Food Certification International Ltd Findhorn House Dochfour Business Centre Dochgarroch Inverness IV3 8GY United Kingdom
T: +44(0)1463 223 039 F: +44(0)1463 246 380 www.foodcertint.com
MSC SUSTAINABLE FISHERIES CERTIFICATION
Northern Ireland Pelagic Sustainability Group (NIPSG) Irish Sea Herring Fishery
Final Report
May 2014
Prepared For: Northern Ireland Pelagic Sustainability Group (NIPSG) Prepared By: Food Certification International Ltd
Food Certification International Final Report Northern Ireland Pelagic Sustainability Group (NIPSG) Irish Sea Herring Fishery
Final Report
June 2014
Authors: T. Southall, P. Medley, C. Leiper & N. Pfeiffer
Certification Body: Client: Food Certification International Ltd Northern Ireland Pelagic Sustainability Group (NIPSG)
Address: Address: Findhorn House The Harbour, Dochfour Business Centre Kilkeel, Dochgarroch Co. Down, Inverness IV3 8GY Northern Ireland Scotland, UK BT34 4AX
Name: Fisheries Department Name: Alan McCulla OBE Tel: +44(0) 1463 223 039 Tel: +44 (0)28 4176 2855 Email: [email protected] Email: [email protected] Web: www.foodcertint.com
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Contents
Glossary ...... iv 1. Executive Summary ...... 1 2. Authorship and Peer Reviewers ...... 4 2.1 Assessment Team ...... 4 2.1.1 Peer Reviewers ...... 5 2.1.2 RBF Training ...... 6 3. Description of the Fishery ...... 7 3.1 Unit(s) of Certification and scope of certification sought ...... 7 3.1.1 Scope of Assessment in Relation to Introduced Species Based Fisheries (ISBF) ...... 7 3.1.2 Scope of Assessment in Relation to Enhanced Fisheries ...... 7 3.2 Overview of the fishery ...... 8 3.2.1 Northern Ireland Pelagic Sustainability Group (NIPSG) ...... 8 3.3 Principle One: Target Species Background ...... 23 3.3.1 Stock Definition ...... 23 3.3.2 Inseparable or Practicably Inseparable (IPI) Stocks ...... 26 3.3.3 Stock Status and Reference Points ...... 27 3.3.4 Key Trophic Level Reference Point (PI 1.1.2d)...... 28 3.3.5 Harvest Strategy and HCR ...... 30 3.3.6 Data and Stock Assessment ...... 30 3.4 Principle Two: Ecosystem Background ...... 34 3.4.1 Retained catch ...... 34 3.4.2 Bycatch species ...... 35 3.4.3 Endangered, Threatened and Protected species interactions (ETP) ...... 36 3.4.4 Habitat impacts ...... 38 3.4.5 Ecosystem impacts ...... 40 3.5 Principle Three: Management System Background...... 41 3.5.1 Description of the Management System...... 41 3.5.2 Isle of Man ...... 42 3.5.3 Decision-making Processes ...... 42 3.5.4 Fisheries Specific Management ...... 43 4. Evaluation Procedure ...... 44 4.1 Harmonised Fishery Assessment ...... 44 4.1.1 Harmonisation Details ...... 44 4.2 Previous assessments ...... 44 4.3 Assessment Methodologies ...... 44 4.3.1 Assessment Tree ...... 44 4.4 Evaluation Processes and Techniques ...... 44 4.4.1 Site Visits...... 44
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4.4.2 Consultations ...... 46 4.4.3 Evaluation Techniques ...... 49 4.4.4 RBF Use ...... 50 5. Traceability ...... 52 5.1 Eligibility Date ...... 52 5.2 Traceability within the Fishery ...... 52 5.2.1 Description of Tracking, Tracing and Segregation Systems within the Fishery and Management systems in place relating to Traceability ...... 52 5.2.2 Evaluation of Risk of Vessels Fishing Outside of UoC ...... 52 5.2.3 Risk of Substitution of Mixing Certified / Non-Certified Catch prior to point of landing ...... 53 5.2.4 At-Sea Processing ...... 53 5.2.5 Trans-Shipment ...... 53 5.2.6 Robustness of management systems relating to traceability ...... 53 5.3 Eligibility to Enter Further Chains of Custody ...... 53 5.3.1 Eligible points of landing ...... 54 5.3.2 Parties eligible to use the fishery certificate ...... 54 5.4 Eligibility of Inseparable or Practically Inseparable (IPI) stock(s) to Enter Further Chains of Custody ...... 54 6. Evaluation Results ...... 55 6.1 Principle Level Scores ...... 55 6.2 Summary of Scores ...... 55 6.3 Summary of Conditions ...... 56 6.3.1 Recommendations ...... 56 6.4 Determination, Formal Conclusion and Agreement ...... 57 7. References ...... 58 Appendix 1. Scoring & Rationale ...... 60 Appendix 1a – MSC Principles & Criteria ...... 60 Appendix 1.1 Performance Indicator Scores and Rationale ...... 63 Appendix 1.3 Conditions ...... 146 Condition 1 ...... 146 Condition 2 ...... 146 Condition 3 ...... 147 Condition 4 ...... 148 Appendix 2. Peer Review Reports ...... 149 Peer Reviewer 1 ...... 149 Peer Reviewer 2 ...... 170 Appendix 3. Stakeholder submissions ...... 188 Appendix 3.1 Amendments made to the PCDR following stakeholder consultation ...... 192
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Glossary
AFBI Agri-Food and Biosciences Institute Northern Ireland
ASCOBANS (Bonn Convention’s) Agreement on the Conservation of Small Cetaceans in the Atlanto-Scandian and Baltic.
ACOM ICES Advisory Committee
ACFA ICES Advisory Committee on Fisheries and Aquaculture
ANIFPO Anglo North Irish Fish Producers' Organisation
Bpa Precautionary reference point for spawning stock biomass
Blim Limit biomass reference point, below which recruitment is expected to be impaired.
CFCA EU Community Fisheries Control Agency
CFP EU Common Fisheries Policy
CR Council Regulation
DARD Department of Agriculture and Rural Development Northern Ireland
EC European Commission
EFF European Fisheries Fund
ETP Endangered, threatened and protected species
EU European Union
F Fishing Mortality
Flim Limit reference point for fishing mortality that is expected to drive the stock to the biomass limit
FMSY Fishing mortality achieving maximum sustainable yield
Fpa Precautionary reference point of fishing mortality expected to maintain the SSB at the precautionary reference point
FAM MSC’s Fisheries Assessment Methodology
FAO United Nations Food and Agriculture Organisation
HAWG ICES Herring Assessment Working Group
HCR Harvest Control Rule
ICES International Council for the Exploration of the Sea
ITQ Individual Transferable Quota
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IUU Illegal, unreported and unregulated fishing
MCS Monitoring, Control and Surveillance
MSC Marine Stewardship Council
MSY Maximum Sustainable Yield
NEA North East Atlantic
NGO Non-Governmental Organisation
NIFPO Northern Ireland Fish Producers Organisation
NIPSG Northern Ireland Pelagic Sustainability Group
OSPAR Oslo-Paris Convention (Convention for the Protection of the Marine Environment of the North-East Atlantic)
P1 MSC Principle 1
P2 MSC Principle 2
P3 MSC Principle 3
PI MSC Performance Indicator
PO Producer Organisation
RAC Regional Advisory Council
RSW Refrigerated Sea Water
SAWG ICES Stock Assessment Working Group
SI Scoring Issue (MSC)
SONAR Sound navigation and ranging
SSB Spawning Stock Biomass
STECF Scientific, Technical and Economic Committee for Fisheries
TAC Total Allowable Catch
UK United Kingdom
UoC Unit of Certification
UNCLOS United Nations Convention on the Law of the Sea
VMS Vessel Monitoring System
WWF World Wide Fund For Nature
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WGECO ICES Working Group on the ecosystem effects of Fishing Activities
WGRED ICES Working Group on Ecosystem Description
WGWIDE ICES Working Group on Widely Distributed Stocks
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1. Executive Summary » This report provides details of the MSC assessment process for the Northern Ireland Pelagic Sustainability Group (NIPSG) Irish Sea Herring Fishery for Irish Sea herring. The assessment process began in April 2013 and was concluded (to be determined at a later date). » A comprehensive programme of stakeholder consultations were carried out as part of this assessment, complemented by a full and thorough review of relevant literature and data sources. » A rigorous assessment of the wide ranging MSC Principles and Criteria was undertaken by the assessment team and a detailed and fully referenced scoring rationale is provided in the assessment tree provided in Appendix 1.1 of this report. » The Target Eligibility Date for this assessment is 1st November 2013
The assessment team for this fishery assessment comprised of Nick Pfeiffer who acted as team leader and primary Principle 2 specialist; Paul Medley who was primarily responsible for evaluation of Principle 1 and Tristan Southall who was primarily responsible for evaluation of Principle 3 Client strengths » The Irish Sea herring stock is well managed with a precautionary long term management plan under development, which proposes to use appropriate reference points to manage the exploitation rate in the fishery against clear objectives. » The conclusions in relation to stock status are drawn from a sound information base which is used to carry out a robust and regular stock assessment. » Pelagic fisheries for herring do not make contact with the seabed – thus reducing any likelihood of negative impact on seabed habitats. » Given the dense aggregations of herring that occur at the time of fishery and the technologically advanced fish finding equipment, vessels are able to confidently fish with little or no bycatch. » The vessels included in this assessment do not have any on board sorting equipment so highgrading and discarding is not possible – unless the haul is ‘slipped’ (i.e. the cod end untied before the fish are pumped aboard). Slippage could be triggered by a catch of undersize fish or by the wrong species mix. The report describes a rationale why slippage is thought to be negligible – a conclusion supported by expert consultation, including evidence from observer coverage. » In the past there has been a good level of observer coverage seeking to quantify the level of interaction with endangered, threatened or protected species. This has shown a negligible level of impact, therefore the fishery is now considered low risk. » The fisheries management process and infrastructure are appropriate to the fishery and are able to govern the level of fisheries exploitation in an informed and transparent manner, employing clearly defined decision-making process, which take account of the precautionary principle. » There is an appropriate level of enforcement and control in this fishery, and a high level of confidence on the part of the authorities in the degree of compliance of the fleet with the fisheries regulations. » The fishery management is supported by a well-resourced and strong scientific capacity which helps to enable management to make informed decisions. 1 version 2.0(01/06/13)
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Client weaknesses » Overall, relatively few weaknesses have been identified in the fishery assessment and scores are generally reasonably high. Weaknesses relate to Principle 1 where the certification has been made with two conditions included as part of the certification. Main P1 weaknesses relate to the lack of a long term management plan that has been implemented for the stock, although this is presently under development, along with an appropriate reference points and a HCR. » Additional weaknesses were identified in Principle 3 and a number of conditions are included in the certification in relation to these. Main weaknesses relate to a lack of clear fishery specific objectives that are designed to achieve the outcomes expressed by MSC’s Principles 1 and 2. The fishery management system would also benefit from greater and more effective and timely review. » Under Principle 2, the fishery scored adequately under all performance indicators, however scores would have been higher had it been demonstrated to the assessment that the fishery engaged in voluntary reporting in relation to slippage and encounters with endangered, threatened and protected species even though this may be an exceptionally rare occurrence). Determination On completion of the assessment and scoring process, the assessment team concluded that the NIPSG Irish Sea Herring Pelagic Trawl fishery should be certified according to the Marine Stewardship Council Principles and Criteria for Sustainable Fisheries. Rationale » There are a number of areas which reflect positively on the fishery: › The herring stock has recovered and is at the highest SSB since the early 1970’s › The fishery is operated by a small number of modern technologically advanced vessels that use electronics to aid in shoal location and tracking › There is very little interaction with other ecosystem components › The fishery is spatially and temporally constrained and is therefore easier to manage › There is an effective management regime in place that covers the operation of the fleet under assessment and that aims to introduce a long term management plan for the stock in the near future › There is a record of high compliance with fishing rules by the NIPSG fleet and catches have remained within advice in recent years Conditions & Recommendations » However, a number of criteria which contribute to the overall assessment score scored less than the unconditional pass mark, and therefore trigger a binding condition to be placed on the fishery, which must be addressed in a specified timeframe (within the 5 year lifespan of the certificate). Full explanation of these conditions is provided in Section 1.3 of the report, but in brief, the areas covered by these conditions are: › PI 1.1.2 Limit and target reference points appropriateness for the stock › PI 1.2.2 There are well defined and effective harvest control rule in place
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› PI 3.2.1 Clear, specific objectives designed to achieve the outcomes expressed by MSC’s Principles 1 and 2 › PI 3.2.5 Effective and timely review of the fishery-specific management system » In addition, the assessment team made one recommendation in relation to supporting the inclusion of ecosystem considerations in the definition of Reference Points for the management of NSAS herring. As recommendations are not the result of a failure to meet the unconditional pass mark, they are non-binding; however in the opinion of the assessment team, they would make a positive contribution to on-going efforts to ensure the long term sustainability of the fishery. Details of these recommendations are provided in Section 6.3.1 of this report. For interested readers, the report also provides background to the target species and fishery covered by the assessment, the wider impacts of the fishery and the management regime, supported by full details of the assessment team, a full list of references used and details of the stakeholder consultation process. FCI Ltd confirm that this fishery is within scope.
