreover, the stakeholders that were consulted referred to the fact that they were not aware of the occurrence of ETP species in Ria Pontevedra, at least ETP of interest in relation to the sword razor clam fishery. Nevertheless, assuming that ETP species occurs in Ria Pontevedra, given that the method used to collect target species is extremely selective, and there is no bycatch or retained species, there is likely to be little adverse interaction between the fishery and ETP species, or threatened ecological communities. b Y There is a high degree of confidence that there are no significant detrimental direct effects of the fishery on ETP species. Potential direct sources of risk to ETP species are limited to: i) divers may disturb ETP species inhabiting areas where razor clams are collected; and ii) interaction between ETP and fishing vessels during transit between port and fishing grounds or during harvesting operations. However, no ETP

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species were identifie d as occupying the same fishing grounds as razor clams. Although some ETP species (marine mammals and marine reptiles) may travel through areas used by sword razor clam vessels (near Ons island) it is believed that there would be a low risk of injury or disturbance to these species. Indeed, up to now no interaction between ETP and razor clams vessels has been reported. Therefore, no detrimental direct effects on ETP species are expected. c Y There is a high degree of confidence that there are no signific ant detrimental indirect effects of the fishery on ETP species. If ETP species occurs in Ria de Pontevedra, the potential indirect effects would be the removal of sword razor clams as a food source for ETP species and habitat disturbance. Notwithstanding this, the team believes that the current management regime of sword razor clams stocks seems to ensure the maintenance of the razor clam populations at a sustainable level and the method of harvesting causes little physical damage or disturbance to the biophysical environment (Jenkins, 2004; Gaspar et al. , 2011). Therefore no detrimental indirect effects on ETP species are expected. http://www.faunagallega.es.tl/#; http://www.medioruralemar.xunta.es/; References Jenkins, 2004; Gaspar et al ., 2011

OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.3.2 The fishery has in place precautionary management strategies designed to: • Meet national and international requirements; PI 2.3.2 • Ensure the fishery does not pose a risk of serious harm to ETP species; • Ensure the fishery does not hinder recovery of ETP species; and • Minimise mortality of ETP species. Met? SG Issue Justification/Rationale (Y/N) 60 a Y There are measures in place that minimise mortality, an d are expected to be highly likely to achieve national and international requirements for the protection of ETP species. See 100 a) b Y The measures are considered likely to work, based on plausible argument (e.g., general experience, theory or comparison with similar fisheries/species). See 100 b) 80 a Y There is a strategy in place for managing the fishery’s impact on ETP species, including measures to minimise mortality, that is designed to be highly likely to achieve national and international requirements for the protection of ETP species. See 100 a)

b Y There is an objective basis for confidence that the strategy will work, based on information directly about the fishery and/or the species involved. See 100 b) c Y There is eviden ce that the strategy is being implemented successfully. See 100 c) 100 a Y There is a comprehensive strategy in place for managing the fishery’s impact on ETP species, including measures to minimise mortality that is designed to achieve above national and international requirements for the protection of ETP species. The impact of the sword razor clam fishery on ETP species is considered negligible and therefore there is no specific management strategy in place for the protection and conservation of ETP species. Nevertheless, Law 42/2007 of the 13 th December, on Natural Heritage and Biodiversity, establishes the duty of the government to classify those species of wildlife whose conservation requires specific protection measures. In this way, a Governmental Conservation Program was put in place for ETP species, the purpose of which is the recovery and sustained long-term survival of these species. In the framework of this program some Conservation and Recovery Plans are being designed for ETP species. The plans designed so far can be

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The fishery has in place precautionary management strategies designed to: • Meet national and international requirements; PI 2.3.2 • Ensure the fishery does not pose a risk of serious harm to ETP species; • Ensure the fishery does not hinder recovery of ETP species; and • Minimise mortality of ETP species. Met? SG Issue Justification/Rationale (Y/N) consulted on the website of the Xunta de Galicia (http://www.medioruralemar.xunta.es/). b Y The strategy is mainly based on information directly about the fishery and/or species involved, and a quantitative analysis supports high confidence that the strategy will work. The team believes that for the sword razor clam fishery there is no need to implement a specific management strategy for the protection of ETP species since no detrimental indirect or direct effects on these species are expected. c Y There is clear evidence that the strategy is being implemented successfully. No detrimental direct effects on ETP species related to this fishery is expected considering all the aspects inherent to the fishery itself such as, harvesting technique, target species distribution, management plan, etc. Moreover, within Ria Pontevedra, ETP species that rely on sword razor clams for food were never reported in the razor clam fishing grounds. Nevertheless, if in the near ETP species that feed primarily on sword razor clams occur Ria Pontevedra, the potential indirect effects would be the removal of the sword razor clams as food sources. Thus, the team agreed that the only strategy needed to be implemented is related to the target species. Trends on both CPUE and size structure of the landings clearly evidence that the management strategy is being implemented successfully. d Y There is evidence that the strategy is achieving its objective. As mentioned in SG100 c, there is n o need to design a specific strategy for ETP species. The only strategy needed to be implemented is related to the target species. The analysis of CPUE and size structure allows to follow trends on the status of the stock and to adjust daily quotas per fishermen whenever necessary. Over recent years both CPUE and mean landing size has remained relatively stable indicating that the sword razor clam populations are healthy. References OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.3.3 Relevant information is collected to support the management of fishery impacts on ETP species including: PI 2.3.3 • Information for the development of the management strategy; • Information to assess the effectiveness of the management strategy; and • Information to determine the outcome status of ETP species. Met? SG Issue Justification/Rationale (Y/N) 60 a Y Information is sufficient to qualitatively estimate the fishery related mortality of ETP species. See 80 a) b Y Information is adequate to broadly understand the impact of the fishery on ETP species. See 80 b) c Y Information is adequate to support measures to manage the impact on ETP species. See 80 c) 80 a Y Sufficient data is available to allow fishery related mortality and the impact of fishing to be quantitatively estimated for ETP species. Harvesting in the fishery involves hand collection limiting the potential for impacts on any ETP species. No interaction with ETP species has been reported or is considered likely within the fishery, and therefore no formal assessment has been conducted. The only potential impacts are associated with small vessel operations, such as boats striking ETP species or damage to the seafloor due to anchoring. b Y In formation is sufficient to determine whether the fishery may be a threat to protection and recovery of the ETP species. ETP for Galicia are identified and management plans are in place to promote the recovery and conservation of ETP species. Of the species classified as ETP for Galicia, none of them seems to be affected by the sword razor clam fishery and therefore there is no need to implement a specific monitoring program for this fishery. c Y Information is sufficient to measure trends and support a full strategy to manage impact on ETP species. The team believes that for the sword razor clam fishery there is no need to implement a specific management strategy for the protection of ETP species since no detrimental indirect or direct effects on these species are expected. 100 a N Information is sufficient to quantitatively estimate outcome status of ETP species with a high degree of certainty. As outlined above, although no ETP species in relation to the sword razor clam fishery were identified for Ria de Pontevedra, the team, through the Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 72 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

Relevant information is collected to support the management of fishery impacts on ETP species including: PI 2.3.3 • Information for the development of the management strategy; • Information to assess the effectiveness of the management strategy; and • Information to determine the outcome status of ETP species. Met? SG Issue Justification/Rationale (Y/N) adopti on of the precautionary principle , considers that the criteria for SG80 are met but not the criteria for SG100 due to the uncertainty related to the scarcity of information on ETP for Ria de Pontevedra. However SG100 criteria may be met at some point in the future if better information becomes available. b N Accurate and verifiable information is available on the magnitude of all impacts, mortalities and injuries and the consequences for the status of ETP species. As above

c N Information is adequate to support a comprehensive strategy to manage impact, minimise mortality and injury of ETP species, and evaluate, with a high degree of certainty , whether a strategy is achieving its objectives. As above

References

OVERALL PERFORMANCE INDICATOR SCORE: 80

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.4.1 The fishery does not cause serious or irreversible harm to habitat structure, PI 2.4.1 considered on a regional or bioregional basis and function Met? SG Issue (Y/P/ Justification/Rationale N) 60 a Y The fishery is unlikely to reduce habitat structure and function to a point where there would be serious or irreversible harm. See 100 a ) 80 a Y The fishery is highly unlikely to reduce habitat structure and function to a point where there would be serious or irreversible harm. See 100 a ) 100 a Y There is evidence that the fishery is highly unlikely to reduce habitat structure and function to a point where there would be serious or irreversible harm. Studies o n the impact of fishing in soft sediments (see reviews done by Sebe & Guerra, 1997; Jennings & Kaiser, 1998; Kaiser et al. , 2001; and Gaspar et al. , 2011) clearly indicate that the fishery would not reduce habitat structure and function to a point where there would be serious or irreversible harm. Indeed, diving for razor clams is highly selective with minimal physical disturbance of the habitat and associated fauna is not affected. Moreover, the fishery does not cover the entire habitat since, although the species occur up to 16m in depth, divers harvest razor clams down to 12m in depth and therefore only a part of the habitat is disturbed. The risks to protected areas and habitat caused by the movement of boats is also considered negligible due to the low number of vessels involved in the fishery and the lack of contact between vessels and seabed. Sebe & Guerra, 1997, Jennings & Kaiser, 1998, Kaiser et al. , 2001 and References Gaspar et al., 2011.

OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.4.2 There is a strategy in place that is designed to ensure the fishery does not pose a PI 2.4.2 risk of serious or irreversible harm to habitat types Met? SG Issue Justification/Rationale (Y/N) 60 a Y There are measures in place, if necessary, that are expected to achieve the Habitat Outcome 80 level of performance. See 100 a) b Y The measures are considered likely to work, based on plausible argument (e.g. general experience, theory or comparison with similar fisheries/habitats). See 100 b) 80 a Y There is a partial strategy in place, if necessary, that is expected to achieve the Habitat Outcome 80 level of performance or above. See 100 a) b Y There is s ome objective basis for confidence that the partial strategy will work, based on information directly about the fishery and/or habitats involved. See 100 b) c Y There is some evidence that the partial strategy is being implemented successfully. See 100 c) 100 a Y There is a strategy in place for managing the impact of the fishery on habitat types. Considering the nature and exten t of the fishery and the fact that hand - picking has no impact on the habitat (Gaspar et al. , 2011) the team agreed that a strategy would not be deemed necessary for this fishery. Notwithstanding, the management strategy implemented in the sword razor clam fishery, although aimed at promoting the sustainable exploitation of the resource, also provides direct protection of the habitat. Indeed, management measures include controlled access, daily quotas, number of fishing days per month, rotational areas, and a closed season. The sword razor clam fishery may also occur in certain zones of the Ons island which is a National Park. In this area, there is a high degree of scrutiny in terms of razor clam fishery to ensure that the conservation objectives of the area are not compromised. b Y Testing supports high confidence that the strategy will work, based on information directly about the fishery and/or habitats involved. The harvesting method and management measures in place, together with the type of habitat and local hydrodynamics, ensure that no long-term effects of sword razor clams harvesting on habitat structure and function

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There is a strategy in place that is designed to ensure the fishery does not pose a PI 2.4.2 risk of serious or irreversible harm to habitat types Met? SG Issue Justification/Rationale (Y/N) occurs. c Y There is clear evidence that that strategy is being implemented successfully. The regulations set out in the management plan are effectively enforced. d Y There is some evidence that the strategy is achieving its objective. Daily fishery -dependent data is collected directly from the fishing ground and the landing point ensuring that the management strategy is being accomplished by divers. Analysis of data shows that the strategy is achieving its objectives. References Gas par et al. , 2011

OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.4.3 Information is adequate to determine the risk posed to habitat types by the fishery PI 2.4.3 and the effectiveness of the strategy to manage impacts on habitat types Met? SG Issue Justification/Rationale (Y/N) 60 a Y There is basic understanding of the types and distribution of main habitats in the area of the fishery. See 100 a) b Y Information is adequate to broadly understa nd the nature of the main impact of gear used in the main habitats, including spatial overlap of habitat with fishing gear. See 100 b) 80 a Y The nature, distribution and vulnerability of all main habitat types in the fishery are known at a level of detail relevant to the scale and intensity of the fishery. Sword razor clams fishing grounds are mapped and characterized ( Fismare, 2010a, b) at a level of detail relevant to the scale and intensity of the fishery. b Y Sufficient data is available to allow the nature of the impact of the fishery on habitat types to be identified and there is reliable information on the spatial extent of interaction, and the timing and location of the use of fishing gear. See 100 b) c Y Sufficient data continue s 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). Spatial and temporal footprint of the sword razor clam fishery is well monitored and recorded on fine spatial and temporal scales. 100 a N The distribution of habitat types is known over their range, with particular attention to the occurrence of vulnerable habitat types. Comprehensive habitat maps for Ria de Pontevedra are not currently available. Thus, further fine scale information is required on the habitats that exist within the unit of certification. Concerning vulnerable habitats, the reviewers only found documentation on the distribution of maërl beds (Peña & Bárbara, 2007). b Y The physical impact of the gear on the habitat types ha s been fully quantified. The spatial extent of the fishery is limited by the extent of the habitat and within the fishable area and only part of the area is potentially disturbed due to diving limitations (divers collect sword razor clams up to 12m depth). Management measures in place together with effective fishing control, promote the protection of the habitat. Local hydrodynamics and Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 77 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

the habitats affected by the razor clam fi shery are well described and quantified (Castaño et al ., 2010; Fismare 2010b; Gonzalez et al ., 2010) which enables the potential impact of fishing to be understood. Physical effects of hand harvesting on the habitat have been studied and quantified by several authors (Sebe & Guerra, 1997; Jennings & Kaiser, 1998; Kaiser et al ., 2001; Gaspar et al ., 2011). c N Changes in habitat distributions over time are measured. Although there are some research projects currently being conducted to map vulnerable habitats, there is no evidence that changes in habitat distributions over time will be measured periodically. Castaño et al ., 2010; Fismare 2010a, b; Gonzalez et al ., 2010, Peña & References Bárbara, 2007; Sebe & Guerra, 1997; Jennings & Kaiser, 1998; Kaiser et al ., 2001; Gaspar et al ., 2011

OVERALL PERFORMANCE INDICATOR SCORE: 85

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.5.1 The fishery does not cause serious or irreversible harm to the key elements of PI 2.5.1 ecosystem structure and function Met? SG Issue (Y/P/ Justification/Rationale N) 60 a Y The fishery is unlikely to disrupt the key elements underlying ecosystem structure or function to a point where there would be serious or irreversible harm. See 100 a) 80 a Y The fisher y is highly unlikely to disrupt the key elements underlying ecosystem structure or function to a point where there would be serious or irreversible harm. See 100 a ) 100 a Y There is evidence that the fishery is highly unlikely to disrupt the key elements underlying ecosystem structure or function to a point where there would be a serious or irreversible harm. There is little damage to the physical environment and there are no bycatch or retained species. Regarding ETP species and as previously mentioned, hand-harvesting for sword razor clams does not have any impact on them. Travel to, from and within fishing grounds would also not pose a risk to ETP species. The removal of the target species may potentially have an impact on the trophic web of Ria Pontevedra, but changes would only occur in the event of overexploitation of sword razor clams populations which is not the case. The team believes that the management measures in place, the information that has been collected and the fishing strategy adopted by divers are sufficient to detect, in a timely manner, a significant decrease in the abundance of razor clams and to avoid the overexploitation of this resource by implementing new management measures. By way of conclusion, the team agreed that there is sufficient information to ensure that there is little risk of impact on the ecosystem associated with the fishery and that the potential impact on the ecosystem is only related to the excessive removal of the target species. In this case, there are suitable mitigation measures in place to limit their effect. References Gaspar et al. , 2011

OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.5.2 There are measures in place to ensure the fishery does not pose a risk of serious PI 2.5.2 or irreversible harm to ecosystem structure and function Met? SG Issue Justification/Rationale (Y/N) 60 a Y There are measures in place, if necessary. See 100 a) b Y The measures take into account the potential impa ct of the fishery on key elements of the ecosystem. See 100 b) c Y The measures are considered likely to work, based on plausible argument (e.g., general experience, theory or comparison with similar fisheries/ecosystems). See 100 c)

80 a Y Ther e is a partial strategy in place, if necessary. See 100 a) b Y The partial strategy takes into account available information and is expected to restrain impact of the fishery on the ecosystem so as to achieve the Ecosystem Outcome 80 level of performance. See 100 b)

c Y The partial strategy is considered likely to work, based on plausible argument (e.g., general experience, theory or comparison with similar fisheries/ecosystems). See 100 c)

d Y There is some evidence that the measures comp rising the partial strategy are being implemented successfully. See 100 d) 100 a Y There is a strategy that consists of a plan , in place. The team believed that a specific strategy for the management of ecosystem impacts of this fishery is not really necessary, given that such impacts is considered to be highly unlikely (Gaspar et al ., 2011). b Y The strategy , which consists of a plan , contains measures to address all main impacts of the fishery on the ecosystem, and at least some of these measures are in place. The plan and measures are based on well- understood functional relationships between the fishery and the Components and elements of the ecosystem. This plan provides for the development of a full strategy that restrains impacts on the ecosystem to ensure the fishery does not cause serious or

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There are measures in place to ensure the fishery does not pose a risk of serious PI 2.5.2 or irreversible harm to ecosystem structure and function Met? SG Issue Justification/Rationale (Y/N) irreversible harm.

There is no need to design a specific plan for the management of the ecosystem. As was previously noted, the greatest risk to the ecosystem is the overexploitation of the target species. The management measures in force ensure that the fishery does not pose a risk to ecosystem functioning namely: i) the restriction of sword razor clam harvesting to hand-picking which is a target-specific harvesting method that does not affect the habitat, that has no bycatch or retained species and that has no impact on ETP species; ii) daily quotas per diver are set on a yearly basis to maintain razor clams populations; iii) a closed season; iv) rotational harvesting to distribute the fishing effort throughout the entire fishable area, v) number of fishing days per month. c Y The measures are considered likely to work based on prior experience , plausible argument or information directly from the fishery/ecosystems involved. The impact on the ecosystem is considered negligible as long as the sword razor clam populations are kept at sustainable levels. The analysis of the data obtained directly from the fishery (CPUE and structure of the catch) indicates that the management measures adopted are working. d Y There is evidence that the measures are being implemented successfully . Although this is not per se an “ecosystem management plan” the team agreed in considering the management measures to be a partial strategy, with good evidence that the strategy is being implemented successfully since the tight monitoring and control made by the water bailiff guarantees that the divers accomplish with what is stipulated in the management plan. References Gaspar et al. , 2011

OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 2.5.3

PI 2.5.3 There is adequate knowledge of the impacts of the fishery on the ecosystem

Met? SG Issue Justification/Rationale (Y/N) 60 a Y Information is adequate to identify the key elements of the ecosystem (e.g., trophic structure and function, community composition, productivity pattern and biodiversity). See 80 a) b Y Main impacts of the fishery on these key ecosystem elements can be inferred from existing information, and have not been investigated in detail . See 80 b) a Y Information is adequate to broadly understand the key elements of the ecosystem. 80 There is quite good information on both the abiotic and biotic part of Ria de Pontevedra which is adequate to broadly understand the key elements of the ecosystem. b Y Main impacts of the fishery on these key ecosystem elements can be inferred from existing information and some have been investigated in detail . From the review done by Gaspar et al . ( 2011) on the fishing impacts of razor clam fisheries on the ecosystem it can be inferred that the razor clam fishery in the Ria de Pontevedra has a negligible impact on the ecosystem. This is for sure one of the most environmentally friendly techniques for fishing and the cleanest catching method. c Y The main functions of the Components (i.e., target, Bycatch, Retained and ETP species and Habitats) in the ecosystem are known . See 100 c) d Y Sufficient information is available on the impact of the f ishery on these Components to allow some of the main consequences for the ecosystem to be inferred. This is a very benign fishery with no bycatch, no retained species, no impact on ETP species, causing low disturbance on the habitat. Although no reference points exist for the fishery, both stakeholders and reviewers agree that in Ria de Pontevedra populations of sword razor clams are exploited at sustainable levels and therefore food chains and food webs are not disrupted. By way of conclusion, ecosystem structure and function as well as ecosystem service at the present fishing effort level are not expected to be affected. e Y Sufficient data continue s to be collected to detect any increase in risk level (e.g., due to changes in the outcome indicator scores or the

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PI 2.5.3 There is adequate knowledge of the impacts of the fishery on the ecosystem

Met? SG Issue Justification/Rationale (Y/N) operation of the fishery or the effectiveness of the measures).

As was mentioned in PI 2.5.2, the explicit strategy for the management of the ecosystem impact of this fishery is not really necessary, given that such impact is considered to be highly unlikely. 100 b N Main interactions between the fishery and these ecosystem elements can be inferred from existing information, and have been investigated .

According to CB3.19.1.2 of the MSC certification requirements , the scoring of this issue should be focused on the following issues: “Fisheries should be capable of adapting management to environmental changes as well as managing the effect of the fishery on the ecosystem” and “Monitoring the effects of environmental change on the natural productivity of fisheries should be considered best practice and should include recognition of the increasing importance of climate change”. Thus, although the fishery is unlikely to have any effect on the ecosystem, there is no monitoring of the effects of environmental change on natural production of the fishery. Hence, the team did not consider that the “main interactions between the fishery and these ecosystem components” can be inferred from existing information, particularly in view of the potential impact of climate change. c Y The impacts of the fishery on target, Bycatch and ETP species are identified and the main functions of these Components in the ecosystem are understood . There are no bycatch or retained species in this fishery and the disturbance of the seabed by divers during harvesting is negligible. ETP species for Ria de Pontevedra (marine fish, birds, reptiles and mammals) are not affected by the sword razor clam fishery because of the very small probability of them interacting with the fishery. d N Sufficient information is available on the impact of the fishery on the Components and elements to allow the main consequences for the ecosystem to be inferred. Although the fishery is unlikely to have any effect on the ecosystem, since interactions between species (e.g. trophic relationships) that occur in the Ria Pontevedra are not known, the team agreed that this PI issue is not met. e N Information is sufficient to support the development of strategies to manage ecosystem impacts. Although the team believes that the fishery does not have any effect on the ecosystem and therefore no specific strategy is needed, it was decided to apply the precautionary principle and thus this PI issue was

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PI 2.5.3 There is adequate knowledge of the impacts of the fishery on the ecosystem

Met? SG Issue Justification/Rationale (Y/N) not met since no information has be en collected or is intended to be collected in the near future. References Jenkins, 2004; Gaspar et al. , 2011

OVERALL PERFORMANCE INDICATOR SCORE: 85

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 3.1.1. The management system exists within an appropriate legal and/or customary framework which ensures that it: • Is capable of delivering sustainable fisheries in accordance with MSC Principles PI 3.1.1 1 and 2; • Observes the legal rights created explicitly or established by the customs of people dependent on fishing for food or livelihood; and • Incorporates an appropriate dispute resolution framework. Met? SG Issue Justification/Rationale (Y/N) 60 a Y The management system is generally consistent with local, national or international laws or standards that are aimed at achieving sustainable fisheries in accordance with MSC Principles 1 and 2. Spain, before joining the EU, signed the United Nations Convention on the Law of the Sea (UNCLOS 1982) which includes the legal framework governing international relations relating to the sea both in issues concerning areas of jurisdiction and sovereignty and environmental protection regulations. In addition to this treaty, Spain is also a signatory to the Conventions on the protection of the sea and the Paris Convention, Oslo Convention, London Convention, etc. With its accession to the EU as a full member (1986), the international conventions and treaties affecting protection of the sea and its biodiversity are signed or ratified by the European Commission on behalf of all EU member states and transposed later into their national policies. Since then the EU has signed several conventions intended to establish an international commitment to ensure both sustainable fishing and conservation of marine resources and biodiversity. Many of the directives of these conventions although voluntary are instead integrated into the relevant European policies and the Common Fisheries Policy (CFP) is no exception. Some of these conventions signed by the EU, and Spain as a member, are: the Code of Conduct for Responsible Fisheries (1995), UNEP 2010, CBD 2010, Aichi-Nagoya Targets 2010; etc Additionally, within the setting of the EU, Regulation No. 2371/2002 set a new framework establishing the objective of sustainable exploitation of fisheries resources in a context of sustainable development and taking into account a balance between the social, environmental and economic aspects. The adoption of Regulation (EC) No. 1198/2006 on the European Fisheries Fund (EFF) inspired by the Code of Conduct for Responsible Fisheries (FAO) reinforces this target of sustainability by giving some of these principles the force of law. Very recently, the EU has also signed other conventions relating to the sustainability of the sea and conservation of its resources and biodiversity under criteria of environmental, economic and social sustainability (Rio