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2. Authorship and Peer Reviewers
2.1 Assessment Team All team members listed below have completed all requisite training and signed all relevant forms for assessment team membership on this fishery.
Assessment team leader: Nick Pfeiffer Primarily responsible for assessment under Principle 2 Nick Pfeiffer is a fisheries and marine environmental specialist with a diverse experience and in-depth knowledge of marine fisheries. Nick’s experience as a fishery scientist spans 15 years and includes the development of fisheries technical conservation measures for commercial fisheries as well as the evaluation of the impacts of a variety of fishing methods on marine ecosystems. Nick is based in the west of Ireland where he is a founding director of the environmental and ecological services company MERC Consultants. As a marine ecologist and aquatic resource specialist with a particular interest in interactions between nature and both aquaculture and capture fisheries Nick provides a range of aquatic environmental and ecological services mainly in support of aquatic nature conservation, fisheries and aquaculture and marine renewable energy. Nick heads up aquaculture and capture fisheries related aspects of MERC’s work while also contributing to other projects such as aquatic habitat mapping, benthic faunal studies and survey work in connection with appropriate assessments for fisheries and aquaculture in Natura 2000 sites. Nick’s academic background includes undergraduate studies in aquaculture and marine science at the University of Plymouth, while he also conducted postgraduate research in fisheries at the University of Georgia and at University College Galway. He was employed as a fisheries scientist with the Irish government from 1992 to 1995. Between 1995 and 1997 Nick was manager of the Marine Fisheries Environment Unit at University College Galway.
Expert team member: Paul Medley Primarily responsible for assessment under Principle 1 Dr Paul Medley is an experienced fishery scientist and population analyst and modeler, with wide knowledge and experience in the assessment of pelagic stocks (amongst a range of marine fish stocks and ecosystems). He holds a first degree in Biology and Computer Science (1st class honours) from the University of York, and a doctorate from Imperial College, London, based on a thesis “Interaction between Longline and Purse Seine in the South-West Pacific Tuna Fishery”. He has travelled widely and worked with a range of fishery systems and biological stocks, both as principal researcher and as evaluator. He is familiar with MSC assessment procedures, having participated in a significant number of MSC full assessments across a range of fisheries, undertaken a substantial number of pre-assessments and acted as peer reviewer in still others. He is familiar with a wide range of fisheries in the North East Atlantic and other parts of the world, and over the period 2000 to 2005 he has been serving with the Centre for Independent Experts, University of Miami, as an evaluator of various US fishery research programmes. He has been working with the MSC on the development of guidelines for certification of small scale, data poor fisheries. He is based in York (UK).
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Expert team member: Tristan Southall Primarily responsible for assessment under Principle 3 Tristan Southall is an experienced fisheries assessor who has worked as both principles 2 and 3 expert on a number of previous MSC assessments, including the Scottish Pelagic assessments for both herring and mackerel. More recently Tristan led the IPSG Mackerel Assessment and has also been involved in the development and trialing of a new MSC assessment methodology, based on risk analysis, for use in data deficient situations. When not assessing the sustainability of fisheries Tristan specialises in fishing and marine industry consultancy, combining detailed understanding of marine ecosystems with broad experience of fishing and aquaculture industry systems, infrastructure and management. This provides him with an informed position which balances the needs of marine ecosystems, biodiversity and wider environment with the practicalities of the industry operation. Bridging these two important areas enables sustainably-minded consultancy, able to interpret and advise upon the impacts of different management decisions on both marine ecosystems and economics. Tristan’s professional experience also includes the evaluation of fisheries on sub-sea environments, analysis of fishery and fleet performance, and a wide range of fisheries and aquaculture planning and management studies, all of which seek to combine both socio- economic and environmental perspectives. Tristan has recently coordinated EU fisheries training and promotion activities – covering all aspects of sustainable fisheries management and control.
2.1.1 Peer Reviewers Peer reviewers used for this report were Dr Massimiliano Cardinale and Dr Mike Pawson. A summary CV for each is available in the Assessment downloads section of the fishery’s entry on the MSC website. Justification for choosing the proposed Peer Reviewers a) Specific areas of expertise relevant to this fishery b) Why they will be in a position to provide expert reviews to ensure the scores and rationales given by the assessment team have taken account of all the available information and can be scientifically justified. Michael Pawson a) 43 years’ experience as a fisheries scientist in biological, fish stock assessment and fisheries management and regulation; extensive knowledge on pelagic and demersal stocks, including herring; b) Member of various ICES stock assessment groups and EC-STECF on fisheries regulation measures as well as for several stock recovery plans; extensive experience as MSC assessor – primarily P1- thus familiar with the MSC methodology and ethos; peer reviewer of research papers, project applications and MSC assessments. Massimiliano Cardinale a) In depth knowledge on fisheries population dynamics and stock assessments, including pelagic and demersal species,; b) Currently research in stock assessment, statistical analysis and modelling of fisheries data; discarding studies in fisheries; was member on ICES herring
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assessment working group (HAWG) – as well as other ICES working groups, and several working groups at EC-STECF; experience as MSC assessor, thus familiar with MSC methodology and ethos.
2.1.2 RBF Training Nick Pfeiffer and Tristan Southall have been fully trained in the use of the MSC’s Risk Based Framework (RBF).
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3. Description of the Fishery
3.1 Unit(s) of Certification and scope of certification sought Food Certification International Ltd confirm that the fishery is within scope of the MSC certification sought for the assessment as defined. Prior to providing a description of the fishery it is important to be clear about the precise extent of potential certification. The MSC Guidelines to Certifiers specify that the unit of certification is “The fishery or fish stock (biologically distinct unit) combined with the fishing method / gear and practice (= vessel(s) and / or individuals pursuing the fish of that stock)”. This clear definition is useful for both clients and assessors to categorically state what was included in the assessment, and what was not. This is also crucial for any repeat assessment visits, or if any additional vessels are wishing to join the certificate at a later date. The unit of certification for the fishery under consideration is as set out below. The fishery assessed for MSC certification is defined as:
Species: Atlantic herring (Clupea harengus)
Stock: Herring in division VIIa North of 52˚30’N
Geographical area: ICES Areas VIIa (Irish Sea) within EU waters
Harvest method: Pelagic trawl
Client Group: Northern Ireland Pelagic Sustainability Group (NIPSG) targeting herring in ICES Areas VIIa (Irish Sea) using pelagic trawl.
Other Eligible Fishers: None
Please note that whilst the Unit of Certification details the full extent of what is being assessed, it is the full and complete Public Certification Report that precisely defines the exact nature of certification for this fishery. This Unit of Certification was used as it is compliant with client wishes for assessment coverage and in full conformity with MSC criteria for setting the Unit of Certification.
3.1.1 Scope of Assessment in Relation to Introduced Species Based Fisheries (ISBF) Herring are native to the north Atlantic and the fishery is not an introduced species based fishery.
3.1.2 Scope of Assessment in Relation to Enhanced Fisheries No stock or habitat enhancement activities take place in the fishery.
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3.2 Overview of the fishery
3.2.1 Northern Ireland Pelagic Sustainability Group (NIPSG) Fishery Ownership and Organisational structure Entitlement to quota for Irish Sea herring is shared between the UK (including Northern Ireland) and Ireland. While other nations have been involved in exploitation of the stock in the past, under the terms of the Common Fisheries Policy, entitlement to the resource is now shared by these two nations. Figure 3.2.1 shows the breakdown of quota by country for 2012.
Figure 3.2.1 Allocations of quota for herring in VIIa North of 52º30’N (2012)
Source: Marine Institute Stock Book 2012
The client for this pre-assessment is the Northern Ireland Pelagic Sustainability Group. NIPSG represents a consortium comprising pelagic fishing interests of both the Anglo North Irish Fish Producers Organisation and the Northern Ireland Fish Producers Organisation. The Anglo-North Irish Fish Producers Organisation (ANIFPO) was founded in 1984 as a non- profit making co-operative and has its headquarters located alongside the harbour in Kilkeel, Co. Down. ANIFPO provide a range of services to Northern Ireland fishermen, especially focused on the area of quota management and representation but increasingly also in relation to marketing. ANIFPO member vessels are based in Annalong, Ardglass, Kilkeel and Portavogie, the main fishing harbours along the County Down coast in Northern Ireland. Member’s vessels range in size from over 70 metres to under 10 metres in length and actively fish in waters all around the UK and Ireland, using a variety of fishing methods such as trawling and crab/lobster potting, to target a wide range of species. The most important catch for the majority of ANIFPO member vessels is Nephrops or Dublin Bay Prawns, which are landed on a daily basis into local ports. ANIFPO is committed to promoting sustainable fishing methods and is involved in a variety of projects including the Sea Fish Industry Authority’s Responsible Fishing Scheme.
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ANIFPO is managed by a Board consisting of eight Directors, who are elected on an annual basis by the membership of the PO. The Board is headed by a Chairman who serves a two year term. The Board meets on a regular basis and is charged with making all policy and management decisions relating to both the day-to-day operations of the PO and the Organisation’s Fish Sales Division. ANIFPO is a constituent organisation within the UK’s National Federation of Fishermen’s Organisations (NFFO) and holds two seats on the NFFO’s Executive Committee. Through the NFFO, ANIFPO is involved in a range of national and European forums. Mr Alan McCulla is Chief Executive Officer with responsibility for overseeing and implementing the decisions of the ANIFPO board as well as for representing ANIFPO member’s interests at National and European level through the European parliament. Further details about ANIFPO are available at http://www.anifpo.com/. The Northern Ireland Fish Producers' Organisation Limited was formed in 1977. NIFPO is Northern Irelands second largest fish producers organisation. It currently has 120 members all of whom are active fishing vessel owners. Member vessels range in size from 60 metre purse seiners to under 10 metre vessels. The majority of the membership is based in County Down in Bangor, Portavogie, Ardglass and Kilkeel but individual members are also based in Cumbria, Scotland, Isle of Man and on the English East coast. Mr. Dick James is the Secretary/Chief Executive to the Organisation having been involved for some 40 years in fisheries. Mr James actively represents his member’s interests in many committees and groups at EU, UK national and regional levels. In its role, NIFPO actively represents its members at national and European level and participates in fisheries management processes and initiatives that are of relevance to its members History of the Fishery There is a long history of exploitation of Irish Sea herring going back to the middle ages at least. An account of the fisheries over the centuries can be found at http://www.isle-of- man.com/manxnotebook/fulltext/ws1923/p001.htm. ICES (HAWG, 2009) provides a description of the fisheries in more recent times. Over the past 50 years, three distinct fisheries that target Irish Sea herring have operated:
1. Isle of Man fishery – an autumn fishery targeting adult fish that spawn around the Isle of Man. 2. Mourne fishery – a winter fishery targeting adult fish that spawn off the Northern Irish eastern coast. 3. Mornington fishery - a mixed industrial fishery that caught juveniles in the western Irish Sea. The main herring fishery in the Irish Sea has been on the fish that spawn in the vicinity of the Isle of Man. The fish are caught as they enter the North Channel, down the Scottish coast, and around the Isle of Man. Traditionally this fishery supplied the Manx Kipper Industry, which requires fish in June and July. However the fish appeared to spawn slightly later in the year in the 1990s and this lead to problems of supply for the Manx Kipper Industry. In 1998 the Kipper companies decided to buy in fish from other areas. Generally the fishery has occurred from June to November, but is highly dependent on the migratory behaviour of the herring. In the 1970s the catch of fish from the Mourne fishery made up over a third of the total Irish Sea catch. The fishery was carried out by UK and Republic of Ireland vessels using trawls, seines and drift nets in the autumn. However the fishery declined dramatically and ceased in the early 1990s (ICES, 1994). The biomass of Mourne herring, determined from larval production estimates is estimated to be 2-4% of the total Irish Sea stock (Dickey-Collas et al.,
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2001).In recent years a small fishery has operated off the Mourne coast that targets herring adult fish using drift nets. The fishery is very limited in scale and catches have been curtailed at around 30 tonnes. The Mornington fishery started in 1969 and at its peak it caught 10,000 tonnes per year. It took place throughout the year. The fishery was closed due to management concerns in 1978 (ICES, 1994). The fishery in area VIIa (N) has not changed in recent years. A pair of UK pair trawlers takes the majority of catches during the 3rd and 4th quarters, but since 2011 a single pelagic trawler take some of the TAC. A small local fishery continues to record landings on the traditional Mourne herring grounds during the 4th quarter. This fishery resumed in 2006 and has seen increasing catches of herring since, peaking at ~171 t in 2009. The fishery has been restricted by the TAC since. Area Under Evaluation The NIPSG Irish Sea herring fishery takes place entirely in ICES Subarea VIIa North of 52º30’N, within the North East Atlantic FAO Area 27 NE Atlantic within ICES area VIIa. The fishery may take place within the UK and Irish waters as well in within the territorial sea of the Isle of Man.
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Figure 3.2.2 ICES subareas NE Atlantic
Source: ICES Species type/s The target species for the fishery under certification is Atlantic herring Clupea harengus. It is one of the most abundant fish species in the world. Atlantic herrings can be found on both sides of the Atlantic Ocean, congregating in large schools.
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They can grow up to 45 centimetres in length and weigh more than 0.5 kilograms. Herring feed on copepods, krill and small fish, while their natural predators are seals, whales, cod and other larger fish. Atlantic herring (Clupea harengus) is a pelagic species, with stocks widely distributed throughout the north-east Atlantic, ranging from the Arctic Ocean in the north to the English Channel in the south. Young herring are typically found close inshore, in estuaries or in sea lochs, whilst adult shoals generally occur further offshore. Herring often travel large distances between spawning, nursery and feeding grounds. During daytime, herring shoals remain close to the sea bottom or in deeper water s – though this is not so in all cases. At dusk they move toward the surface and disperse over a wide area. The herring is a very tender and fragile fish with large and delicate gill surfaces and scales. It has a low level of pollution tolerance and it has retreated from many heavily impacted estuaries worldwide. It is this characteristic that enables herring to serve as a bio-indicator of cleaner and more oxygenated waters. Herring are demersal spawners. Shoals of herring gather on the spawning grounds and spawn more or less simultaneously - releasing eggs in a single batch. Eggs are laid on the sea bed, on stones, gravel or sand beds. A female herring may deposit from 20,000 up to 120,000 eggs, depending on age and size. The eggs sink to the bottom, where a mucous coat enables them to form layers or clumps. Incubation time varies between 10 to 40 days depending on temperature. Herring larvae are between 5 and 6mm at the time of hatching, and early nutrition is provided by a small yolk sac. Only the eyes are well pigmented and the rest of the body is semi- transparent - virtually invisible underwater. The newly hatched larvae drift with oceanic currents. By the age of one-year, herring have a typical length of 10cm, and first spawning occurs at 3 years old. Adult herring have been reported as old as 20 years, but this is very uncommon. Clupea harengus play an important role in temperate and cold water food chains, consuming zooplankton (copepods, larval snails, diatoms, mysids, euphausiids etc.) and juvenile sandeels. There are no marked differences between the diets of small and large herring; only the proportions of the different food items change with size. Young herring typically capture prey individually, but where prey concentrations reach very high levels, such as micro-layers that occur at fronts, herring are able to filter feed are able to “filter feed” when prey reach high concentrations. The main fish predators on herring in the Irish Sea include whiting (Merlangius merlangus), hake (Merluccius merluccius) and spurdog (Squalus acanthias), whereas cod (Gadus morhua) appears to be a minor predator of herring. The size composition of herring in the stomach contents indicates that predation by whiting is mainly on 0-ring and 1-ring herring whilst adult hake and spurdogfish also eat older herring. Small clupeids are an important source of food for piscivorous seabirds including gannets, guillemots and razorbills, which nest at several locations in and around the Irish Sea. Marine mammal predators include grey and harbour seals, and possibly pilot whales, which occur seasonally in areas where herring aggregate. Whilst small juvenile herring occur throughout the coastal waters of the western and eastern Irish Sea, their distribution overlaps extensively with sprats (Sprattus sprattus). The biomass of small herring has typically been less than 5% of the combined biomass of small clupeids estimated by acoustics. In the north east Atlantic, herring can be divided into several different stocks. Different stocks tend to mix together for most of the year but during the spawning season they migrate to their separate spawning areas. The most important stocks are the winter-spawning Norwegian and Icelandic herrings and the autumn spawning Icelandic, North Sea and Baltic Sea herrings. Herring stocks can be further categorised by their different spawning areas and times. The Irish Sea herring is considered as a separate stock and is also an autumn spawner. Greater detail in relation to herring stocks in the Irish Sea is provided by ICES in the 2009 report of the Herring Assessment Working Group (see below). 12 version 2.0(01/06/13)
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Some different stocks are known to mix together for parts of the year but during the spawning season they migrate to their separate spawning areas. The Irish Sea herring is known to mix with the Celtic Sea herring stock and stock identity is complex as the juveniles mix with those from the Celtic Sea and the adults migrate from the Irish Sea after spawning. The exact degree of mixing is uncertain but is believed to be significant.
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IRISH SEA HERRING STOCKS Herring spawning grounds in the Irish Sea are found in coastal waters to the west and north of the Isle of Man and on the Irish Coast at around 54˚N (ICES, 1994; Dickey-Collas et al., 2001). Spawning takes place from September to November in both areas, occurring slightly later on average on the Irish Coast than off the Isle of Man. ICES Herring Assessment Working Groups having used vertebral counts to separate catches into Manx and Mourne stocks associated with these spawning grounds. However, taking account of inaccuracies in this method and the results of biochemical analyses, the 1984 WG combined the data from the two components to provide a “more meaningful and accurate estimate of the total stock bio-mass in the N. Irish Sea.” All subsequent assessments have treated the VIIa(N) data as coming from a single stock. During the 1970s, catches from the Manx component were about three times larger than those from the Mourne component. By the early 1980s, following the collapse of the stock, the catches were of similar magnitude. The fishery off the Mourne coast declined substantially in the 1990s then ceased, whilst acoustic and larva surveys in this period indicate that the spawning population in this area has been very small compared to the biomass off the Isle of Man. The occurrence in the Irish Sea of juvenile herring from a winter-spring spawning stock has been recognized since the 1960s based on vertebral counts (ICES, 1994). Nursery grounds in the western Irish Sea were generally dominated by winter-spawned fish whereas samples from the eastern Irish Sea were mainly autumn-spawned fish. Recaptures from 10 000 herring tagged off the SW of the Isle of Man in July 1991 occurred both on the Manx spawning grounds and along the Irish Coast with increasing proportions from the Celtic Sea in subsequent years (Molloy et al., 1993). The pattern of recaptures indicated a movement towards spawning grounds in the Celtic Sea as the fish matured. A proportion of the Irish Sea herring stocks may occur to the north of the Irish Sea outside of the spawning period. This was indicated by the recapture on the Manx spawning grounds of 3-6 ring herring tagged during summer in the Firth of Clyde (Morrison and Bruce, 1981). Aggregations of post-spawning adult herring were detected along the west coast of England during an acoustic survey in December 1996 (Department of Agriculture and Rural Development for Northern Ireland, unpublished data), showing that a component of the stock may remain within the Irish Sea. The results of WESTHER, a recent EU-funded programme aiming to elucidate stock structures of herring throughout the western seaboard of the British Isles have recently been published. Using a combination of morphometric measurements, otolith structure, genetics and parasite loads the conductivity of stocks within and beyond the Irish Sea have been examined. The results of this programme and existing knowledge have been evaluated by SGHERWAY and contributed significantly to the understanding of herring stock structure in western waters.. Source: Annex 8 - Stock Annex Irish Sea Herring VIIa (N) ICES HAWG REPORT 2009 ICES ADVISORY COMMITTEE ICES CM 2009/ACOM:03)
As indicated initially, this report does not intend to provide a scientifically comprehensive description of the species. Interested readers should refer to sources that have been useful in compiling the following summary description of the species.
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These include: » http://www.fishbase.org/Summary/SpeciesSummary » ICES: Herring Assessment Working Group (Stock Annex) (ICES 2012b) » ICES Fishmap: http://www.ices.dk » http://oar.marine.ie/bitstream/10793/84/1/Herring%20Conference.pdf » FAO Species Factsheet: http://www.fao.org/fishery/species/2886/en
Management History Management of the Irish Sea herring fisheries takes place within the framework of the Common Fisheries Policy of the European Union. Fishing activity is regulated at European level, by allocation of 'Total Allowable Catches' (TACs) to defined individual fishing areas. Within these TACs, each member state is granted quota allocations. The TAC for this fishery is split between the UK including NI) and the Republic of Ireland, in 2009 the split was 74% to the UK and 26% to Rep of Ireland. In most cases the non UK herring entitlement is traded to the Northern Irish Producer Organisations. The Northern Ireland allocations are managed by two local Producer Organisations (POs), overseen by the Department of Agriculture and Rural Development (DARD), within the UK wide quota management system. In Northern Ireland, the Northern Irish Government’s Department of Agriculture and Rural Development is responsible for a range of management and regulatory duties, including management of fleet activity, management of national quota, monitoring, control and enforcement of all fisheries occurring within national jurisdiction, collection, collation and transmitting of key fishery data, and undertaking at least a base range of scientific monitoring and development work. The latter functions are undertaken by the Agriculture, Food and Environmental Sciences Division (AFESD) of the Agri-Food and Biosciences Institute (AFBI), which is part of DARD. Within EU member states, responsible authorities divide amongst their various fleets the national quota allocations agreed at the December meeting of the Council of Ministers. Accordingly, it is up to the Northern Ireland fleet, operating through the main Producer Organisation’s, to allocate their quota share to individual vessels. In turn, fishers report landings to DARD (via the logbook reporting scheme) who in turn report aggregated information to the UK authorities and the European Commission. At the point in the fishing season when the aggregate Total Allowable Catch is near to being taken the Commission can make a Regulation to close the fishery. Within Northern Ireland there are systems in place to monitor weekly quota uptake, providing a basis and means to close the fishery once the quota is taken up. The core backdrop to the management of this fishery is the advice provided by the ICES Advisory Committee (ACOM). ACOM draws on the on-going work of international scientists from relevant research laboratories and institutions – including the Agriculture, Food and Environmental Sciences Division of DARD and the Marine Institute - on aspects of stock biology and relevant marine science through various ICES working groups. Scientific research and assessment is carried out by a large number of specialised ICES Working Groups. For herring, the most relevant group is the Herring Assessment Working Group (HAWG). The assessments are reviewed and evaluated by ACOM which then provides advice on the status of target and non-target stocks to the European Commission. ICES advice, via Commission proposals, informs the annual EU Council of Ministers regulation establishing management measures, in particular TACs and quotas.
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As a result of previous reform of the CFP, Regional Advisory Councils were established. With respect to herring fisheries, the relevant RAC is the Pelagic RAC. The Pelagic RAC provides a forum for fishermen and other stakeholders (including NGO’s), policy makers and scientists to exchange views on management of pelagic fish stocks in order to work towards integrated and sustainable management of pelagic resources in a manner that encompasses both the ecosystem approach and the precautionary principle. The Pelagic RAC prepares and provides advice on the management of pelagic fish stocks on behalf of the fisheries sector and other stakeholders. It covers the pelagic stocks of all the areas, excluding the stocks in the Baltic Sea and Mediterranean Sea. The Pelagic RAC (as a foundation under Dutch law) was inaugurated on 16 August 2005, and consists of a General Assembly, an Executive Committee and two Working Groups. The work is furthermore done in collaboration with observers, for example, from non-EU countries that have an interest in particular stocks or regions covered by the Pelagic RAC. In recent years, the Irish Sea herring fishery has been prosecuted exclusively by UK and to much lesser extent Irish vessels. TACs were first introduced in 1972, and vessels from France, Netherlands and the USSR also reported catches from the Irish Sea during the 1970s before the closure of the fisheries from 1978 to 1981. By the 1990s only the fishery on the Manx fish remained, and by the late 1990s this was dominated by Northern Irish boats. The number of Northern Irish vessels landing herring declined from 24 in 1995-96 to 6-10 in 1997-99 and to 4 in 2000. Only two vessels operated in 2002 and 2003. However, total landings have remained relatively stable since the 1980s whilst the mean amount of fish landed per fishing trip has increased, reflecting the increase in average vessel size. There are two closed areas in operation to protect the spawning stock during part of the spawning season and to prevent exploitation of juveniles (Figure 3.2.2). These measures were introduced during the period of the industrial fishery in the Irish Sea (1969 – 1979). The area off the Louth and Down coast is closed from the 21st September – 31st December and the east of the Isle of Man is closed from 21st September until 15th November. Republic of Ireland vessels are not permitted to fish east of the Isle of Man, under the terms of an international agreement made in the 1960’s.