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The management system exists within an appropriate legal and/or customary framework which ensures that it: • Is capable of delivering sustainable fisheries in accordance with MSC Principles PI 3.1.1 1 and 2; • Observes the legal rights created explicitly or established by the customs of people dependent on fishing for food or livelihood; and • Incorporates an appropriate dispute resolution framework. Met? SG Issue Justification/Rationale (Y/N) Summit +20). Conventions that are in accordance with MSC Principles 1 and 2. The condition of Spain's membership of the EU involves the adaptation of its Fisheries Policy to the legal framework established by the Common Fisheries Policy (CFP) as well as the Fisheries Laws of the Autonomous Communities concerned, as is the case of Galicia. The management system that guides all fisheries in Galicia meets the legal requirements and long-term objectives set by EU Regulation No. 850/98 as basis document that has guided the drafting of the fisheries laws of both the Government of Spain (Law 3/2001) and the Autonomous government of Galicia (Law 11/2008 of 3 rd December) as amended by Law 6/2009 of 11 December (Law 6/2009). A Regulation applicable to the regulation of fishing gear; species; minimum size; restrictions on fishing; etc. based on the precautionary principle and target of sustainable fisheries. Under it, the legal and judicial framework is broadly consistent with national and international laws and standards concerning sustainable fisheries in accordance with MSC Principles 1 and 2. The precautionary approach in the case of the fishery under assessment is inherent in the management system. b Y The management system incorporates or is subject by law to a mechanism for the resolution of legal disputes arising within the system. See 100 b) c Y Although the management authority or fishery may be su bject to continuing court challenges, it does not demonstrate disrespect or defiance of the law by repeatedly violating the same law or regulation necessary for the sustainability of the fishery. See 100 c) d Y The management system has a mechanism to generally respect the legal rights created explicitly or established by the customs of people dependent on fishing for food or livelihood in a manner consistent with the objectives of MSC Principles 1 and 2. See 100 d)

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The management system exists within an appropriate legal and/or customary framework which ensures that it: • Is capable of delivering sustainable fisheries in accordance with MSC Principles PI 3.1.1 1 and 2; • Observes the legal rights created explicitly or established by the customs of people dependent on fishing for food or livelihood; and • Incorporates an appropriate dispute resolution framework. Met? SG Issue Justification/Rationale (Y/N) 80 b Y The management system incorporates or is subject by law to a transparent mechanism for the resolution of legal disputes which is considered to be effective in dealing with most issues and that is appropriate to the context of the fishery. See 100 b) c Y The management sys tem or fishery is attempting to comply in a timely fashion to binding judicial decisions arising from any legal challenges. See 100 c) d Y The management system has a mechanism to observe the legal rights created explicitly or established by the customs of people dependent on fishing for food or livelihood in a manner consistent with the objectives of MSC Principles 1 and 2. See 100 d) 100 b Y The management system incorporates or subject by law to a transparent mechanism for the resolution of legal disputes that is appropriate to the context of the fishery and has been tested and proven to be effective . The resolution of conflicts between divers and the Administration are resolved through dialogue and direct negotiations. Failing that, through claims by those affected against the Administration and appeals, both administratively and, if rejected, through the court system at the various instances that prove necessary for the resolution of disputes between the parties (Supreme Court of Justice of Galicia). The management system has transparent and explicit mechanisms for dispute resolution and which are appropriate to the fishery's context. They have been tested and shown to be effective.

c Y The management system or fishery acts proactively to avoid legal disputes or rapidly implements binding judicial decisions arising from legal challenges. The management system complies in a timely fashion with the legal decisions arising from legal disputes and is proactive in avoiding them. See section 3.5 subsections 3.5.2 and 3.5.3

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The management system exists within an appropriate legal and/or customary framework which ensures that it: • Is capable of delivering sustainable fisheries in accordance with MSC Principles PI 3.1.1 1 and 2; • Observes the legal rights created explicitly or established by the customs of people dependent on fishing for food or livelihood; and • Incorporates an appropriate dispute resolution framework. Met? SG Issue Justification/Rationale (Y/N) d Y The management system has a mechanism to formally commit to the legal rights created explicitly or established by the customs of people dependent on fishing for food and livelihood in a manner consistent with the objectives of MSC Principles 1 and 2. In the particular case of the fishery under assessment, shell -fish er men's rights are explicit and legally protected by the legal codification system (indefinite licenses renewable annually) that governs formal access to the fishery. In the PEs, the divers themselves or the Administration may propose increases in licenses depending on the state of the fishery but it is the CMRM which has the authority to approve them (see section 3.5 subsection 3.5.7). There is an explicit legal framework that favours the implementation of a management system which is highly likely to contribute to the sustainable exploitation of the fishery. In this regard, the operational framework is consistent with the laws and legal framework at the local, national and international levels. Regulation (EC) No. 850/98: http://www.maec.es/fr/MenuPpal/EspanayUE/Politicascomunitarias/Documents/b a30411417e44449ad39bdce5416540freglamento4.pdf Regulation (EC) No. 2371/2002 ( http://eur- lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2002:358:0059:0080:ES:PDF ) Regulation (EC) No. 1109/2006 ( http://www.boe.es/doue/2006/223/L00001- 00044.pdf ) Spanish Constitution: References (http://noticias.juridicas.com/base_datos/Admin/constitucion.t8.html ) Fisheries Law of Galicia 6/2009 of 11 th December (http://www.fedpemar.es/doga15122009.pdf ) Fisheries Law of Spain 3/2001 (http://noticias.juridicas.com/base_datos/Admin/l3-2001.html ) Penalty system law 11/2008 of 3 rd December (Regional Government of Galicia): ( http://noticias.juridicas.com/base_datos/CCAA/ga-l11-2008.t14.html ) Code of Conduct for Responsible Fisheries (http://www.fao.org/fishery/code/es ) OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 3.1.2 The management system has effective consultation processes that are open to interested and affected parties. PI 3.1.2 The roles and responsibilities of organisations and individuals who are involved in the management process are clear and understood by all relevant parties Met? SG Issue Justification/Rationale (Y/N) 60 a Y Organisations and individuals involved in the management pr ocess have been identified. Functions, roles and responsibilities are generally understood. See 100 a) b Y The management system includes consultation processes that obtain relevant information from the main affected parties, including local knowledge, to inform the management system. See 100 b) 80 a Y Organisations and individuals involved in the management process have been identified. Functions, roles and responsibilities are explicitly defined and well understood for key areas of responsibility and interaction. See 100 a) b Y The management system includes consultation processes that regularly seek and accept relevant information, including local knowledge. The management system demonstrates consideration of the information obtained. See 100 b) c Y The consultation process provides opportunity for all interested and affected parties to be involved. See 100 c) 100 a Y Organisations and individuals involved in the management process have been identified. Functions, roles and responsibilities are explicitly defined and well understood for key areas of responsibility and interaction. All organisations, institutions and individuals involved in the management system are easily identifiable and defined explicitly. See section 3.5 subsection 3.5.2 b Y The management system includes consultation processes that regularly seek and accept relevant information, including local knowledge. The management system demonstrates consideration of the information and explains how it is used or not used . All parties involved participate in the consultative processes regularly. Relevant information is used (however incomplete information) as well as the knowledge of divers and there is an explanation of the manner in which this information is used or not. See section 3.5 subsections 3.5.2 and 3.5.3.

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The management system has effective consultation processes that are open to interested and affected parties. PI 3.1.2 The roles and responsibilities of organisations and individuals who are involved in the management process are clear and understood by all relevant parties Met? SG Issue Justification/Rationale (Y/N) c Y The consultation process provides opportunity and encouragement for all interested and affected parties to be involved, and facilitates their effective engagement. Decree 423/1993 (17th Dec ember) on consolidation of the current regulations on shell fishing, as amended by Decree 237/2002 (11th July), makes explicit the consultative character with regard to formulation of the MP. The technical and socioeconomic formulation of the MP requires a highly participatory system of consultation between all stakeholders: divers, checkpoint, TA, associations, Biologist of the Area, Territorial Authority, the DXIDP and CMRM. The design of the Management Plans has explicit mechanisms (participatory and consultative process) that provide an incentive for cooperation between the parties involved in the management system. See section 3.5 subsections 3.5.2. and 3.5.3 References

OVERALL PERFORMANCE INDICATOR SCORE: 100

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 3.1.3 The management policy has clear long -term objectives to guide decision -making PI 3.1.3 that are consistent with MSC Principles and Criteria, and incorporates the precautionary approach Met? SG Issue Justification/Rationale (Y/N) 60 a Y Long -term objectives to guide decision -making, consistent with the MSC Principles and Criteria and the precautionary approach, are implicit within management policy See 80 a) 80 a Y Clear long -term objectives that guide decision -making, con sistent with MSC Principles and Criteria and the precautionary approach are explicit within management policy. The fishery's long term objectives are clearly defined in the CMRM management policy. They guide decision-making and are consistent with MSC Principles and Criteria. The precautionary approach is inherent in the management policy and is applied consistently and with the information available during the design of the fishery's management plan. 100 a N Clear long -term objectives that guide decis ion -making, consistent with MSC Principles and Criteria and the precautionary approach, are explicit within and required by management policy. The long -term goals are clearly defined in the CMRM management policy but are not applicable to the management plans of the fishery under assessment given the life history and dynamics of the target species. This has been identified in section 3.3.1. and 3.3.2 mainly the short lifespan, fast growth and high variability in success of spatfall and recruitment. The application of long-term management models can not therefore be apllied. Nevertheless, the annual management plans are consistent with MSC Principles and Criteria. The precautionary principle is applied in a more conservative way. Fisher ies La w of Galicia 6/2009 of 11 th December (http://www.fedpemar.es/doga15122009.pdf ) Fisheries Law of Spain 3/2001 (http://noticias.juridicas.com/base_datos/Admin/l3-2001.html ) References Penalty system law 11/2008 of 3 rd December (Regional Government of Galicia): ( http://noticias.juridicas.com/base_datos/CCAA/ga-l11-2008.t14.html ) Code of Conduct for Responsible Fisheries (http://www.fao.org/fishery/code/es ) OVERALL PERFORMANCE INDICATOR SCORE: 80