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Figure 3.2.3 Position and geographical area of herring closures within the Irish Sea as defined by Council Regulation (EC) No 850/98, amended by EC 2723/1999.
Source: Pelagic Regional Advisory Council Fishing Practices
Three pelagic trawling vessels are included in the certification. All are large (<49m) modern high seas pelagic fishing vessels. These vessels are technologically advanced and there is on-going investment in state of the art technology and modern electronic equipment such as sonar, net and catch monitors, which have greatly improved the precision of this method of fishing. The vessels obtain all of their pelagic catch using pelagic trawls fished either in single vessel operations (Voyager) or in pair trawling arrangements (Havilah and Stephanie M). The fishing operation takes place mainly during the hours of darkness when dense shoals form above the seabed. When a single vessel is involved in trawling, pelagic trawl doors are used to keep the mouth of the net open rather than each end of the net being towed in unison by two separate vessels (pair trawling). Fish handling is highly automated and fish is pumped onboard from nets directly into large tanks containing refrigerated seawater (RSW). These vessels land catches directly to processing factories in Northern Ireland, Ireland and occasionally into ports in other jurisdictions.
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Pelagic trawls are towed at the appropriate level in the water column to intercept target shoals, with gear depth being controlled by altering towing speed and/or warp length. The horizontal opening is maintained by mid-water pelagic trawl doors whilst the vertical opening is normally maintained using a chain weighted groundline and floatation attached to the headline. The trawl used by the NIPSG pelagic fleet is designed and rigged to fish in midwater, including in the surface water and is therefore not designed to come in contact with the seabed, and any inadvertent contact is extremely rare – and would risk causing expensive damage to the net. The large net (considerably larger than a demersal trawl net) consists of a cone shaped body, ending in a codend with lateral wings extending forward from the opening. Large mesh in the wingends of the forward moving trawl herd the fish before tapering to finer meshes in the square, belly and eventually the cod end. Larger mesh fitted to the front of the net is intended to facilitate the escape of small fish and also pelagic invertebrates such as jellyfish, which have the potential to be impacted by pelagic fisheries. Table 3.2.1: List of member vessels
Name Vessel Reg. No. Havilah N200 Stephanie M N265 Voyager N905 Source: client An up to date vessel list can be obtained by contacting FCI using the following details: MSC Fisheries Department Contact Email: [email protected] Contact Tel: +44(0)1463 223 039 (FCI main number)
Historical Fishing Levels Table 3.2.2 summarises catches by nation 1987-2012. Figure 3.2.4 summarises catches for the years 1961-2011. Table 3.2.3 presents ICES advice, management, and catch of herring in Division VIIa North of 52º30’N (Irish Sea) from 1987-2012. Catches peaked in excess of 40,000t in the 1970’s prior to a sharp decline in the spawning stock biomass. Since then catches fluctuated between 2,500t and 10,000t between 1987 and 2004. Catches have been relatively stable at between 4,400-5,200t since 2005.
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Table 3.2.2 Catches of Irish Sea herring (herring in VIIa North of 52º30’N) by fishing nation and total catch 1987-2011
Source: ICES HAWG 2013
Figure 3.2.4 Catches of Irish Sea herring (herring in VIIa North of 52º30’N) 1961-2011
Source: ICES HAWG 2013
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Table 3.2.3 ICES advice, management, and catch of herring in Division VIIa North of 52º30’N (Irish Sea) from 1987-2012.
Source: ICES HAWG 2013
Other Resource Attributes and Constraints The fishery is concentrated in the autumn and targets aggregations of spawning herring. Outside of these periods the stock is more widely dispersed outside of the main fishing areas and it is less economic to pursue catches at these times.
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3.2.3 Administrative Framework User Rights (Legal and Customary Framework) The UK fishing industry has traditionally been open access, however over the years fisheries management and fleet policy have gradually curtailed access and thereby reduced the opportunities for anyone wishing to fish, with restricted licenses and restricted quotas now being a pre-requisite before fishing. Access to these has however been non –discriminatory and market economies have influenced the evolving shape of the industry. Although licenses and quotas are now expensive, those in possession of licenses and quota are quite likely to be representatives of some families that have fished the same waters for many generations, and have been able to take advantage of the opportunities to remain in the industry. This is especially true of the fishery under assessment. In terms of relevant customary fishing rights for those depending on fishing for food or livelihood, the Mourne coastal fishery warrants mention. This Northern Irish coastal fishery targets VIIaN herring using drift gill nets from ‘skiff’ vessels no more than 12m LOA. This fishery receives a set allocation of the VIIaN quota which safeguards this traditional inshore fishery. In recent years this has been set at 30t for a short seasonal fishery. Fishers wishing to partake in the fishery must apply for a permit each autumn season. The quota allocation provided to this inshore fishery is comparatively small, and far smaller than it has been historically, when over 1,000t was allocated to the fishery and there is now demand for a greater share of the overall TAC. According to DARD, the reallocation of quota share from the coastal fishery to the main VIIaN herring fishery has taken place over a number of years making use of quota which had not been taken up in the Mourne fishery. It is only in recent years with the increase in herring quota and the increase in herring price that the demand of inshore fishers to participate in the Mourne Fishery has increased, including from a number of fishers without historical track record in the fishery. Around half of the fishers active in the Mourne fishery are part time and many are also young fishermen, relatively new to the fishery. In July 2013 a UK high court ruling found that the UK government could reallocate underutilized quota from large vessels in Producer Organisations back to smaller inshore vessels. However, as the VIIaN herring quota is fully utilized it is not anticipated that this ruling will lead to any change in the existing allocation to the Mourne fishery. However, DARD are seeking to enable an additional amount of quota to be leased by the Mourne fishery. There has been no forcible removal of quota from coastal communities, and the Mourne fishermen are eligible to buy or lease quota as any other fisherman in an open market. The coastal communities are not indigenous populations dependent on fishing for food, indeed those in the Irish Sea herring fishery under assessment have their background in the Mourne coastal fishery. Representatives of the Isle of Man Fisheries Directorate (within the Department of Environment Food and Agriculture) also highlighted the fact that Isle of Man fishers do not have access to the herring catch within their waters – aside from a very small coastal fishery. It is understood that historically Isle of Man fishers did have a larger share of catches but that their allocation reduced when quota was allocated to EU Producer Organisations, which the Isle of Man (outside the EU) did not have access to. Whilst the fisheries management system clearly recognises the inshore sector, including ring fencing some quota for smaller vessels, it does not formally commit to safeguard traditional fishing communities or traditional fishing methods.
Further details on the administrative framework are contained in section 3.5 of this report.
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Legal / Administrative Status The fishery under assessment is legal, legitimate and takes place within the context, restrictions and limitations of the Common Fisheries Policy and relevant national fishery management agreements.
Involvement of Other Entities EU / DG Mare takes overall responsibility for management of Irish Sea Herring with decisions on TAC and technical conservation measures ultimately taken at an EU level. Within the UK DEFRA / MMO takes overall responsibility for fisheries policy and licensing. Within the devolved administration of Northern Ireland the Fisheries & Environment Division of DARD has administrative responsibility for sea fisheries in Northern Ireland waters including enforcement of fisheries legislation and fishing vessel licensing; the administering of fisheries grant schemes (under the Fisheries Act (Northern Ireland) 1966 as amended). Within the Isle of Man jurisdiction, the Fisheries Directorate (part of the Department of Environment Food and Agriculture) has overall responsibility for management. While in this fishery they are not engaged in stock management, they do play an important role in elements of spatial management and protection of spawning / nursery grounds. For example, the Directorate has responsibility for managing implementation of the closed area specified in Council Regulation 2723/1999, part of which falls within its territorial sea. The Directorate has exclusive responsibility for enforcing the 3 nautical mile fisheries exclusion zone for vessels >50’ around the island. All enforcement and inspection of landings functions in Northern Ireland is carried out by DARD enforcement officers. Inspections within the Irish Sea can be carried out by DARD enforcement officers or the Royal Navy Fishery Protection Squadron, or if in waters of the Republic of Ireland by the Sea Fisheries Protection Authority (SFPA), or in the waters of the Isle of Man by the Isle of Man Fisheries Directorate. Oversight of enforcement activity is carried out at EU level by European Fisheries Control Agency in Vigo.
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3.3 Principle One: Target Species Background Principle 1 of the Marine Stewardship Council standard states that: A fishery must be conducted in a manner that does not lead to over fishing or depletion of the exploited populations and, for those populations that are depleted, the fishery must be conducted in a manner that demonstrably leads to their recovery. Principle 1 covers all fishing activity on the entire herring stock - not just the fishery undergoing certification. However, the fishery under certification would be expected to meet all management requirements, such as providing appropriate data and complying with controls, therefore demonstrably not adding to problems even if the problems will not cause the certification to fail. In the following section the key factors that are relevant to Principle 1 are outlined. The primary sources of information on this section are: » ICES. 2013a. Report of the Herring Assessment Working Group for the Area South of 62 N (HAWG), 12-21 March 2013, ICES Headquarters, Copenhagen. ICES CM 2013/ACOM:06. 1270pp. » ICES. 2013b. Herring in Division VIIa North of 52º30’N (Irish Sea). Book 5.4.14 Advice June 2013
3.3.1 Stock Definition Herring spawning grounds in the Irish Sea are found in coastal waters to the west and north of the Isle of Man and on the Irish Coast at around 54oN (ICES, 1994; Dickey-Collas et al., 2001). Spawning takes place from September to November in both areas, occurring slightly later on average on the Irish Coast than off the Isle of Man. Vertebral counts had been used to separate catches into Manx and Mourne stocks associated with these spawning grounds, but this technique was found deficient and catches have been combined since 1984. All subsequent assessments have treated the VIIa (N) data as coming from a single stock. The occurrence in the Irish Sea of juvenile herring from a winter-spring spawning stock has been recognized since the 1960s based on vertebral counts (ICES, 1994). More recently, a study of otolith microstructure suggested that nursery grounds in the western Irish Sea were generally dominated by winter-spawned fish, whereas samples from the eastern Irish Sea were mainly autumn-spawned fish (Brophy and Danilowicz 2002). An experiment tagging herring off the SW of the Isle of Man in 1991 indicated a movement towards spawning grounds in the Celtic Sea as the fish matured (Molloy et al., 1993). This suggests that there is some mixing of populations between the Irish and Celtic Sea areas. A proportion of the Irish Sea herring stocks may also occur to the north of the Irish Sea outside of the spawning period. This was indicated by the recapture on the Manx spawning grounds of 3-6 ring herring tagged during summer in the Firth of Clyde (Morrison and Bruce, 1981). Aggregations of post-spawning adult herring were detected along the west coast of England during an acoustic survey in December 1996 (Department of Agriculture and Rural Development for Northern Ireland, unpublished data, reported in ICES 2013), showing that a component of the stock may remain within the Irish Sea. A large EU framework project entitled “A multidisciplinary approach to the identification of herring (Clupea harengus L.) Stock components west of the British Isles using biological tags and genetic markers” (WESTHER) has been completed, which focused on identifying herring populations and the degree to which they mix. In 2010, the ICES Study Group on the Evaluation of Assessment and Management Strategies of the Western Herring Stocks (SGHERWAY) determined the implication of the findings of this project for the assessment and management of these stocks. The figure below summarises the findings from WESTHER. 23 version 2.0(01/06/13)
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It concluded that there was mixing of juveniles and adults (spawners and feeding migration) throughout the management areas to the west of the British Isles. Although the North Sea was not included as part of the study area, it is likely that there is also some mixing across the 4o management line. The other important conclusion was that there is very little mixing between the Celtic Sea area and the other stock areas. ICES (2013) reported that a significant proportion of the catch in the Irish Sea (as much as 30% in some years) are likely to be juveniles originating from the Celtic Sea spawning stock. This is based on the assumption that all herring that originate from winter spawning are from the Celtic Sea, whereas the Irish Sea is predominantly autumn spawning. There is, however, uncertainty about the migration of adults back to the Celtic Sea and the occurrence of mature fish on the spawning grounds in the Irish Sea suggest that not all fish necessary return to their natal spawning ground. If they did, the population will be genetically distinct and the opposite was found during WESTHER. Although SGHERWAY found that a combined assessment of the three stocks VIaN, VIaS/VIIb,c and VIIaN (the Malin Shelf metapopulation) would give important information on the Malin Shelf metapopulation, it was thought unlikely to be useful for management advice purposes because it does not provide sufficient information on the status of the individual components.SGHERWAY subsequently concluded that “managing metapopulations is only possible with detailed information on fisheries independent data. However, whenever subcomponents of the metapopulation differ considerably in abundance, sustainable management is impossible for the smallest subcomponent. The VIIaN ICES stock should therefore continue to be assessed and managed separately. Where there is uncertainty of stock identification fishing mortality should be kept at low levels. Should identification rates increase, fishing mortality may also be increased. “(ICES 2010). The assessment of Irish Sea herring has proven to be difficult mostly due to: the spatial and temporal aspects of the migration of adult fish during the spawning season and the timing of the acoustic survey and the commercial fishing operation in relation to this migration. Since 2007 much work has been completed to address this that has resulted in an improved stock assessment. the high and variable abundance of juvenile herring from winter spawning origin (mostly Celtic Sea). This is currently addressed by management actions that reduce juvenile catches and precautionary fishing mortality.
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Figure 3.3.1 Hypothetical movements of juveniles and adults to feeding and spawning grounds based on historical evidence and WESTHER results (Pieter-Jan.Schön, pers. comm.).
Source: Westher
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The mixing of herring at both juvenile and adult stages within the northern Irish Sea during the spawning season has been considered (Schön Burke et al 2009). The proportion of fish from winter spawning origin is highly variable spatially within a year as well as temporally between years. Other findings include: There are a number of spawning sites in the Irish Sea, but the assessment focuses on the main one and the winter spawning that might occur within that area. Other areas may be predominantly winter spawning, such as Belfast Lough. Mature fish were found on the main spawning grounds from winter spawning origins, indicating that not all fish return to their natal spawning ground. No correlation has been found between juvenile abundance in the Irish and Celtic Sea. Given that the Celtic Sea is a much larger stock, there would be a clear relationship if all fish of winter spawning origin migrate from the Celtic Sea. In summary. ICES has concluded that the mixing issue is sufficiently taken into account in the assessment, to the extent that the routine estimates of the extent of mixing was deemed unnecessary for assessment and management advice purposes. The unit of stock assessment and the Irish Sea fleet unit are closely aligned, which allows sustainable management advice. The harvest control rule based on fishing mortality is being developed with the intention of providing sufficient protection given the SGHERWAY recommendation to link the identification rate to the fishing mortality. Therefore, the Irish Sea constitutes a management unit. The fishery primarily prosecutes a semi-discrete group of fish which are of interest to fishery managers (Begg et al. 1999), and is a stock in the sense that it can be managed so that the fishery is sustainable, rather than it strictly consists of a discrete fish population with no immigration or emigration.
3.3.2 Inseparable or Practicably Inseparable (IPI) Stocks The MSC certification requires that each of all target stocks must meet the Principle 1 requirements, so it is possible to interpret CR 1.3 to require that this certification include the Celtic Sea stock. The Celtic Sea and Irish Sea stocks are currently practically inseparable, Celtic Sea herring are likely to exceed 2% of the Irish Sea catch and Celtic Sea herring has been MSC certified (CSHMAC Celtic Sea Herring Trawl Fishery), so Principle 1 scoring for Celtic Sea herring could be a requirement for this fishery (CR 27.4.9). The argument for this is that the Irish Sea catch that may have originated from the Celtic Sea and therefore the state of the Celtic Sea stock is relevant to labeled herring caught in the Irish Sea. We have chosen not to do this for the following reasons: The current harvest strategy is to manage the Irish Sea as a single unit, while recognizing some degree of mixing among spawning components. Thus the mixing is taken into account as part of the harvest strategy, and is essentially addressed as an uncertainty in the assessment and in setting the harvest control. The certification label will relate to the management unit that is scored. Scoring Principle 1 for Celtic Sea as well would be based on argument that the biological population structure rather than the management unit forms the basis for assessment. This is not the approach that has been taken with most other stocks (NEA mackerel, most herring stocks) and while desirable, is probably impractical for the same reasons that fisheries are managed as unit stocks rather than populations. To be consistent, this practice should be applied across stocks that could require several Principle 1 scoring for components with significant degrees of mixing. The additional Principle 1 scoring increases the cost of this assessment and does not improve the assessment in our opinion and could lead to conditions that the client cannot hope to comply with. This could lead to a failure of the fishery on a technicality, which, on the face of
26 version 2.0 (01/06/13) Food Certification International Final Report Northern Ireland Pelagic Sustainability Group (NIPSG) Irish Sea Herring Fishery it, does not appear to be linked to whether the fishery is sustainable, or not. This is not the intent of IPI certification requirements. It is noted in this assessment that the effect of Irish Sea catches on the Celtic Sea stock is likely to be negligible, and that the Celtic Sea stock is in a good state. This observation forms part of the harvest strategy scoring, rather than a full separate Principle 1 scoring. Scoring both Celtic Sea and Irish Sea components would introduce a certain degree of double- scoring with two Principle 1 scores, since both harvest strategies consider the state of surrounding stocks. We agree with ICES that the level of exploitation should be linked to the identifiability of the stock. It has been suggested to increase sampling so that catches can be separated between major stock components throughout the seas West of Britain. This would allow more precise TACs to be set relative to the state of each component. Where catches from different management units are mixed and allocated to different TACs then Principle 1 (and possibly Principle 3) scoring should be applied to all units. No further research on juvenile mixing is now expected as it is low priority, with the exception of improvements of the stock assessment in representing and estimating mixing. Further research on mixing between the Celtic and Irish Sea stocks would be expected to make little impact on management advice.
3.3.3 Stock Status and Reference Points Trends from the most recent assessment indicates an increase in spawning stock biomass (SSB) and recruitment in recent years, with an associated downward trend in fishing mortality (F). Based on the most recent estimates the stock is being harvested sustainably and below FMSY (Fig. 3.3.2).
The biomass reference points for the stock are Bpa (9 500 t) and Blim (6 000 t). Bpa can be considered a lower bound for region where the biomass may be considered at MSY (i.e. so that SSB should remain above this point if the target FMSY is applied). These biomass reference points were not revisited by the benchmark working group in 2012. There are no precautionary F reference points for this stock. MSY reference points were estimated by means of the plotMSY software (ICES WKPELA 2012). FMSY were calculated based on the three common stock recruit relationships; Ricker, Beverton-Holt and “Hockey-stick”. The Beverton and Holt relationship was preferable as there is no evidence of reduced recruitment at high SSB, which is the underlying assumption for a Ricker curve. Standard statistical criteria (CV and AIC test) suggest that Beverton and Holt is also slightly better model fit. FMSY appears to be well -1 estimated and a FMSY of 0.26 year has been proposed as the candidate target reference point. The benchmark process concentrated on the F reference points. Standard biomass reference points depend upon the stock recruitment relationship, for which the evidence is weak. The current biomass is at a high level and considered well above any candidate biomass limit reference point. As part of the development of the management plan (a management plan is not yet in place for this stock) and continuing work at ICES, the working group are reinvestigating the reference points and this will include biomass reference points. This will happen within the next year, being an integral part of the management plan.
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Figure 3.3.2 Herring in Division VIIa North of 52º30’N (Irish Sea) spawning stock status and fishing mortality in relation to current reference points (from ICES 2013b).
Source: ICES (2013b)
Source: ICES (2013b)
3.3.4 Key Trophic Level Reference Point (PI 1.1.2d) The main fish predators on herring in the Irish Sea include whiting (Merlangius merlangus), hake (Merluccius merluccius) and spurdog (Squalus acanthias), whereas cod (Gadus morhua) appears to be a minor predator of herring. The size composition of herring in the stomach contents indicates that predation by whiting is mainly on 0-ring and 1-ring herring whilst adult hake and spurdogfish also eat older herring.
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Small clupeids are an important source of food for piscivorous seabirds including gannets, guillemots and razorbills, which nest at several locations in and around the Irish Sea. Marine mammal predators include grey and harbour seals, and possibly pilot whales, which occur seasonally in areas where herring aggregate. Whilst small juvenile herring occur throughout the coastal waters of the western and eastern Irish Sea, their distribution overlaps extensively with sprats (Sprattus sprattus). The biomass of small herring has typically been less than 5% of the combined biomass of small clupeids estimated by acoustics. Irish Sea herring is a member of the family Clupeidae, which is listed in box CB1 (MSC CR 1.3), and therefore could be designated as a key low trophic level stock. Therefore Irish Sea herring must fail to satisfy two out of the three sub-criteria below (CB2.3.13a) to avoid being designated a key low trophic species. The sub-criteria are assessed mainly based on information in Lees and Mackinson (2007). Within the Ecopath model, Lees and Mackinson (2007) define herring as part of the “small planktivorous fish” group, of which herring make up of about a third of the biomass. The Lees and Mackinson (2007) model is publicly available and based on credible data and information. As for all Ecopath models, the Irish Sea model depends on estimating energy flow in the ecosystem in an equilibrium state, although possible dynamics were explored using Ecosim. The model is a simulation, and is not a statistical model fitted to data. Lees and Mackinson (2007) provided a diet matrix which was used to calculate the food web connectivity indices for small planktivorous fish (see GCB 2.3.13). Based on these estimates, we calculated the Proportional Connectance to be 5% and the weighted SURF index as 0.00125, which places this group in the indeterminate region (guidance reference points: Proportional Connectance > 8% and/or SURF index > 0.005 indicates key LTL, Proportional Connectance < 4% and/or SURF index < 0.001 indicates non-key LTLT; GCB 2.3.13). However, the estimates from the diet matrix represent a maximum for these indices, since the “small pelagic planktivorous fish” group, although dominated by herring, consists also of scad (Trachurus trachurus), pilchards (Sardina pilchardus), shads (Alosa alosa), sprat (Sprattus sprattus), and anchovy (Engraulis encrasicolus). Therefore, it is highly likely that the SURF index calculated specifically for herring would be below the reference point, and therefore Irish Sea herring does not meet this sub-criterion. a large volume of energy passing between lower and higher trophic levels passes through this stock; Based on the biomass estimates used in the Ecopath model, Lees and Mackinson (2007) estimate that approximately 33% of the small pelagic planktivorous fish group are herring and therefore the biomass was in the region of 1.2 t km-2, compared to consumer biomass which was 88 t km-2, which equates to significantly less than the 5% threshold of the consumer biomass, and therefore this sub-criterion is not met. In addition, the average catch is relatively small and has always been less than 50,000t threshold (GCB 2.3.13 ii). In addition, the biomass of small herring has typically been less than 5% of the combined biomass of small clupeids (including sprats) estimated by acoustics. there are few other species at this trophic level through which energy can be transmitted from lower to higher trophic levels, such that a high proportion of the total energy passing between lower and higher trophic levels passes through this stock (i.e. the ecosystem is ‘wasp- waisted’). Herring make up approximately 33% of the small pelagic planktivorous fish group with five other species. Other species that have a similar trophic role are mackerel (Scomber scombrus) and sandeel (Ammodytes tobianus, Hyperplus lanceolatus). Based on information used by Lees and Mackinson (2007), Irish Sea herring makes up less than 5% of the total biomass across similar trophic groups, which strongly suggests the Irish Sea ecosystem is not “wasp- waisted”.
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More generally speaking, the MSC criteria for key low trophic stocks favour low-diversity ecosystems which are dominated by broad environmental effects, such as those found in upwelling systems or systems with strong seasonality. The Irish Sea is not an upwelling system with relatively high diversity, similar to the North Sea where the herring stocks are not key low trophic stocks. The Irish Sea appears to share a wide number of ecosystem characteristics with the North Sea (Lees and Mackinson 2007). In addition, estimated trophic level for Irish Sea planktivorous fish is 4.15, higher than the mean level reported for this species (mean 3.2; www.Fishbase.org). Survey data suggests that zooplankton groups account for more than 90% of the diet of small pelagic planktivorous fish. Therefore it was found that Irish Sea herring is not a key low trophic stock and scoring issue 1.1.2d is not relevant and not scored.