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 3.1.4 The management system provides economic and social incentives for sustainable PI 3.1.4 fishing and does not operate with subsidies that contribute to unsustainable fishing Met? SG Issue Justification/Rationale (Y/N) 60 a Y See 80 a) 80 a Y The managem ent system provides for incentives that are consistent with achieving the outcomes expressed by MSC Principles 1 and 2, and seeks to ensure that perverse incentives do not arise. Access to the fishery is regulated by a finite number of licenses appropr iate to its size. The effort on the resource is determined by the economic and environmental objectives. Owning and maintaining a license in this fishery is a certain guarantee for maintaining a fairly stable source of income. The fishery has subsidies or positive incentives. The checkpoint water bailiff and TA are both co-funded. The CMRM finances 40% and 82% of the TA and water bailiff respectively. The balance is financed by the divers themselves. This model in which the fishermen participate in co-funding the fishery implies a high degree of involvement and reinforcement of the objectives of sustainability of the fishery consistent with MSC Principles 1 and 2. Additionally, there are other incentives offered by the CMRM that open up the opportunity to the fisheries sector some aspect of the fishery (monitoring, scientific research on the resource; clean-up funds; trading, etc). It does this through annual public calls for proposals in relation to which, through the associations, fishermen from a particular fishery can submit specific projects. In the case at hand, the assessment of Solenidae in Ría de Pontevedra carried out by FISMARE consultancy is an example. See section 3.5 subsection 3.5.5 The management system provides incentives (social, economic and environmental) that are consistent with MSC Principles 1 and 2 and ensures that there are no explicit incentives that are perverse and that can lead to the overexploitation of the stocks. See section 3.5 subsection 3.5.5 100 a N The management system pr ovides for incentives that are consistent with achieving the outcomes expressed by MSC Principles 1 and 2, and explicitly considers incentives in a regular review of management policy or procedures to ensure they do not contribute to unsustainable fishing practices. The management system provides incentives that are explicit and consistent with MSC Principles 1 and 2. The incentives are not subject, under the management policy, to regular review in the management system. References

OVERALL PERFORMANCE INDICATOR SCORE: 85

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The management system provides economic and social incentives for sustainable PI 3.1.4 fishing and does not operate with subsidies that contribute to unsustainable fishing Met? SG Issue Justification/Rationale (Y/N)

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 3.2.1 The fishery has clear, specific objectives designed to achieve the outcomes PI 3.2.1 expressed by MSC’s Principles 1 and 2 Met? SG Issue Justification/Rationale (Y/N) 60 a Y Objectives , which are broadly consistent with achieving the outcomes expressed by MSC’s Principles 1 and 2, are implicit within the fishery’s management system. See 80 a) 80 a Y Short and long -term objectives , which are consistent with achievin g the outcomes expressed by MSC’s Principles 1 and 2, are explicit within the fishery’s management system. The long -term objectives are provided for in the Fisheries Law of Galicia but not implicitly in the management system of the fishery under assessment. The fishery does not justify having long-term objectives because the management of this species does not allow it, as stated in Principle 1.1.1. Management Plans are valid for one year and constitute a management strategy with short-term objectives. The annual monitoring of the fishery is appropriate for these fisheries, as it adapts to the life history and dynamics (short-lived, fast growing, etc) of the target species. See section 3.5 subsection 3.5.5 100 a N Well defined and measurable short and l ong -term objectives , which are demonstrably consistent with achieving the outcomes expressed by MSC’s Principles 1 and 2, are explicit within the fishery’s management system. No explicit long -term objectives are provided for in the fishery's specific management system. References

OVERALL PERFORMANCE INDICATOR SCORE: 80

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 3.2.2 The fishery -specific management system includes effective decision -making PI 3.2.2 processes that result in measures and strategies to achieve the objectives Met? SG Issue Justification/Rationale (Y/N) 60 a Y There are some decision -making processes in place that result in measures and strategies to achieve the fishery-specific objectives. See 80 a) b Y Decision -making processes respond to serious issues identified in relevant research, monitoring, evaluation and consultation, in a transparent, timely and adaptive manner and take some account of the wider implications of decisions. See 80 b) 80 a Y Decision -making processes are established that result in measures and strategies to achieve the fishery-specific objectives. The decision making process in the fishery is close to a co -management model, both for the design of MP as for everyday decision-making. The MPs are designed to establish measures and strategies that guarantees the sustainability of the fishery. The MP is flexible enough so that the divers themselves may take some direct decisions (without consulting the CMRM but under the supervision of the TA) such as, reduce catch quotas; close a fishing area; switch between fishing areas, etc. Communication between the parties (divers, TA and CMRM) is direct and easy, allowing high flexibility in the making decisions process. Decision-making processes have been established that result in measures and strategies to achieve the fishery's specific objectives. This process is well established. See section 3.5 subsection 3.5.8. 3.5.3. b Y Decision -making processes respond to serious and other important iss ues identified in relevant research, monitoring, evaluation and consultation, in a transparent, timely and adaptive manner and take account of the wider implications of decisions. The design of the annual MP is the result of the integration of fishery, economic-social and political information and data provided by several stakeholders (TA; biologists Area; INTECMAR; divers and Confrarias; CMRM). The decision-making process enables a transparent and effective response to important or serious issues that may be identified in the monitoring, research or assessment of the fishery. See section 3.5 subsections 3.5.2; 3.5.3; 3.5.8. c Y Decision -making processes use the precautionary approach and are based on best available information. The design of MP is based on the available information (CPUE and structure of the catches). This information supports the exploitation strategy defined

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The fishery -specific management system includes effective decision -making PI 3.2.2 processes that result in measures and strategies to achieve the objectives Met? SG Issue Justification/Rationale (Y/N) for the next year. In the absence of full information about the fishery, the precautionary principle is applied systematically which is reflected in the fishing effort: daily quota; maximum number of fishing days, maximum number of divers, etc. The precautionary approach is inherent to the decision-making process and is applied. The decision-making process is based on the best information available. See section 3.5 subsections 3.5.2; 3.5.3; 3.5.8. d Y Explanations are provided for any actions or lack of action associated with findings and relevant recommendations emerging from research, monitoring, evaluation and review activity. MPs are reviewed annually. This peculiarity allows the integration of new information arising from research and monitoring activities, which may result in the modification of the management measures to be set for the next year. The recommendations arising from the assessment, monitoring and scientific research processes are explained. 100 b N Decision -making processes respond to all issues identified in relevant research, monitoring, evaluation and consultation, in a transparent, timely and adaptive manner and take account of the wider implications of decisions. The decision -making process does not respond to all the issues of a scientific nature relating to the fishery, above all some of the issues outlined in Principle 1. The lack of a full stock assessment and other scientific information that could be significant, means that the precautionary approach should be applied much more conservatively to the MP. d N 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. The report that is disseminated among the stakeholders does not contain recommendations associated with scientific research, as evidenced in Principle 1. References

OVERALL PERFORMANCE INDICATOR SCORE: 80

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 3.2.3 Monitoring, control and surveillance mechanisms ensure the fishery’s management PI 3.2.3 measures are enforced and complied with Met? SG Issue Justification/Rationale (Y/N) 60 a Y Monitoring, control and surveillance mechanisms exist and are implemented in the fishery under assessment and there is a reasonable expectation that they are effective. See 80 a) b Y Sanctions to deal with non -compliance exist and there is some evidence that they are applied. There is evidence that the control mechanisms are applied. Although there are penalties, in the case of the fishery in question, they are relatively rare. The main causes of penalties are failing to pass through the checkpoint and exceeding the quota. c Y Fishers are generally thought to comply with the management system for the fishery under assessment, including, when required, providing information of importance for the effective management of the fishery. The divers are generally aware of the importance of complying with the fishery's management system and cooperate practically in the MP's design process. They are organised internally and provide relevant information for effective management of the fishery. See subsections 3.5.8 and 3.5.3 80 a Y A monitoring, control and surveillance system has been implemented in the fishery under assessment and has demonstrated its ability to enforce relevant management measures, strategies and/or rules. The MP clearly sets out the water bailiff's functions (Checkpoint control ): conduct the daily monitoring of harvesting; perform internal and external monitoring of the resource and apply penalties if necessary. Therefore, the fishery has a monitoring and control system that has been implemented and which demonstrates its capacity to enforce the fishery's measures and strategies. See section 3.5 subsection 3.5.9 b Y Sanctions to deal with non -compliance exist, are consistently applied and thought to provide effective deterrence. Sanctions are dissuasive and consistently applied. c N Some evidence exists which demonstrates fishers comply with the management system under assessment, including, when required, providing information of importance for the effective management of the fishery. The m embers of the fishery cooperate with the management system by providing meaningful information voluntarily and proactively as well as when required to do so. Nevertheless, there are some evidence of non- compliance. See SG80d

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Monitoring, control and surveillance mechanisms ensure the fishery’s management PI 3.2.3 measures are enforced and complied with Met? SG Issue Justification/Rationale (Y/N) d N There is no evidence of systematic non -compliance. Member divers of the fishery have unanimously agreed (verbally) that, as a compensatory measure for the operation of the monitoring system and sea checkpoint, each diver may once per week sell one daily catch quota outside the formal marketing channels. In this way, the unaudited sale for that day provides them with some additional net income which is used, up to the present day, to finance control at sea and technical assistance. It is important to highlight that this practice is known by Fishing Administration.

Divers, administration and the audit team have all identified the need to eradicate this malpractice. For this reason we have defined a Condition for this performance indicator. 100 a N A comprehensive monitoring, control and surveillance system has been implemented in the fishery under assessment and has demonstrated a consistent ability to enforce relevant management measures, strategies and/or rules. There is a comprehensive control and surveillance system but no systematic and comprehensive scientific monitoring of the fishery. There has not been a full assessment of the fishery, as set out in Principle 1. b N Sanctions to deal with non -compliance exist, are consistently applied and demonstrably provide effective deterrence. See 80 c) c N There is a high degree of confidence that fishers comply with the management system under assessment, including, providing information of importance for the effective management of the fishery. See 80 c)

References

OVERALL PERFORMANCE INDICATOR SCORE: 70

CONDITION NUMBER (if relevant): 1

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Evaluation Table: PI 3.2.4 The fishery has a research plan that addresses the information needs of PI 3.2.4 management Met? SG Issue Justification/Rationale (Y/N) 60 a Y Research is undertaken, as required, to achieve the objectives consistent with MSC’s Principles 1 and 2. See 80 a) b Y Research results are available to interes ted parties. See 80 b) 80 a Y A research plan provides the management system with a strategic approach to research, in addition to reliable and timely information sufficient to achieve the objectives consistent with MSC’s Principles 1 and 2. There is a clear research plan that was designed taking in consideration the biology and ecology of the target species. Data gathered comprises: biomass landed per day, fishing days, size structure of the catches; estimation of CPUE. This information is analysed a biologist (TA). Additional information can be obtained by research institutes and/or universities. Therefore, research plans is sufficient and consistent with the objectives of Principle 1 and 2 of the MSC. See section 3.5 subsections 3.5.2, 3.5.3 and 3.5.8. b Y Research results are disseminated to all interested parties in a timely fashion. The results of the research plans provided by the TA, the CMRM, the INTECMAR, CIMA and other related institutions, are reported and distributed to stakeholders in a timely manner. The research results are disseminated in a timely manner to stakeholders who have access to them within an adequate time. See section 3.5 subsection 3.5.2. 100 a N A comprehensive research plan provides the management system with a coherent and strategic approach to research across P1, P2 and P3, in addition to reliable and timely information sufficient to achieve the objectives consistent with MSC’s Principles 1 and 2. There is no comprehensive research plan from the scientific point of view , for each and every aspect which may affect a fishery and its management system. Scientific research is fragmented (although is sufficient and consistent with the Principles 1 and 2 of MSC) and does not provide full information regarding the status of the stock, as it was stated in Principle 1. b N Research plan and results are disseminated to all interested parties in a timely fashion and are widely and publicly available .

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A comprehensive research plan for the fishery is lacking. Refer ences

OVERALL PERFORMANCE INDICATOR SCORE: 80

CONDITION NUMBER (if relevant):

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Evaluation Table: PI 3.2.5 There is a system of monitoring and evaluating the performance of the fishery - PI 3.2.5 specific management system against its objectives There is effective and timely review of the fishery-specific management system Met? SG Issue Justification/Rationale (Y/N) 60 a Y The fishery has in place mechanisms to evaluate some parts of the management system. See 100 a)

b Y The fishery -specific m anagement system is subject to occasional internal review. See 80 b) 80 a Y The fishery has in place mechanisms to evaluate key parts of the management system See 100 a) b Y The fishery -specific management system is subject to regular internal and occasional external review. The specific management system is subject to regular (annual) internal reviews and occasional external reviews. There is a recent report by the company FISMARE on "pre-assessment of the razor clam fishery in Ría de Pontevedra," that was carried out at the request of the Fishermen's association of San Martiño de Bueu which was co-funded by the CMRM. 100 a Y The fishery has in place mechanisms to evaluate all parts of the management system. There are mechanisms to eva luate all measurable parts of the management system with existing administrative, technical and scientific resources. The processes and procedures used ensure the sustainability of the fishery in the most essential parts of the management system. All processes are met (monitoring, management, scientific knowledge, etc.) and are reviewed annually. See section 3.5 subsections 3.5.2, 3.5.8 and 3.5.9. b N The fishery -specific management system is subject to regular internal and external review. The specif ic management system is not subject to regular external review. Currently, the costs of the review are too high to accomplish this objective. Assessment of the razor clam fishery in Ría de Pontevedra"; 2010 FISMARE consultancy. Report 1: Study of the physical environment of razor clam beds in Ría de References Pontevedra: hydrodynamics and characterisation of sedimentary floors. Report 2: I. Development of a high resolution digital mapping of shellfish beds of razor clam and pod razor shell.

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II. Direct as sessment of the status of razor clam and pod razor shell populations in Ría de Pontevedra. Report 3: Analysis of historical data from the fishery. OVERALL PERFORMANCE INDICATOR SCORE: 90

CONDITION NUMBER (if relevant):

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Appendix 1.2.Risk Based Framework (RBF) Outputs Direct impact of Present Rationale Fishing activity fishing (Y/N) Bait collection NO No bait is used. YES The fishing activity itself can affect the Fishing Capture sustainability of the resource. NO The fishermen argued that once the allocated Incidental behaviour quota had been reached they stop fishing. Bait collection NO No bait is used NO During the fishing activity some sword razor clams may be damadged. However, daily Fishing practice and fishermen experience ensure that Direct impact this impact is minimal. without capture NO No incidental behaviours have been identified Incidental behaviour in this fishery. Gear loss NO Fishing gear are not used in the fishery. Anchoring/mooring NO Insignificant given that they anchor in the sand. Navigation/steaming NO It is a benthic organism so there is no impact. NO The juveniles that are caught incidentally are Translocation of species (boat immediately released by the divers. The launching, reballasting) incidental introduction of exotic species is not an issue. Addition/movemen NO Very selective fishery. There are no discarded t of biological Discarding catch species. material NO Not carried out. The stocks are considered to be Stock enhancement in a healthy state of conservation. Provision NO All individuals caught are declared in the point of control. Disturb physical Bait collection NO No bait is used. processes NO Highly selective fishing method not affecting Fishing the habitat or associated species. Boat launching NO Impact on the habitat is negligible. Anchoring/mooring NO Impact on the habitat is negligible. Navigation/steaming NO Impact on the habitat is negligible. External Hazards Other fishery capture methods YES There is a fishery that used a towed dredged for (specify the Venerupis senegalensis which can interfere in particular example the sword razor clam fishery. However, there is within each activity only one boat which works for 10 days per year. area) Nevertheless, since razor clams are fast burrowers low damadged levels are expected. Moreover the fishery only occurs at depths higher than 15m. Stakeholders considered the impact to be very low.

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Table 1.2.1: Principle 1 SICA Scoring Template Target Species Performance Indicator Risk -causing Spatial scale Temporal Intensity of activity Relevant Consequence MSC activities of activity scale of subcomponents score Score activity

Target species outcome Fishing activities 5 (46 -60%) 5 (200 -300 2 (activity occurs Population size 1 100 from all fisheries days of rarely or in few

including: fishing) restricted locations Reproductive and evidence of • Direct capture capacity activity even on Age/size/sex these scales is rare) structure

Geographic

range Rationale: Stakeholder considered that the most significant combination of activity -component -subcomponent for this PI was the impact of razor clam harvesting on population size. All stakeholders present in the RBF meeting agreed that this impact was

negligible, leading to a SICA score of 1, which converts to an MSC score of 100. The reason pointed out by stakeholders to reach this score were as follows: 1) The footprint of the fishery is relatively low since only 15-20% of the fishable area is exploited every year. 2) Although Ensis arcuatus can occur up to 15-16m depth in Ría Pontevedra, divers only exploit beds down to 12m in depth, since snorkelling and "hookah" does not allow them to dive deeper. Thus, it can be considered that the areas between the bathymetries of 12-16m act as breeding sanctuaries. 3) Over the last 5 years CPUE has been relatively constant, which indicates that the sword razor clam populations of Ria Pontevedra are healthy; 4) If a significant decrease on CPUE is noticed, measures are put in place in order to reduce fishing effort, aimed at counteracting this trend. The team fully agreed with this assessment done by stakeholders.

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Productivity-Susceptibility Analysis (PSA) Considering the life history attributes of Ensis arcuatus it was concluded that this species has a high productivity. Susceptibility to fishing pressure was scored as medium or high for attributes 1 and 2, respectively, and low for the remaining two attributes. Concerning areal overlap susceptibility was considered medium due to the fact that only 15-20% of the fishable area is exploited, whereas susceptibility for the vertical overlap attribute was classified as high since although razor clams can burrow into the sediment up to 60 cm in depth, individual ones remain near the surface for feeding most of the time and therefore a high vertical overlap occurs. Once sword razor clams are harvested by hand selectivity is extremely high and therefore susceptibility for the selectivity attribute was low. Similarly, the post-capture mortality attribute was classified as low because if undersized razor clams are accidentally caught they are released in situ which allows them to re-burrow almost immediately escaping predation. This led to an overall score for the PSA of 1.57 which corresponds to a MSC score of 99.7 (rounded to 100) – the same score as the SICA, and the final score for PI 1.1.1. Productivity Seven attributes of the life history of Ensis arcuatus were considered and scored to achieve productivity. The scores and rationale for each attribute are shown in the following Table. Productivity score. Value Score Reference Average age at maturity Full spawning by the second year 1 Hernández -Otero et al ., (1+) 2011b, 2012 Average maximum age Around 6 years 1 Hernández -Otero et al. , 2011b, 2012 Fecundity More than 3000000 eggs emitted 1 Joaquin Espinoza, per female pers.com.; da Costa et al. , 2008. Average maximum size Around 15 cm shell length 1 Average size at maturity Around 8 cm shell length 1 Hernández -Otero et al ., 2012 Reproductive strategy Broadcast spawner 1 Joaquin Espinoza, pers.com.; da Costa et al. , 2008. Trophic level Main food source is phytoplankton 1 http://www.seaaroundu but other feeding sources can be s.org/eez/724/200.aspx# used sporadically or depending on the environment. Trophic level is around 2. Overall score Arithmetic mean of scores 1

Susceptibility Susceptibility scores four attributes of the fishery in relation to the Ensis arcuatus population, notably areal overlap, vertical overlap, selectivity and post-release mortality. However, since the selectivity attribute is not defined by MSC for this particular gear type it was defined by the team.

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Based on this, the team proposed dividing the selectivity of hand harvesting into three categories taking into consideration the MLS. The MLS established for the species (100mm) allows E. Arcuatus to spawn at least once before being captured: 1. Low risk score for selectivity for the species: more than 95% of the razor clams picked by divers have the minimum legal size. 2. Medium risk score for selectivity for the species: 75%-95% of razor clams picked by divers have the minimum legal size. 3. High risk score for selectivity for the species: <75% of razor clams picked by divers have the minimum legal size. The scores and rationale for each attribute are shown in the following Table.

Susceptibility score. Value Score

Areal Overlap 15 -20% of the fishable area is exploited every year. 2

Vertical Overlap Sword razor clams live burrowed into the sediment up to 3 60 cm in depth. However individual ones remain near the surface for feeding most of the time and therefore a high vertical overlap occurs.

Selectivity Hand picking is a very selective method and therefor e 1 most of the individuals caught are above the MLS.

Post -capture mortality Post -capture mortality is negligible – undersized sword 1 razor clams are discarded immediately in situ by the diver.

Overall score 1.13

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Appendix 1.3. Conditions Table A1.3: Condition 1

Performance 3.2.3 . Monitoring, control and surveillance mechanisms ensure the fishery’s Indicator management measures are enforced and complied with

Score 70

Rationale See pages 95 and 96 .

By th e second surveillance audit, t he fishery under assessment and therefore all the divers which form part of the MP for the razor clam fishery of the Ría de Pontevedra, must eradicate the unregulated sale of one of the weekly quotas Condition and ensure that all catches are sold in the fish auction and are registered for tax purposes. By the third surveillance audit the fishery must also demonstrate that there is no evidence of systematic non-compliance and therefore a high degree of confidence.

As soon as t he malpractice referring the unregulated one day sale eradicate the SG80d score could be reached, achieving full compliance with the management system. In addition as staded in the client action plan, will implement a protocol of rules violations so they could achieve the SG100b and Milestones c. In conclusion and considering the previous information, by the second survailance audit the fishery would be willing to reach the score 95. To assess the effectiveness of the condition, the CAB will compare all the catches recorded by the water bailiff at the checkpoint against total sales from the fish auction.

Client action plan See page 108 for the client’s Plan of Action.

As the attainment of the condition depends directly on the fishers incl uded in Consultation on the certification unit and is based on an improvement in the management of condition the fishery the consultation process has been done with the client.

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Client Action Plan

When Conditional Requirement How meet By Whom Completed

Development of rules, Fishermen and regulations and disciplinary Cofradías (Fishermen January 2013 measures for the users Associations) taking who market MSC. part in the Fishery.

Development of the The fishery under protocol for the Fishery technician January 2013 assessment and communication of assistant unit. therefore all the infringements.

Year 1Year divers which form Fishermen and part of the Catches sold in the fish Cofradías (Fishermen Management Plan auction equal or bigger October 2013 Associations) taking for the razor clam than 90 %. fishery of the Ría part in the Fishery. de Pontevedra, Commun ication of must eradicate violations of the rules, Fishery technician the unregulated regulations and current assistant unit and October 2013 sale of one of the legality to the Cofradía de Pescadores weekly quotas management authority de Bueu. within two years equal or higher than 70%. and ensure that all catches are sold in Fishermen and the fish auction All catches are sold in the Cofradías (Fishermen October 2014 and are registered fish auction. Associations) taking for tax purposes. part in the Fishery. Year 2Year Full communication of the Fishery technician violations of the rules, assistant unit and regulations and current October 2014 Cofradía de Pescadores legality to the de Bueu. management authority.

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Appendix 2 Peer Review Report

Peer Reviewer 1

Has the assessment team arrived at an Conformit y Assessment Body appropriate conclusion based on the evidence Yes Response presented in the assessment report? Justification: This is a small, well-managed fishery, based on a small clearly- defined area and fished by a small number of boats. The method used to harvest the razor clams, by diving, is highly selective and has very little environmental impact. The fishery has access to good scientific support.

Do you think the condition(s) raised are Conformity Assessment Body appropriately written to achieve the SG80 Yes Response outcome within the specified timeframe? Justification: The one condition raised is very appropriate and it is essential that this officially condoned malpractice is eliminated. The condition is appropriately written to achieve SG80 within the 2-year period set.

If included: Do you think the client action plan is sufficient Yes Conformity Assessment Body to close the conditions raised? Response Justification: The action plan should be sufficient but will depend on the support of the divers and will need initial close surveillance

General Comments on the Assessment Report (optional) This is generally a straightforward fishery and has been subjected to a thorough and correctly carried out assessment according the to MSC requirements. There are, however, a few issues that I believe need clarification.

1. The assessment is based almost entirely on the sword razor clam Ensis arcuatus , which apparently makes up 90% of the catch, with the other 10% composed of the pod razor shell Ensis siliqua and the grooved razor shell Solen marginatus. My question to the team is - are you considering these latter two species to be target species? In this case the stocks of these two species needs to be assessed, together with the impact of the fishery on them. If not, then they must be considered to be retained species and should be considered in the scoring of 2.1.