3.3.5 Harvest Strategy and HCR The current harvest strategy consists of a precautionary catch limit (TAC) based on fishing mortality and biomass estimated within a stock assessment, as well as various closed areas to improve selectivity and reduce various risks of overfishing. The fishery is relatively small, with fishing mainly being carried out by a single pair trawl. A harvest control rule is under development. It is intended to have a draft HCR in place by the first quarter of 2014 and have it evaluated by ICES by the end of 2014. This suggests that the plan should be implemented in 2015, as long as it is used before being included in regulation. In any case, the HCR should be implemented within the certification period. In the meantime, a reduced fishing mortality is applied which has resulted in the stock recovery in recent years. The Herring Assessment Working Group is supporting the development of a long-term management plan for this stock, which should be able address a number of outstanding issues leading to an improved stock assessment and advice. The plan was being developed with stakeholders in 2013 and should be forwarded to ICES for evaluation. There are irregular cycles in the productivity of herring stocks (weights-at-age and recruitment). There are many hypotheses as to the cause of these changes in productivity, but in most cases it is thought that the environment plays an important role (through transport, prey, and predation). Coincident periods of high and low production have been seen in the herring in VIaN and Irish Sea herring, and exploitation and management strategies should be able to adapt to changes in productivity. The Irish Sea herring stock has shown a marked decline in productivity during the late 1970s and has remained on a low level since then. Reported international landings in 2012 for the Irish Sea amounted to 5 693 t with UK vessels acquiring extra quota through swaps with the Republic of Ireland and banking from 2011 to 2012. The majority of catches in 2012 were taken during the 3rd quarter. There is also a traditional gillnet fishery on the Mourne herring, which has a derogation to fish within the Irish closed box. Boats from the Republic of Ireland are not permitted to fish east of the Isle of Man. The closed areas consist of: all year juvenile closures along part of the east coast of Ireland, and the west coast of Scotland, England and Wales (within 12 miles of the coast); spawning closures along the east coast of the Isle of Man (Douglas Bank spawning ground) from 21st September to 15th November, and along the east coast of Ireland all year round. These closures help explain differences in selectivity between the survey and the fishery. Herring are an important prey species in the ecosystem and also one of the dominant planktivorous fish. No explicit account is taken of herring’s role in the ecosystem.
3.3.6 Data and Stock Assessment Overall landings are recorded accurately and discarding (slippage) is thought to be very low. No significant catches are taken in other fisheries.
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Biological sampling of the catch has been good, with the exception of 2009. Routine sampling of the main catch component was conducted in 2012, with sampling coverage concentrated on the pair trawlers. 27 samples from the main catch component were acquired in 2012, with a further 3 samples taken from the gillnet fishery operating on the Mourne ground. There was no biological sampling of the main catch component (pair trawlers) in 2009 due to a failure to acquire samples from the landings. There is an observer programme, which, since 2010, has adhered to the EU data collection regulation requirements. The aim of the programme is to observe and record total catch composition and size distribution of species as well as any interaction between the fishery and cetaceans, seals and basking sharks and other ETP species. The number of trips in the main fishery range from 22-42 trips since 2005 (averaging 29 trips) and the aim has been to observe at least 6 trips annually (5% coverage). Of the more than 62 hauls observed, there has been 3 observation of slippage in the last 4 years. Although low, this is still likely to be an overestimate, since the observer coverage is skewed towards the start of the fishing season when the likelihood of slippage will be higher because there is less chance of fishing exclusively on spawning/mature (larger size) fish aggregations. Once the fishery moves to the east of the Isle of Man in the later part of the fishing season there is no occurrence of slippages observed or reported in the past. Anecdotal information from the Isle of Man fisheries department also suggested that although slippage may have been a problem in the past, there has been very little evidence of slippage since at least 2007. This is based on the amount of herring strandings observed on the island during the fishing season and other reports from the public. ICES considers slippage and discarding to be insignificant for this fishery. The main abundance index is provided by a fishery independent acoustic survey. Commercial CPUE is not used for this stock. The acoustic survey consists of stratified, systematic transects over the survey area and includes trawl sampling. Sprat and 0-group herring are distributed predominantly around the periphery of the Irish Sea, whereas the adult (SSB) are encountered in the main spawning areas. The survey is designed to coincide with the spawning adult population on the spawning grounds. Errors in the survey are mainly associated with significant inter-annual variation in the timing of migration patterns. The acoustic survey in 2012 was carried out over the period 29 August - 12 September, and sampling intensity was high with 33 successful trawls completed. The SSB estimates from the survey are calculated using the maturity ogives from the commercial catch data which are estimated annually. The estimate of herring SSB of 21,541t for 2012 is an increase from the 2011 estimate, but still a significant reduction from the 2010 estimate. A significant decrease in 0-gp herring and sprat biomass was observed in 2012, particularly for sprat. Winter hatched fish, of which the majority are thought to be of Celtic Sea origin, are present in the pre- spawning aggregations sampled in the Irish Sea during the acoustic survey (results of microstructure analysis from 2011). The acoustic survey data fits all ages well except age 1, when fish from the different hatching seasons mix most.
A series of additional acoustic surveys has been conducted since 2007 by Northern Ireland, following the annual pelagic acoustic survey (conducted during the beginning of September) with surveys completed approximately every fortnight. The enhanced survey programme was initiated to investigate the temporal and spatial variability in the population estimates from the routine acoustic survey and only concentrates on the spawning grounds surrounding the Isle of Man and the Scottish coastal waters, representing ~85% of the total Irish Sea SSB and ~81% of exploitable biomass (P-J Schön, pers comm). A detailed analysis of these surveys is being conducted as part of the development of the management plan and could lead to a change in design of the main acoustic survey to improve biomass estimates.
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A herring larvae survey (NINEL) is used in the stock assessment and the data series is available from 1993. The survey is conducted in November each year using a systematic grid of stations covering the spawning grounds and surrounding regions in the NE and NW Irish Sea (ICES 2013) and provides an indicator of the spawning stock biomass (fecundity). The production estimate of (1.12 x 1013 larvae) for 2012 in the NE Irish Sea was highest in the time series, but with high uncertainty around the estimate. Herring larvae are generally found to be most abundant to the southeast and northeast of the Isle of Man and less abundant in the western Irish Sea. There was a continued low occurrence of larvae in the area of the traditional Mourne spawning ground, although this might be due to a timing mis-match between larvae emergence and sampling. Groundfish surveys carried out by Northern Ireland since 1991 in the Irish Sea, were used 1996 to 1999 to obtain indices for 0- and 1-ring herring. However, these indices performed poorly in the assessment and have not been used since. Biological sampling has been used to calculate mean weights-at-age in the catch rather than a model growth for example. The mean weights-at-age in the 3rd quarter catches are used as estimates of stock weights at spawning time. Mean weights-at-age have shown a general downward trend in the last 22 years. The 2012 benchmark decided the natural mortality estimates from the North Sea, which they considered was not ideal and should be considered as preliminary estimates until specific values could be calculated for the Irish Sea. Variable maturity ogives are used based on the corresponding annual quarter 3 biological sampling from the catch. The final assessment was carried out by fitting the state-space model FLSAM (“SAM”, in the FLR environment). Previously, an assessment for this stock had not been accepted by the working group for more than 20 years before this 2012 and 2013 assessment was accepted. The working group reports that stock parameters were estimated well by the model, suggested by the relatively low uncertainty associated with the stock parameter and the retrospective analysis showed estimates for SSB, F and recruitment for the years 2011 and 2012 indicating a low retrospective bias, except for fishing mortality. The retrospective pattern generally shows a consistent underestimation of SSB and overestimation of F. At the Benchmark (ICES, 2012) the state-space models SAM model was chosen as the assessment model for Irish Sea herring. It was found that the modeling framework (FLR: http://www.flr-project.org / ADMB: http://admb-project.org) has a number of highly desirable characteristics, such as the stochastic treatment of all observations, a full statistical framework for evaluating model results, open source and cross platform source code, and an extremely high degree of flexibility allowing ready customisation to the peculiarities of the stock (ICES 2010). The data and methods were internally reviewed during the 2012 benchmark. The review included sensitivity tests to test model configurations, and a justified choice for a base model, and a “best fit” solution was found for the point estimates. The main issues with the stock are stock mixing (at younger ages from fish of different spawning season origin) and the different trends in mortality observed in the survey and the commercial catches. The majority of this variation may arise from the inter‐annual variation in herring migration patterns and the annual closure of the Douglas Bank spawning grounds, which will effect the selectivity of both the fishery and acoustic survey. The data are treated as a “mixed stock” because both the fishery and survey operate on this mixture without adjustment for winter hatched fish. This issue was addressed in the assessment model configuration. The juvenile stock mixing has resulted in increased estimates of fishing mortality, and high catchability estimates across the younger ages in the survey. Currently, the model does not have the structure to deal directly with the emigration of small herring from other stocks. Excluding winter hatched fish from the data, leaving only fish
32 version 2.0 (01/06/13) Food Certification International Final Report Northern Ireland Pelagic Sustainability Group (NIPSG) Irish Sea Herring Fishery of autumn spawning origin, does not change the perception of a significant increase in biomass estimates. Overall, the uncertainty estimates of the model parameters suggest the model explains the available data reasonably well and is able, importantly, to provide reasonable forecasts with low retrospective bias.
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3.4 Principle Two: Ecosystem Background Principle 2 of the Marine Stewardship Council standard states that: Fishing operations should allow for the maintenance of the structure, productivity, function and diversity of the ecosystem (including habitat and associated dependent ecologically related species) on which the fishery depends. The following section of the report highlights some of the key characteristics of the fishery under assessment with regard to its wider impact on the ecosystem.
3.4.1 Retained catch
Like many northeast Atlantic herring fisheries, the NIPSG fishery for Irish Sea herring targets spawning aggregations of adult herring. As such, catches tend to be characteristically clean with few or insignificant volumes of other species being captured at the same time. Official landings data was made available to the assessment team by DARD and this has allowed for an analysis of landings of all species of fish that were landed by NIPSG member vessels while they also landed Irish Sea herring, for the years 2010, 2011 and 2012. The data reveal that landings are comprised only of herring, and no other species were landed. Discussions with skippers, processors and enforcement personnel confirmed that there are no retained species other than herring in the catches. While small numbers of mackerel, horse- mackerel or whiting may occasionally be removed from the catch during processing, the number and biomass is considered to be insignificant. The nature of the clean catches therefore reflects the fat that the fishery is spatially and temporally limited and takes place in an area where few other pelagic species occur. Being a pelagic fishery, few demersal species are captured. The fishery therefore is characteristically clean, like most pelagic trawl herring fisheries, but even more so than many other certified herring fisheries on account of marked spatial and temporal constraints.
Table 3.4 - Aggregated landings by species for NIPSG vessels when landing Irish Sea herring, 2010-2012
Retained catch 2010 2011 2012 t % t % t %
Herring 4,764 100 5,054 100 5,635 100
Horse Mackerel Nil - Nil - Nil -
Mackerel Nil - Nil - Nil -
Source: DARD The vessels utilise sophisticated electronics to aid in identification of suitable shoals prior to deploying fishing gear. This assures a further degree of control over the resulting catch and it is exceptionally rare for vessels to end up with catches that have a significant proportion of unmarketable or undersize fish mixed in with the catch. All catches must be recorded in electronic log-books and processors are required to complete sales notes. Sales notes can be cross referenced with landings declarations, while there is full traceability in processing units and factory outputs can be traced back to declared inputs by vessels.
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There are no retained catches of species that are considered depleted or have poor stock status or which are vulnerable. Mackerel is subject to a long-term management plan and the stock is known to be above limit and precautionary reference points. While mackerel has been certified under MSC, the certification is suspended at present due to on-going catches in excess of the agreed TAC by the Faroe Islands and Iceland. Overall, the NIPSG Irish Sea pelagic trawl herring fishery is considered to be generally clean, with insignificant quantities of mackerel or horse mackerel being the only occasionally retained species in the catch. The management response is considered effective and appropriate to the nature and scale of the retained catch component. There is accurate and on-going collection of information in relation to levels of retained catch.