2. The malpractice noted in SI 3.2.3, which gave rise to the condition, was not previously mentioned in the text and needs further explanation. For example, do these catches appear in the official landing statistics for the fishery or are they completely unrecorded? This could be quite important since one daily catch quota per diver per week could amount to some

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20% of the total catch. If these landings are not recorded, is there any monitoring of the weight of catch taken on this day? This could provide a mechanism for further abuse.

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Performance Indicator Review

Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation information and/or raised where possible. Please attach additional pages if available rationale used improve the necessary. been used to score this fishery’s to score Indicator performance this support the to the SG80 Indicator? given score? level? (Yes/No) (Yes/No) (Yes/No/NA)

1.1.1 Yes Yes NA RBF used

1.1.2 Yes Yes NA RBF default score

1.1.3 NA NA NA

1.2.1 Yes No NA Not clear from the rationale why the score The team decided to assign a higher weight to SG100d of 90 was awarded when 2 out of 3 issues since the scoring issue that this SG relates to, “Harvest are not met. strategy review”, were not evaluate in SG60 and 80. On the contrary, the other 2 scoring issues of SG100 were previously evaluated in both SG60 and SG80.

1.2.2 Yes Yes NA

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1.2.3 Yes No NA I agree the score but am not convinced According to the interviews made with stakeholders, that ‘lllegal fishery is not relevant recreational fishing for razor clams in Ria Pontevedra is considering the low number of sanctions neglectable or even nil, due to: applied in recent years’ . The fact that they are not being caught is, in itself, not good evidence that it does not occur. Do 1) According to the Galician law, recreational fishery recreational divers not take razor clams towards commercial species subject to a management for their own consumption? How can this plan is forbidden; be monitored? 2) The depth distribution of Ensis arcuatus makes its access extremely difficult to recreational fishers. 3) In Ria de Pontevedra scuba-diving fishing is only carry out in rocky areas, areas where Ensis arcuatus does not occur. Moreover if scuba divers enters the authorization areas attributed to the Confrarias they are easily detected; 4) Sometimes recreational fishing is practice in Ria Pontevedra but in the intertidal areas of the Ria and towards to other bivalve species such as cockles (Cerastoderma edule) and the (Ruditapes decussatus) but only during the Summer.

Moreover, according to the Deputy Directorate General for Coastguards of Galicia. the IUU although may exist is neglectable when compared to other fisheries.

1.2.4 Yes Yes NA RBF default score

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2.1.1 Yes Yes but see NA See General Comment about whether E. The team agreed that the text on page 12 could lead to comment siliqua and S. marginatus should be misinterpretations and therefore was changed. Ensis considered as target species or retained siliqua and Solen marginatus are not caught since 2005, species due to the low commercial value of the species. In this way and also bearing in mind the opinion of stakeholders, the team considered that no retained species exists in the fishery.

2.1.2 Yes Yes NA

2.1.3 Yes No NA There may be no retained species at The fishing license that is hold by the divers is exclu sively present but what if the divers started to for the harvesting of razor clams. Therefore they are not land other species? Would there be a allowed to land other species. Moreover, the fishery is mechanism in place to detect this if there is no monitoring. The score of 100 may continuously and daily monitored by a water bailiff that not be justified. control all the catches from all the divers. Nevertheless, the team agreed that in the subsequent fishing audits this issue will be followed in order to guarantee that no other species are retained by divers.

2.2.1 Yes Yes NA

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2.2.2 Yes No NA The rationales for 100 c and d simple According to the MSC guidelines, bycatch must be state that there is no bycatch but it should interpreted as the species in the catch that are not still be possible to have a strategy even if retained and that are discarded as well as those that die there is at present no need to implement it. because of unobserved fishing mortality.

In this fishery, sword razor clams are picked up by hand by divers and no tools are used. This is an extremely selective fishery where only the target species is harvested. Divers are obliged to release in situ all the undersized razor clams that are caught accidentally. No impact on other species occurs. Since other fishing methods are not and, at the present, can not be allowed, the team believes that in the near future (at least in the next five years – the duration of the MSC certification) this panorama won’t change and therefore the team really believes that a strategy for bycatch is not needed.

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2.2.3 Yes No NA If there is no monitoring how can you be Indeed, there is not in place a monitor ing plan for sure that there is no need? bycatch. As it was mentioned before the fishery is extremely selective and therefore only the target species is caught. In addition, other benthic species are rarely dislodged. This was corroborated in similar fisheries by one of the elements of the auditor team that dived for several years with professional razor clam divers to ascertain how the fishing is undertaken and to observe fishing impacts. On the other hand, the fishery is continuously and daily surveilled by a water bailiff that control both the divers fishing behaviour and the catches. This procedure ensures that the daily quota is accomplished and that no other fishing techniques are used. This fishery is probably one of the most benign fisheries in the world. Therefore, the team still believes that there is no need to design a specific bycatch monitoring program.

2.3.1 Yes Yes NA

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2.3.2 Yes No NA PI 2.3.2 is about EPT species but the Indeed, there is not in place a precautionary rationales for 100c and d are about the management strategy related to ETP species specifically strategy for razor clam stocks so the for this fishery, as it was referred in SG100a. In PI 2.3.1 score of 100 has not been justified. I do not believe there is a precautionary the rationale for SG100c says that no detrimental direct management strategy specifically related effects on ETP species related to this fishery is expected to ETP species in place in this fishery so considering all the aspects inherent to the fishery itself the score of 100 cannot be justified such as, harvesting technique, management plan, etc. Moreover, within Ria Pontevedra, in the sword razor clam fishing grounds, ETP species does not occur (according to stakeholders, including NGO’s). Nevertheless, concerning indirect effects, as it was mentioned in PI 2.3.1, SG100c, if ETP species occurs in Ria Pontevedra the potential indirect effects would be the removal of the razor clams as food sources. In this sense, managers must have to design a fishing management plan in order to maintain in good health the sword razor clams populations. This was the reason underlying the rationale of SG 100c and d of PI 2.3.2. We agree with the reviewer, that the rationale, as it is, is not clear and may confuse the reader. Therefore, the rationale of SG 100c and d was changed in order to accommodate what was abovementioned.

2.3.3 Yes Yes NA

2.4.1 Yes Yes NA

2.4.2 Yes Yes NA

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2.4.3 Yes Yes NA Justification for 100b should state which We agree with the reviewer. References were added. authors have quantified the physical effects of hand harvesting

2.5.1 Yes Yes NA

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2.5.2 Yes No NA If you do not fully understand the According to the MSC guidelines it is mentioned that for functional relationships between the the evaluation of PI 2.5. 2 It may not be necessary to have fishery and the Components and a specific “ecosystem strategy” other than that which elements of the ecosystem (PI 2.5.3 100b scored as No), then how can you argue comprises the individuals strategies for the other here that there is no need for a plan? components of P1 and P2 . The lecture that the team made was that it should only take into consideration the effects of fishing on: target species, retained species, bycatch species, ETP species and habitat. Since the greatest risk to the ecosystem is the overexploitation of the target species, it is of utmost importance to ensure that the management measures in force does not pose a risk to the ecosystem. The team believes that the harvesting strategy in place guarantees the sustainability of the fishery and thus not posing in risk the ecosystem.

In the case of PI 2.5.3, the MSC guidelines specifically mention that the rationale must focus on the following aspects: a) Fisheries should be capable of adapting management to environmental changes as well managing the effect of the fishery on the ecosystem. b) Monitoring the effects of environmental change on the natural productivity of fisheries should be considered best practice and should include recognition of the increasing importance of climate change. In this PI it was introduced a different view, that is, the team must be taken into account if management takes into consideration environmental changes in particular climate changes. The team considered that both points are not meet because there is no monitoring of the effects of environmental changes on natural production Public Certification Report: of the fishery. In addition, the existing information does Razor Clam Fishery from Ria de Pontevedra not allow inferring about the potential impact of climate page 118 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012 change on the fishery.

2.5.2 Yes No NA I do not understand the comment in the We agree that the comment in the rationale about ‘100% rationale about ‘100% observer observer coverage’ can lead to misinterpretations. coverage’. To what does this refer? Indeed there are no independent observers’ onboard There are no independent observers on the boats. fishermen vessels. What it was meant is that all divers are controlled during fishing operations, every day and during the entire year by a water bailiff. It is worth noting that the fishery is carried in a limited area which is easily monitored and controlled by the water bailiff. The team assumed that this water bailif is idoneoues and therefore control is effective. The sentence was changed in order to avoid misunderstandings.

2.5.3 Yes Yes NA

3.1.1 Yes Yes NA

3.1.2 Yes Yes NA

3.1.3 Yes No NA 100a rationale states but does not explain Additional information was added to the rationale in how these goals are not applicable to this ordet to specify which are the particular features of the fishery. What characteristics? sword razor clam stocks that justifies that SG 100a was met..

3.1.4 Yes No necessarily NA A proportional score is awarded here but The team has scored 85 because it was decide d to give a since there are two issues it is not clear higher weight to the second part of the IC considering from the rationale why 85 has been that their failure can weaken the positive and explicit awarded and not 90. incentives of the fishery.

3.2.1 Yes Yes NA

3.2.2 Yes Yes NA

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3.2.3 Yes No Yes I strongly agree that the malpractice As it i s reported in SG 80d is currently taking place a described in 80d indicates systematic malpractice that no member of the fishery has hidden at non-compliance and must be stopped by any time. Indeed, during the several meetings that were the imposition of a condition. However, although this practice seems to be carried out during the fishery assessement, this officially condoned, it is clearly non- malpractice was reported by divers. This malpractice is compliance with the management system the result of an agreement by all divers and the Cofradia so 80c should not be scored as a ‘Yes’, and is "tolerated" by Fishing Administration. With this and neither should 80a. Unless closedly malpractice each diver may once per week sell one daily monitored this practice could also lead to catch quota outside the formal marketing channels with further abuse if a proportion of the catch one day was kept overnight to augment the purpose of generating a higher profit (without paying the unrecorded landing the following day. taxex) that covers the costs of the monitoring at sea and AT. . Is worth noting that the divers are willing to eliminate it by accepting the proposed condition in this MSC full assessment. No other malpractice (hidden or explicit) occurs. It is important to emphasize that the control and surveillance is effective and prevents any other malpractice.

The assessment team considered that the isolated nature and transparency of the abovementioned malpractice does not poses in question the monitoring and control tasks, ensuring the compliance of the management measures estipulated for the fishery.

3.2.4 Yes Yes NA

3.2.5 Yes Yes NA

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Any Other Comments

Comments Conformity Assessment Body Response Minor corrections: All suggestion s were accepted and the text was changed in conformity.

Page 11. Sentence about the water flow of the Lérez river is not clear. What does the average volume of 14.8m3 mean? Is this a flow rate per unit time or what?P 12 uses ‘razor clam’ and ‘sword razor clam’ for Ensis arcuatus interchangeably, which is confusing since there are two other species of razor clam present. P16 Length at metamorphosis cannot be 378.81 mm - presumably m P16 chlorophyll a – delete comma and italicize ‘a’ to prevent confusion P20 – In common English usage ‘inland waters’ means lakes, ponds and rivers – ‘inshore waters’ is what is required here.

For reports using the Risk-Based Framework:

Performance Does the report Are the RBF risk Justification: Conformity Assessment Body Response: Indicator clearly explain scores well- Please support your answers by referring to specific how the process referenced? scoring issues and any relevant documentation where used to Yes/No possible. Please attach additional pages if necessary. determine risk

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using the RBF led to the stated outcome? Yes/No 1.1.1 Yes Yes Razor clams in Spain and elsewhere have been fairly The referee is right. What it was meant was declared well researched and relevant scientific studies are not landed . The sentence was rewritten. referenced to provide the information used in the PSA analysis.

Table 8.1.2 possibly contains one inaccurate statement under ‘Fishing Activity –Provisioning’, where it states that ‘all individuals caught are landed in the fish auction’. This refers to my concerns expressed above in the General Comments that the practice of allowing the unrecorded landing of one daily quota per diver per week could result in a considerable underestimate of landings.

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Peer Reviewer 2

Has the assessment team arrived at an Yes Conformity Assessment Body appropriate conclusion based on the evidence Response presented in the assessment report? Justification:

The overall report is adequate and supports the final conclusion.

Do you think the condition(s) raised are Yes Conformity Assessment Body appropriately written to achieve the SG80 Response outcome within the specified timeframe? Justification:

There is only one condition raised. This condition raised against the single score < 80 in the assessment is appropriate and within the capability of the assessed fishery, and should achieve the SG80 outcome.

If included:

Do you think the client action plan is sufficient Yes/No Conformity Assessment Body to close the conditions raised? Response Justification:

The client’s proposed response to draft condition is realistic and appropriate.

Has the assessment team arrived at an Yes Conformity Assessment Body appropriate conclusion based on the evidence Response presented in the assessment report? Justification: The overall report is adequate and supports the final conclusion.

General Comments on the Assessment Report (optional) It is a well written report. The available information is presented clearly in the body of the report.

In the scoring tables however there are several PIs where not every single scoring issue is addressed as is required by MSC. In the scoring tables there are also several references to the body of the report which makes it sometimes difficult for the reader to see on what justification the team has drawn its conclusions.

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Performance Indicator Review

Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

1.1.1 See comments on RBF in the special paragraph below.

1.1.2 NA RBF used

1.1.3 NA

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Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

1.2.1 Yes No NA The rationale does not explain very clearly in The analysis of historical data on both CPUE which way the harvest strategy is responsive and structure of the catches allows to the state of the stock. managers to follow trends and to adopt

fishing effort to the status of the stock. Therefore, for instance, if CPUE decreases dramatically fishing effort is adjusted by reducting the daily quota per fishermen, by reducing the number of fishing days per year, or even to close the fishery in certain areas.

We believe that this information is already in the rationale of this PI namely in SG100d.

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Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

1.2.1 Yes No NA In the rationale for the first SG 100 issue (a) “In general, the precautionary approach in it is mentioned that the precautionary fisheries management is about being approach is adopted. The application of the cautious when scientific knowledge is precautionary approach is not part of the scoring issues here and in my opinion cannot uncertain, and not using the absence of form part of the rationale. adequate scientific information as a reason to postpone action or failure to take action to avoid serious harm to fish stocks or their ecosystem.” The team decided to adopt this approach (following FAO, DFO, etc. suggestion) whenever insufficient information was available namely to attribute the score 100 in several indicators.

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Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

1.2.2 No No NA The rational does not explain what harvest The team believes that the text that justifies control rule is used and why the team the score attributed to this PI is clear and considered the harvest control rules to be explains why it was considered that the well defined. A harvest control rule could be the reduction of fishing days when stock is harvest control rules are well defined. As it low or similar measures. was mentioned in PI 1.2.1 (Score 100d) “the harvesting strategy is periodically reviewed Same comment on the use of the and is improved as necessary”. Moreover in precautionary approach in scoring. PI 1.2.2 score 80b it is mentioned that “the exploitation strategy adopted each year can be changed as necessary by reducing the fishing effort both in terms of fishing days per month and area, and number of divers as well as by adjusting daily quotas”. Regarding the precautionary approach, please see answer to comment 1.2.1.

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Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

1.2.3 Yes ? NA The rationale states: “Various fishery data is We agree with the reviewer and the collected on a daily basis which allows us to abovementioned statement was rewritten: indirectly follow the evolution of the stock.” “Various fishery data (CPUE and size From this sentence it is not very clear which data about the stock size or structure are structure of the catches) is collected on a available and how these support the harvest daily basis which allows to indirectly follow strategy. The word ‘us’ should be avoided the evolution of the stock” here.

1.2.4 N/A RBF used

2.1.1 No Yes NA On page 12 of the report it is mentioned that The team agreed that the text on page 12 the divers may also harvest Ensis siliqua but could lead to misinterpretations and that this harvest is minimal. If this is the case therefore was changed. Ensis siliqua and Ensis siliqua should be considered as a retained species in this fishery. Solen marginatus are not caught since 2005, due to the low commercial value of the species. In this way and also bearing in mind the opinion of stakeholders, the team considered that no retained species exists in the fishery.

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Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

2.1.2 ? Yes NA See above. If Ensis siliqua is retained it See comment to PI 2.1.1 should be decided whether it is a main retained species (>5 %) or not. If it is a main retained species then a rationale that a (partial) strategy is in place should be given here.

2.1.3 ? Yes NA See comments on 2.1.1 and 2.1.2 above. If See comment to PI 2.1.1 other species are (sometimes) retained it is important to describe th epossibility to detect any increase of risk levels for these retained species.

2.2.1 Yes Yes NA Information on the discarding of the target Although we agree with the reviewer that species and its survival is not relevant here information on target species should not be since this is dealt with under P1. included in this PI, we decided to maintain this information just to emphasize that the fishery only impacts the target species.

2.2.2 Yes Yes NA

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Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

2.2.3 Yes No NA Rather than stating that there is no need for This statement was added to the rationale of information it should be stated that the this PI as suggested by the reviewer: “As available information clearly shows that there already mentioned the available information are no discarded species. clearly shows that there are no discarded species in this fishery and therefore there is no need to gather any type of information related to this issue”

2.3.1 Yes Yes NA

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Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

2.3.2 Yes No NA Since the rationale states that there is no We understand the point of view of the specific management strategy in place for reviewer. However, as mentioned in the the protection and conservation of ETP rationale of SC80b “ETP species for Galicia species it can not be concluded that there is a comprehensive management strategy for are identified and management plans are in ETP species. SG 100 a and b are therefore place to promote the recovery and not met and the score is too high. conservation of ETP species, of the species classified as ETP for Galicia, none of them seems to be affected by the razor clam fishery and therefore there is no need to implement a specific monitoring plan for this fishery”. In this context, the team really believes that the fishery has no impact, both directly or indirectly, on ETP species and thus there is no need to design a specific management strategy for ETP species. Therefore, the team still believes that SG100 a and b are met.

2.3.3 Yes Yes NA Reference to the precautionary principle Please see ans wer to comment 1.2.1. should be avoided since it is not part of the scoring issues.

2.4.1 Yes Yes NA

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Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

2.4.2 Yes Yes NA

2.4.3 Yes No NA Under SG80a it is only mentioned that fishing This in formation can be found in section grounds are mapped and characterized. 3.4.4 of this report. According to the scoring issue some reference to habitat types should be provided.

2.5.1 Yes Yes NA

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Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

2.5.2 Yes No NA It is conlcuded that an explicit strategy is not According to the MSC guidelines it is neccesary. This would imply that there is mentioned that for the evaluation of PI 2.5.2 only an implicit strategy in place. An implicit It may not be necessary to have a specific strategy would merely be a partial strategy and not a plan. SG100 a & b are therefore “ecosystem strategy” other than that which not met and the score is too high. comprises the individuals strategies for the other components of P1 and P2 . The lecture that the team made was that it should only take into consideration the effects of fishing on: target species, retained species, bycatch species, ETP species and habitat. Since the greatest risk to the ecosystem is the overexploitation of the target species, it is of utmost importance to ensure that the management measures in force does not pose a risk to the ecosystem. The team believes that the harvesting strategy in place guarantees the sustainability of the fishery and thus not posing in risk the ecosystem. Nevertheless we agree with the reviewer and we removed from the rationale the word “explicit” in order to avoid misinterpretations: “The team believed that a specific strategy for the management of Public Certification Report: ecosystem impacts of this fishery is not Razor Clam Fishery from Ria de Pontevedra really necessary, given that such impacts is page 133 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012 considered to be highly unlikely (Gaspar et al., 2011).”

Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

2.5.3 Yes N0 NA SG80 and SG100e. Although it is concluded We agre e with the reviewer and it was under PI 2.5.2 that a strategy is not decided to score SG100e as “No”, the final necessary this does not automatically lead to score of PI 2.5.3 was in this way reduced the conclusion that sufficient data continues to be collected. Some refrence to information from 90 to 85. or monitoring of the fishery would be needed to conclude that this issue is met.

3.1.1 Yes Yes NA The first sentence of SG100b is merely a We agree with the r eviewer . The rational copying of the scoring issue. It should be was modified in order to accommodate this placed as a final conclusion after the comment. information provided here. .

3.1.2 Yes No NA See 3.1.1 Same comment as 3.1.1. The We took into account the comment of the information in the referenced paragraphs reviewer and more information was added should also be provided in the table itself. to the rationale. Nevertheless, it is Some information on consultative processes should be provided in the table. important to note that during the MSC European CB Training held in London on the 3-4 of October, one of the main guidelines regarding the full assessment report was to not repeat information throughout the document.

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Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

3.1.3 Yes Yes NA In the SG100 rationale it is stated that the Additional comments have been added to long term objectives are not applicable to the specify which are the particular features of management plans of the fishery. This the sword razor calm stock that justifies that statement undermines the SG80 rationale and it is not realy clear what it exactly the SG100a was met.. means.

3.1.4 Yes Yes NA The first sentence of the SG80 rationale is We agree with the r eviewer . The rational e merely a copy of the scoring issue. It could was modified in order to accommodate this be the conclusion of the rationale but it comment. should not be the start of it.

The rationale could express more clearly that subsidies exist but that they do not result in perverse incentives (for instance) lead to overexploitation.

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Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

3.2.1 No No NA The SG100 rationale states that no explicit More information was added to explain the objectives are provided for the fisheries assessment team rationale. management system. This would imply that the SG 80 issue is not met. The SG 80 rationale states that long objectives are not implicit in the management system which would be strange since the management is aiming at the sustainable exploitation of the resources. As it is now the SG80 rationale does not really support a score of 80.

3.2.2 Yes No NA The rationale here merely is a copy of the We took into account t he comment of the scoring issue. The information on which the reviewer and more information was added team draws this conclusion should be to the rationale. Nevertheless, it is summarized in the scoring table. The rationale in the table should justify the important to note that during the MSC scoring and say which scoring issues are European CB Training held in London on the met. 3-4 of October, one of the main guidelines regarding the full assessment report was to not to repeat information throughout the document.

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Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

3.2.3 Yes No Yes The rationale at SG80a is merely a copy of We took into account the comment of the the SG80a scoring issue. Justification why reviewer and more information was added the issue is met should be provided in the to the rationale. Nevertheless, it is table. important to note that during the MSC European CB Training held in London on the 3-4 of October, one of the main guidelines regarding the full assessment report was to not to repeat information throughout the document.

3.2.4 ? No NA The SG100 rationale states that there is no We took into account the comment of the comprehensive research plan and that reviewer and more information was added research is fragmented. This would imply to the rationale. Nevertheless, it is that there is no reseach plan in place and the SG80 issue is not met. The SG80 issue important to note that during the MSC should provide justification that a specific European CB Training held in London on the research plan for the fishery under 3-4 of October, one of the main guidelines assessment exists, relevant to the scale and regarding the full assessment report was to intensity and the issues requiring research. not to repeat information throughout the (Certification requirements CB4.10.3). If this document. is not the case a condition should be formulated here.

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Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to specific scoring issues and any relevant documentation where information and/or rationale raised improve possible. Please attach additional pages if necessary. available been used to score this the fishery’s used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)

3.2.5 Yes No The SG100a rationale is merely a copy of the We agree with the r eviewer . The rational e SG100a scoring issue. Justification should was modified in order to accommodate this be provided why the team concludes that the comment. scoring issue is met.

Any Other Comments Comments Conformity Assessment Body Response All suggestions were accepted and the text was changed in conformity. Page 11. 3,447 km3. This figure seems to high. Page 12 Ensis silicua = Ensis siliqua

For reports using the Risk-Based Framework:

Performance Does the report Are the RBF risk Justification: Conformity Assessment Body Response: Indicator clearly explain scores well- Please support your answers by referring to specific how the process referenced? scoring issues and any relevant documentation where used to Yes/No possible. Please attach additional pages if necessary. determine risk using the RBF led to the stated outcome?