3.4.2 Bycatch species There is no bycatch in the NIPSG Irish Sea herring fishery. All catches are retained and landed. There are no mechanisms or installations on board vessels that could facilitate size or species grading and the bulk nature of the fishery means that all catches are handled using automated pumping techniques. As such, the time that would be needed in order to grade catches and discard unwanted fish would slow down the process of taking fish on-board, resulting in damage and significant loss of quality. Catches are pumped directly into RSW tanks and there is no further handling of catches until they are landed in port. Concerns exist in relation to the possibility of slippage (whereby entire catches may be dumped at sea) in some European pelagic fisheries. However, there are few economic incentives for slipping fish in this fishery. While it is possible that slippage may occur in this fishery, all indications from stakeholders (DARD, vessel crews, processors) are that it is a was a more common event in the past and is now a very infrequent event that is more likely to result from technical problems with machinery and on-board equipment than for any other reason. Vessels occasionally make very large catches, however in general vessels will have sufficient capacity to hold 500 or more tonnes of fish. In the case of two of the three vessels included in the certification, the Havilah and Stephanie M pair trawl and can share capacity for landing fish. This means that there is always sufficient capacity to take on-board and land the entire catch. There are few incentives for slipping herring – catches can be graded at factory and vessels. There is no price advantage for larger herring unlike some other pelagic fisheries including mackerel. Despite the low level of discarding through slippage that is believed to occur in the Irish Sea herring fisheries, there remains some uncertainty as to the precise level of slippage in this fishery. This is likely to be difficult to quantify precisely, however from the point of view of scientific assessment of stocks, a figure of 5% appears to be the estimate that is used as working figure for unaccounted fishing mortality. The NIPSG fleet are encouraged to record slippage events on an on-going basis and to provide data to the scientific community in order to reduce uncertainty in the future. Occasional mortality of seabirds is likely in the fishery, as many birds will feed in and around the fishing gear once it is on the surface. Capture of seabirds occurs through enmeshing of diving birds and it is considered an unintended bycatch. All available studies, observer reports and information point to this being a minor problem in northeast Atlantic herring trawl fisheries and instances of seabird mortality are considered highly likely to be very low and not to present a significant risk to any affected populations. Overall, the management response to the bycatch issue in the herring fishery is considered appropriate to the species involved and the scale of the issue. There is sufficient on-going data collection to identify increased risks of bycatch in the fishery and current fishery
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3.4.3 Endangered, Threatened and Protected species interactions (ETP) There is a reasonably extensive suite of legislation that is relevant to protecting populations of endangered, threatened and protected species. EU Directives including the Habitats and ‘Birds’ Directives as well as Northern Ireland national legislation such as the Wildlife (Northern Ireland) Order 1985 and the Nature Conservation and Amenity Lands (Northern Ireland) Order 1985. In Northern Ireland seals are protected by the Conservation of Seals Act 1970, which makes it an offence to kill or take seals at certain times of the year or by the use of certain prohibited means. The UK is also a signatory to the Convention on International Trade in Endangered Species (CITES). During the assessment, the team has reviewed all relevant international, EU and national legislation in order to identify those species, which are considered as ETP. The Irish Sea herring fishery is conducted within the Irish Sea eco-region, where a range of ETP species (as defined by the MSC CR v1.2 Jan 2012) are known to occur (Table 3.6), including relevant determining convention/legislation. While this is not an exhaustive list of all species that may be endangered, threatened or protected within the Irish Sea, it is in accordance with the requirements of the definition of ETP species as per the CR. Table 3.4.1 - ETP species known to occur within the North Sea
NORTH SEA ETP SPECIES
UK UK transposed into national signatory legislation
Council Directive EU Council Convention or legislative instrument CITES 92/43/EEC Reg 57/2011
Habitats Directive SPECIES Appendix I Appendix II
Harbour Porpoise Phocoena phocoena
Harbour Seal Phoca vitulina
Grey Seal Halichoerus grypus
Angel shark Squatina squatina
Common Skate Dipturus batis
Basking shark Cetorhinus maximus
Spurdog Squalus acanthias
Allis Shad Alosa alosa
Sturgeon Acipenser sturio Priority species
Source: assessment team
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Figure 3.4.1 Natura 2000 designated sites within the Irish Sea. Designated sites are contained within blue boundaries and include the three small sites west of the isle of Man.
Source: DEFRA
Harbour porpoise and bottlenose dolphin are also listed under Annex II of the Habitats Directive, requiring the designation of Special Areas of Conservation (SAC) to protect a representative range of their habitats. A regularly updated review of the current status on candidate SACs and SACs off the UK coast is provided by the JNCC at DEFRA - UK marine SACs. In relation to this fishery, there are a number of designated cSAC‘s within the northern Irish Sea that are in close proximity to the main fishing grounds (see Figure 3.4.1.) The designations of these sites are for large shallow inlets and bays in the case of Strangford Lough in Northern Ireland and Luce Bay and Sands in Southern Scotland (north of the Isle of Man). The Pisces reef complex comprises 3 sites west of the Isle of Man and outside of Isle of Man territorial waters, which are designated for reefs. The fishery is not considered likely to impact on any of these sites which are all outside of the main fishing area that lies to the west between the Northern Ireland coast and the Isle of Man. Some fishing activity within the Pisces Reef sites is possible or likely, however this is not considered likely to impact the conservation value of the site (considered further under ‘Habitats’ – 3.4.4. The species or animal groups that the fishery could potentially interact with based on an understanding of spatial and temporal aspects of the fishery include harbour porpoise, seals and basking shark.
Manx basking shark watch provides details in relation to the occurrence of basking shark in Manx waters. The waters of the Isle of Man are one of the sea areas within which basking shark are most frequently sighted in the UK. The peak sightings period is between May and August and 60% of sightings are made within 1km of the land. The main areas where basking
37 version 2.0 (01/06/13) Food Certification International Final Report Northern Ireland Pelagic Sustainability Group (NIPSG) Irish Sea Herring Fishery sharks are sighted and where they may form aggregations is around the southwestern tip of the island. Because the fishery does not take place until after the peak period for shark occurrence and also occurs away from the areas of greatest density, it is considered that the fishery poses little if any risk to basking shark. This is evidenced further by observer data from AFBI who have not witnessed any interactions with basking shark in 6 observer trips per annum since 2005. For cetaceans, there are permissible thresholds, or sustainable take levels, in use, based on criteria defined by international agreements: ASCOBANS (Agreement on the Conservation of Small Cetaceans of the Baltic and North Seas) advises for example that the maximum annual bycatch of Harbour porpoises should not exceed 1.7% of the population in that year; the IWC (International Whaling Commission) states that if the number of small cetaceans captured is greater than 1% of their total population size, then this should cause concern. The ASCOBANS limit is increasingly accepted as being most relevant for most small cetaceans, although ASCOBANS is moving towards a more precautionary approach to reduce the bycatch to less than 1% of the best available abundance estimate. No such limits have been proposed for some other ETP species including Basking shark, which may occasionally interact with the fishery. In general, populations of endangered, threatened and protected (ETP) species are highly studied and well understood in the Irish Sea and marine mammal atlas provides details of the distribution and relative abundance on marine mammals in the Irish Sea and other areas. The Sea Mammal Research Unit (SMRU) at St. Andrews has undertaken extensive surveys to determine the level of bycatch of sea mammals in UK pelagic fisheries. To date no cetacean or seal bycatch has been seen by independent observers in the pelagic herring trawl fisheries that have been monitored, although this did not include the Irish sea herring fishery. More specific stakeholder information provided by AFBI (pers comms) who operate an observer coverage scheme for the herring trawl fleet indicates no bycatch of protected cetaceans, seals or basking shark within the fishery. Observer coverage amounts to approximately 6 trips per year (or about 5% of effort). The level of interaction between this herring fishery and the relevant ETP species is considered unlikely to be significant in terms of population level impacts. All indications are that there are no instances of capture of cetaceans, seals or basking shark in the pelagic trawl fishery. This is largely based on the interpretation of data from monitoring of pelagic trawl fisheries under Council Regulation 812/2004, and from scientific and discard observer studies in this and other fisheries. There have been no recordings of any cetacean capture while vessels have been engaged in pelagic trawling.
3.4.4 Habitat impacts A broad range of mainly sedimentary but also hard seabed substrates are found in the Irish Sea. Several indicative maps are available that indicate the nature, distribution and extent of seabed habitats. In addition there are a multitude of more focused and detailed studies that confirm seabed type in a number of different areas. Other freely available data (e.g. OSPAR, Search MESH) indicate the locations of known sensitive seabed communities in the North Sea and adjacent waters. There is good information in relation to the operation of the fishery and the location of the main sensitive seabed habitat types in the Irish Sea. All NIPSG vessels carry Vessel Monitoring System equipment, meaning that data is collected on an on-going basis in relation to the spatial and temporal operation of the fleet while engaged in the Irish Sea herring fishery. Specific knowledge of pelagic fisheries and the manner in which this one operates has led the team to conclude that significant seabed habitat impacts are highly unlikely as vessels target
38 version 2.0 (01/06/13) Food Certification International Final Report Northern Ireland Pelagic Sustainability Group (NIPSG) Irish Sea Herring Fishery shoals of herring in mid water and fishing gear used is not designed to withstand interactions with the seabed. The frequency of on-going data collection in relation to the operation of the fishery is considered sufficient to allow for regular monitoring and detection of changes in risk to seabed types from fishing gear interaction in this fishery. Figure 3.4.2 a-d indicates the general distribution Irish Sea herring fishing effort by NIPSG vessels for 2010-2012 from a sample of NI government VMS data. Figure 3.4.2.a-d. Sample VMS plots aggregated for all fishing events for Irish Sea herring. a.
source: DARD b.
source: DARD
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source: DARD
d.
source: DARD
3.4.5 Ecosystem impacts There is considerable knowledge of the habitats and ecosystem of the Irish Sea, drawing on more than one hundred years of regular monitoring and research, the intensity of which has accelerated in recent decades. Many studies describe the biological community structure in the Irish Sea and herring is an important low trophic level component of the wider marine ecosystem – both as prey and predator.
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The Irish Sea herring stock has suffered notable declines in spawning stock biomass in the past - most notably in the late 1970s. The subsequent recovery of the fishery has provided considerable information to scientists about the potential of the stock to recover – without causing long-term consequences and this now provides the basis for the current precautionary management regime. The TAC ensures that the herring biomass in the ecosystem remains high, thereby ensuring that the role of the herring stock as a prey source for other species is safeguarded. There is no evidence that the pelagic trawl herring fishery causes serious harm to the biological diversity, community structure or productivity of the Irish Sea ecosystem. Working with this background information and the knowledge of the scale and manner in which Irish Sea herring fisheries are prosecuted and managed, it is considered highly likely that the impacts of the herring fishery across all P2 components are within acceptable limits. The fishery does not cause serious or irreversible harm to ecosystem structure and function, not does it compromise the provision of ecosystem services to other dependent species and communities within the Irish Sea.
3.5 Principle Three: Management System Background Principle 3 of the Marine Stewardship Council standard states that: The fishery is subject to an effective management system that respects local, national and international laws and standards and incorporates institutional and operational frameworks that require use of the resource to be responsible and sustainable. In the following section of the report a brief description is made of the key characteristics of the management system in place to ensure the sustainable exploitation of the fishery under assessment.
3.5.1 Description of the Management System. The Irish Sea Herring fishery takes place in ICES area VIIa. Although the fishery is targeted by vessels from Northern Ireland (a devolved administration of the United Kingdom), the fishery takes place in 4 areas of differing jurisdiction. The areas of jurisdiction of relevant to the fishery management system are The United Kingdom, Northern Ireland (although part of the UK the devolved administration has inshore jurisdiction and clearly defined responsibilities), the Republic of Ireland and the Isle of Man. The UK (including Northern Ireland) and the Republic of Ireland are both member states of the European Union. The Isle of Man is not a member of the European Union. The overarching mechanisms of management are the EU fisheries management system, as described below. Further comment on how the Isle of Man is engaged in the management process is also set out below. The United Kingdom is a Member State of the European Union and its fisheries are therefore subject to the principles and practices of the Common Fisheries Policy (CFP) of the EU. The Irish Sea Herring fishery is managed through the CFP in accordance with the basic fisheries regulation. The first EU common measures in the fishing sector date from 1970, when it was agreed that, in principle, EU fishermen should have equal access to Member States' waters. It was also decided that the EU was best placed to manage fisheries in the waters under their jurisdiction and to defend their interests in international negotiations. The CFP came into being in the form we recognise today in 1983. It was reviewed thoroughly in 2002 and the current basic fisheries regulation (No.2731/2002) was adopted by the Council of Ministers on 20th December 2002. The current policy is again under review, and a revised policy is likely to be enacted in 2013. The scope of the CFP extends to conservation, management and exploitation of living aquatic resources and aquaculture, as well as processing and marketing of fishery products, covering
41 version 2.0 (01/06/13) Food Certification International Final Report Northern Ireland Pelagic Sustainability Group (NIPSG) Irish Sea Herring Fishery related activities, both within EU waters and by any member state vessel or national – with due regard to the UN Convention on the Law of the Sea (UNCLOS) and without prejudice to the primary responsibility of the flag State. The CFP regulation is a ‘chapeau’ regulation setting out the strategic aims of the CFP and enabling the Council of Ministers, or in certain cases the Commission, to make more detailed Regulations. In total there are in excess of 600 related regulations broadly divided into 4 categories (Structural measures, State Aid, Management of Resources, market organisation). Included within these are regulations dealing with almost all fisheries management related aspects from control requirements, to fleet structure, technical conservation, marketing, annual total allowable catches (TAC) and species management and recovery plans. Outside the CFP framework other EU legislation dealing with habitats and species protection and is also relevant to fisheries management and to fishermen.