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Yes/No No No In the SICA a risk score of 5 (46-60 %) is attributed to In RBF we asked stakeholder to estimate the 1.1.1 the spatial scale of the activity. In the rationale it is proportion of the fishable area within Ria de stated that only 15-20% of the fishable area is exploited Pontevedra where Ensis arcuatus occurs that every year. Thus it is not clear how the score of 5 is reached. For Principle 1, the score should be potentially can be fished. Stakeholders informed us determined based on the percentage of the total that around 60% of the area may be potentially range of the stock that overlaps with all fishing activity exploited by divers. The reason given was that razor affecting the stock (Certification requirements clam divers, due to the harvesting technique used, CC2.3.2.1). can not reach the entire depth distribution range of the species. Indeed, divers can harvest razor clams up

to 10-12m depth and this species may occur until the bathymetric of 16m. Then we asked stakeholders to estimate the proportion of the fishable area that is effectively exploited by divers per year. According to them, only 15-20% of it is exploited every year. In the PSA the areal overlap is described by stating No other fisheries affect significantly Ensis arcuatus

that only 15-20% of the fishable area is exploited every stocks. year. It is not clear whether this overlap concerns the fishable area in Pontevedra or the whole distribution area of the target species stock. For P1 the combined geographical overlap of all fisheries impacting the stock should be considered (CC2.4.2.2.1).

The selectivity score of 1 seems appropiate. However it We accepted the suggestion of the reviewer and we

should be explained why the risk is low when over 95 added the following justification: % of the shells collected are over the minimum legal size. Eg that the razor shells scan spawn before they reach that size or that a large part of the shells present Susceptibility scores four attributes of the fishery in on the fishing area will not be picked by the divers. relation to the Ensis arcuatus population, notably areal overlap, vertical overlap, selectivity and post- release mortality. However, since the selectivity attribute is not defined by MSC for this particular gear type it was defined by the team. Based on this,

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the team proposed dividing the selectivity of hand harvesting into three categories taking into consideration the Minimum Landing Size (MLS). The MLS established for the species (100mm) allows E. arcuatus to spawn at least once before being captured. The post capture mortality of a retained species should We do not agree with this view. Indeed, evidence

be scored with a high susceptibility score (3) since post suggests that Post-capture mortality of discarded capture mortality of the target species will be 100 %. individuals is negligible – undersized sword razor (Table CC 16.) clams are discarded immediately and in situ by the diver.

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Appendix 3 Skateholders submissions

Appendix 3.1 Amendments made to the PCDR following stakeholder consultation

During the assessment stage regarding the Public review of the Draft assessment Report, a written submission was received by stakeholders. The information is the following :

Regarding the above skateholders submission the Team carried out the changes listed on the MSC Template for Skateholders Input . Regarding Figure 6 and 7, the Team request to Maria del Carmen Garcia Alonso from the CMRM the last catch datas (2011) for the Razor Clam so as to fulfil the current graphs.

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MSC Review on Compliance with the scheme requirements

Ref Type Page Requirement Reference Details Conformity assessment body response 3470 Major 50 CR-27.10.5.3 If all of the SG80 scoring issues are met, the PI must achieve at In PI 1.2.1 only one of the three As it was justified for the Peer Reviewers, the team least an 80 score and the team shall assess each of the scoring Scoring Issues is met. The score decided to assign higher weight to SG100d because issues at the SG100 level. a. If not all of the SG100 scoring does not follow the procedure the evaluation of the “Harvest strategy review” can issues are met the PI shall be given an intermediate score (85, outlined in CR 27.10.5.3 only be done in this SG 100d. On the contrary, the 90 or 95) reflecting overall performance against the different other two 100 issues were already scored under 60 SG100 scoring issues (should follow clauses i,ii, iii and iv) an 80 issues. 3470 Major 96 CR-27.10.6.1 Rationale shall be presented to support the team’s conclusion The rationale does not support The CAB after assessed the MSC coments, has the score for P.I 3.2.3 SG80c. decided to change the score SG80c in orther to avoid Rationale provided in SG80d “.. misinterpretations and support the need of the each diver may once per week Condition. sell one daily catch quota outside the formal marketing channels. In this way, the unaudited sale for that day provides them with some additional net income…” and "Divers, administration and the audit team have all identified the need to eradicate this malpractice. For this reason we have defined a Condition for this performance indicator” seems to contradict the rationale for SG80c 3473 Major 109 CRT-A2 The report shall include the unattributed reports of the Full Assessment Reporting We agree with the MSC Reviewers. The and peer reviewers in full using the ‘MSC peer review Template, Appendix 2, states that modifications were done. 122 template’ available on the MSC website forms and Peer Reviewers Reports has to be templates page presented unattributed. (http://www.msc.org/documents/schemedocuments/ forms-and-templates). CABs shall ensure that Public Certification Report: the ‘Contact Information’ table is removed. Razor Clam Fishery from Ria de Pontevedra page 142 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

3477 Major 37 CR-27.12.2.1 If the CAB determines the systems are sufficient, fish and fish The report does not specify from We agree with the reviewers. The information products from the fishery may enter into further certified which point chain of custody is regarding the scope of the fishery certificate was chains of custody and be eligible to carry the MSC ecolabel. needed. It does not detail that at added. See point 5.3. The CAB shall determine: The scope of the fishery certificate, the first change of ownership the including the parties and categories of parties eligible to use product will no longer be covered the certificate and the point (s) at which chain of custody is by the fishery certificate. needed. 3479 Major 57 CR-27.10.6.1 Rationale shall be presented to support the team’s Rationale does not support the There are no retained species in this fishery. Indeed, conclusion score in PI 2.1.2 SG100. apart from the target species no other species are Clarification is needed on how caught because no fishing gear is used since razor the harvest strategy may be clam are picked up by divers using theirs hands considered a strategy to limit solely. This is a highly selective fishery and thus the retained species. team considers that there is no need to implement a specific strategy for retained species.

The team believes that highly selective fisheries are not considered in the actual MSC guidelines and therefore some criterion are not suitable for these type of fisheries such as the one under assessment.

Notwithstanding, upon the considerations made by the MSC, it was added a sentence in section 3.4. explaining why it is believed that there is no need to design a specific strategy for retained species. 3480 Major 59 CR-27.10.6.1 Rationale shall be presented to support the team’s Rationale does not support the Please see Ref 3479 conclusion score in PI 2.1.3 SG100c. Information is not provided on the levels of retained species or on any harvest strategies. 3481 Major 63 CR-27.10.6.1 Rationale shall be presented to support the team’s Rationale does not support the There are no bycatch species in this fishery. Indeed, conclusion score in PI 2.2.2 SG100. apart from the target species no other species are Clarification is needed on how caught because no fishing gear is used since razor the harvest strategy may be clam are picked up by divers using theirs hands considered a strategy to limit solely. This is a highly selective fishery and thus the Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 143 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

bycatch. team considers that there is no need to implement a specific strategy for bycatch species.

The team believes that highly selective fisheries are not considered in the actual MSC guidelines and therefore some criterion are not suitable for these type of fisheries such as the one under assessment.

Notwithstanding, upon the considerations made by the MSC, it was added a sentence in section 3.4. explaining why it is believed that there is no need to design a specific strategy for bycatch.

3482 Major 65 CR-27.10.6.1 Rationale shall be presented to support the team’s Rationale does not support the Please see Ref 3481 conclusion score in PI 2.2.3 SG100c. Information is not provided on the levels of bycatch species or on any harvest strategies. 3485 Major 79 CR-27.10.6.1 Rationale shall be presented to support the team’s Rationale does not support the In this fishery no fishing gears are used and conclusion score in PI 2.5.2 SG100. therefore impact and/ or interaction on/with ETP Clarification is needed on how species are unlikely to occur. Thus there is no need the harvest strategy may be to implement a specific strategy for ETP species in considered a strategy to limit ETP this fishery. species. The team believes that highly selective fisheries are not considered in the actual MSC guidelines and therefore some criterion are not suitable for these type of fisheries such as the one under assessment. Notwithstanding, upon the considerations made by the MSC, it was added a sentence in section 3.4. explaining why it is believed that there is no need to design a specific strategy for ETP species. 3467 Guidance N/A CR-CF1.2 Fisheries assessment reports shall conform with the Sections REFERENCES and We agree with the Reviewers. The numbers of the template "MSC Full Assessment Reporting Template" APPENDICES should not be sections were eliminated. found at http://www.msc.org/documents/schemedocuments. numbered as chapters. Public Certification Report: Razor Clam Fishery from Ria de Pontevedra page 144 Date of issue: 20 th December 2012 © Marine Stewardship Council, 2012

3475 Guidance 6 CR-27.12.1.7 The CAB shall determine if the systems of tracking and The weaknesses identifies a risk There was a mistake regarding this issue, as it is tracing in the fishery are sufficient to make sure all fish of a breakdown in traceability describe in point 5.2.3. all the bags that contain the and fish products identified and sold as certified by the during transportation on land but razor clams are sealed with numbered flange, so the fishery originate from the certified fishery. The CAB shall this is not detailed in the product can not be replaced and therefore the risk consider the following points and their associated risk for the traceability section nor is how disappears. Accordingly this weakness has been integrity of cerified products. The robustness of the this risk is to be addressed. removed. management systems 3491 Major 106 CR- CC2.4.2.2.5 Scoring Post capture mortality (PCM).a. The team Post Capture Mortality has been Regarding Table CC16, expecifically Post Capture CC2.4.2.2.5 shall use their knowledge of species biology and fishing scored as ‘1’ (low-risk) indicating Mortality, the score 1 (low-risk) indicate: Evidence of practice together with Independent field observations to ‘Evidence of post capture release post-capture release and survival. The CAB assess: i. Biological factors that may limit the potential of a and survival’. MSC assumes that understands that apart from the target species no species to be captured alive. ii. Handling practices of the this interpretation would relate other species are caught because are picked up by fishery (ies) being considered. iii. The time taken to clear to the small proportion of the divers using theirs hands solely, thereby we have discards from the deck. iv. The probability that if a species is total catch which is returned e.g. scored with 1. captured it would be released in condition that would permit due to being under legal size, not The CAB do not agree with the MSC interpretation subsequent survival to the total catch. As the species concerning the high-risk score for Post Capture is a retained species, not a Mortality. This consideration assumed that the discarded bycatch species, the target species has to be considered as retained PCM should be considered as species when the reality is that represents the ‘high-risk’ and the score changed landing of the fishery. to a ‘3’ accordingly. As shown in Moreover the Team again believes that highly Table CC16, such scoring is selective fisheries are not considered in the actual applicable by default to cases of MSC guidelines and therefore some criterion are not ‘Retained species’, or where the suitable for these type of fisheries such as the one ‘majority are dead when under assessment. released’ (in the case of bycatch species)

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Appendix 3.2 Material of the site visits

Skateholders attendance during the site visits and RBF meetings

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Figure 14 List of those who attended the stakeholder’s meeting. Source ASI

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Figure 15. Action protocol in the RBF meeting (Galicia)

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Figure 16. Those who attended the RBF meetings

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Appendix 4 Surveillance frequency

The surveillance level has been determined following the MSC CR Requirements. The following criteria have been taken into consideration in order to calculate the surveillance score:

Surveillance Razor Cl am Criteria Score Fishery 1. Default Assessment tree used? Yes 0 X No 2 2. Number of conditions Zero conditions 0 Between 1 -5 conditions 1 X More than 5 2 3. Principle Level Scores >= 85 0 X <85 2 4. Conditions on outcome PIs? Yes 2 No 0 X TOTAL 1

The surveillance level ( score of 1) has been evaluated as remote, following option 2, and the first surveillance audit will be conducted on site in one year.

Score from Surveillance Year 1 Year 2 Year 3 Year 4 CR Table C3 Category

On -site On-site Off-site On-site surveillance Remote 1 surveillance surveillance surveillance audit & surveillance audit audit audit recertification site visit

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Appendix 5 Client agreement

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