3.5.2 Isle of Man The Isle of Man is situated in the Irish Sea between the islands of Great Britain and Ireland. It is a self-governing British Crown dependency. Although the Isle of Man is not part of the United Kingdom, the UK is responsible for the Foreign Affairs and Defense. Furthermore, the Isle of Man is not part of the EU although there are no trade tariffs imposed between the UK and the Isle of Man. From the perspective of fisheries management the Isle of Man has a 12nm territorial sea, which is divided into zones (0-3nm & 3-12nm). Only vessels under 15.24m (50ft) registered length are allowed to fish within 3 miles of the Isle of Man and require a permit to do so. As such, none of the vessels covered by this assessment may fish within 3 nm of the Isle of Man. To fish within the 3-12nm zone UK registered vessels must hold an additional Isle of Man fishing permit which is issued bi-annually. The vessels covered by this assessment do fish within the Isle of Man 3-12nm zone. There is a Fisheries Agreement between the Fisheries Administration of the UK and the Isle of Man. The most recent of these is from 2012. This sets out the principles of fair access to each administration’s waters by vessels of both the UK and Isle of Man and stipulates that the Isle of Man government will keep rules and laws for the management of fisheries within its territorial seas in line with the UK commitments under the EU Common Fisheries policy. Furthermore catches by Isle of Man registered vessels of catches of EU quota managed stocks will count against the UK initial quota allocation. For the apportionment of quota within the UK fisheries administrations, the Isle of Man allocation will be included as part of England. The Agreement also clearly outlines the process for resolution of disputes, namely that if parties are unable to resolve a dispute then a binding decision will be taken by an arbitrator appointed by the president of the Chartered Institute of Arbitrators, with the costs borne equally by all parties to the dispute.
3.5.3 Decision-making Processes The majority of decision making for the Irish Sea Herring takes place in Brussels, within a typical framework of European Decision making on pressure stocks. At the heart of the European Union legislative / decision-making process is The European Commission; the politically independent, civil service. The Directorate-General for Maritime Affairs and Fisheries (DG Mare), is the administrative department of the Commission with responsibility for fisheries. The Commission is responsible for the preparation of proposals for new laws, which, once adopted by the Commissioners, are sent to The Council of the European Union, where elected national representatives, review the proposals of the commission makes Community laws, after reviewing proposals of the commission, and depending on their nature, after consulting with various committees and The European Parliament.
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In drafting legislative proposals DG Mare consults widely, including with, relevant groups, third countries and regional fisheries organizations including advisory committees – notably the Scientific, Technical and Economic Committee on Fisheries (STECF). The opinion of STECF is crucial in the process of setting annual Total Allowable Catches TACs and quotas. Once enacted the European Commission (DG Mare) then has responsibility for implementation, management and control of community law in Member States and, where appropriate, European legislation is enacted at the national level through relevant primary and secondary legislation. The annual decision on quota allocations for the forthcoming fishing season provides an indication of the how the European decision-making process works. The ICES working groups with responsibility of stock assessment, submit annual assessments to ICES ACOM, who in turn review and disseminate to the European Commission (DG Mare). The advice will be reviewed by STECF before preparing recommendation for the commissioners. In doing so, every effort is made to consider and assess the implications of decisions in view of pragmatic solutions at stakeholder (Catching Sector) level. This process is facilitated by the RAC structure and ACFA will typically also contribute to this consultation process. The Commissioners then pass recommendations to the Council of the European Union, who take the final decision at the annual December council negotiations. The key roles and responsibilities which shape the decision-making process or play a role in the management of the fishery are listed and detailed in section 3.1.2 of the scoring assessment tree. Although decisions on the setting of overall TAC and the share of that TAC between member states rests with the EU (in accordance with the principle of relative stability), decisions on how national quota allocation is divided among the fleet is taken by the member state (albeit in accordance with some overarching rules). National decision-making over how the UK share the Irish Sea Herring TAC is divided therefore rests with DEFRA.
3.5.4 Fisheries Specific Management The fisheries specific management is largely carried out according to the standard EU decision-making processes outlined above. In particular this is the process for annual decisions about setting the TAC. For other decisions, such as those taken either by the UK, the devolved administration of Northern Ireland and the Isle of Man, there is no single fishery specific decision-making process or body by which the overall management of the Irish Sea herring is looked at holistically and cohesively. In particular the Isle of Man has an important role to play in the management of the fishery insofar as much of fishing effort takes place in IoM waters and they are therefore responsible for legislating for and enacting special and seasonal closures. Current efforts are underway within Northern Island to develop decision-making rules to determine the level of exploitation of the resource according to harvest control rules. This GAP II funded has been supported by the regional advisory council and has sought to bring key stakeholders from all relevant jurisdictions together to develop management rules for the fishery, in particular a harvest control rule. Once this HCR is completed it is likely to be enacted in European Legislation. Such a legislative process will more clearly define the fishery specific objectives of the fishery and will also outline the process and timing by which the overall management system is reviewed and evaluated. This gap in the fishery specific management is addressed in this assessment by conditions in both principles 1 & 3.
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4. Evaluation Procedure
4.1 Harmonised Fishery Assessment There are no previous assessments or existing certifications of fisheries for Irish Sea herring N of 52°30’. While a considerable number of herring fisheries in the northeast Atlantic have already been certified under MSC and several others are in assessment, no other fisheries with common Units of Certification have been assessed under the MSC scheme. Nevertheless, the Celtic Sea herring fishery and the West of Scotland herring fishery are both MSC certified fisheries and are based on pelagic trawl gears. Accordingly the scoring of P2 components has been carried out with consideration of the scores achieved for PI’s in these assessments. However, the current fishery is based on a different stock and occurs in a different sea area and clear differences are inevitable with respect to scoring for retained, bycatch, ETP and ecosystem outcome, management and information PI’s. Harmonisation of P1 and P3 is not relevant as this assessment deals with a separate stock that is managed under its own set of rules, within the context of the CFP.
Completed assessments None. Assessments in progress No other fisheries for Irish Sea herring N of 52°30’ are in assessment.
4.1.1 Harmonisation Details Harmonisation meeting/s No harmonisation meetings were held.
4.2 Previous assessments This is the first MSC assessment for this fishery.
4.3 Assessment Methodologies This fishery was assessed using version 1.3 of the MSC Certification Requirements and version 1.3 of the MSC Full Assessment Reporting Template.
4.3.1 Assessment Tree The Default Assessment tree was used without any adjustments.
4.4 Evaluation Processes and Techniques
4.4.1 Site Visits During week commencing 19th August 2013, 3 members of the assessment team, supported by an FCI staff member, undertook a site visit to Belfast. This enabled a scheduled programme of consultations to take place with key stakeholders in the fishery – including skippers, scientists, fishery protection officers, NGOs, fishery managers and technical support staff. Prior notification of this site visit was issued on the MSC website and in the Irish Skipper publication in order that all relevant stakeholders were aware of the opportunity to meet with the assessment team.
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Itinerary of field activities
Day 1 – 19th August – Belfast city » On day 1, the assessment team met with the client organisation to discuss the fishery under assessment and provide an opportunity for the team to develop their level of knowledge with regard to the client group as well as to ask specific questions and confirm details of the assessment. This also provided an opportunity to request additional information and for the client to ask questions of the assessment team.
Day 2 – 20th August – Belfast city » On day 2, the assessment team met with 2 stakeholders to discuss the fishery under assessment and provide an opportunity for interested parties to submit comments, additional information or ask questions of the assessment team.
Day 3 – 21st August – Belfast city » On day 3, the assessment team met with 1 stakeholder to discuss the fishery under assessment and provide an opportunity for interested parties to submit comments, additional information or ask questions of the assessment team. Day 4 – 22nd August – Belfast city » On day 4, the assessment team carried out preliminary scoring.
Day 5 – 23rd August – Bangor Co. Down » On day 3, the assessment team visited 2 vessels from the client group specified under the Unit of Certification and met privately with 2 vessel skippers. This was to provide further detail on the fishing methods and practice in use under this fishery assessment and to give the vessel skippers / owners an opportunity to provide any feedback or comments they wished in an open and transparent manner.
Additional individuals contacted during field activities A conference call was held with the Fisheries Directorate of the Isle of Man Government on September 5th 2013 during which discussions concerning the role of the Isle of Man authorities were held.
Dialogue with respect to scientific aspects of the fishery was facilitated via email communications with Dr Pieter Jan Schön, Marine Fisheries Programme Leader, Agri-Food and Biosciences Institute by way of follow up from the site visit and prior to final scoring.
The Irish Whale and Dolphin Group and World Wide Fund for Nature were also contacted during the site visit, no submissions were received.
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4.4.2 Consultations Stakeholder issues No written submissions were received. Verbal representations were provided to the assessment team expressing a range of views, opinions and concerns. The team is of the view that matters raised have been adequately debated and addressed as a part of the scoring process for this fishery, and that none of the issues raised, therefore, require separate attention beyond that represented in this report. Interview Programme Following the collation of general information on the fishery, a number of meetings with key stakeholders were scheduled by the team to fill in information gaps and to explore and discuss areas of concern. Meetings were held as follows: Table 4.1: Interview Programme Name Position Organisation Mr Alan McCulla Chief Executive Officer ANIFPO, NIPSG Mr Brian Cunningham Managing Director Cloughmore Shellfish Ltd Mr Comgall Milligan Director C&O Milligan (Processors) Mr Paddy Campbell Sea fisheries policy manager DARD Mr Greg Griffiths Deputy Chief Fisheries Officer DARD Mr Andrew Orr Skipper FV Havilah NIPSG Mr Stephen McCulloch Skipper FV Stephanie M NIPSG Ms Karen McHarg Director of Fisheries Fisheries Directorate, IoM Government Dr Peter Duncan Scientific Advisor Fisheries Directorate, IoM Government Mr Colin Eastwood Chief Fisheries Protection Fisheries Directorate, IoM Officer Government Source: FCI assessment team Summary of Information Obtained
Meeting with Mr Paddy Campbell and Mr Greg Griffiths, DARD
Landings – Recording of Data
» How data was recorded and collected – (Confirmed list of Data DART will supply) » If discarded catches were recorded » Introduction of electronic log books » Recording of any slippage » Query relating to possible landings in Isle of Man - couldn’t handle such big boats » Clyde – To far for boats and stringent checks - Tank dipping
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Compliance enforcement
» Details of the ports used to land catches, what port authority’s checks are in place. » The number of checks made in 2012 - what percentage were Irish Sea fisheries/ Celtic Sea Fisheries » Appeals process- Introduction of fines system » CCTV – Scottish pelagic trial taking place at present » Royal navy have right to board any sea vessels » Query if the DART fisheries department was every auditing to check resources were sufficient – this took place 18th/19th January this year. Audit was fair – generally good
Management
» Management plan is in place – confirmation - stage of planning required from PJS » Process of re-evaluating the management plan was discussed » NGO involvement in management process – Meetings take place in October with invited Stakeholders
Quota
» The history of Skiff fishery quota and reduction » DARD do not get involved with quota swaps, donations or purchases, this is done between the fisheries » Quota decision is made in December annually
Meeting with Mr. Comgal Milligan (C&O Milligan – Fish Processors)
» History of C&O Milligan business » Relationship with the fishery » How catch is split between the 3 main processors » Bi-Catch issues – how it is dealt with and volume of other species » Where the fish he processes come from – Query about Clyde herring was this ever and issue » Difficulty selling non MSC certified fish – restricted market - doors closed to him as no MSC stock to sell » The anticipated timeline was discussed
Meeting with Mr Brian Cunningham, Cloughmore Shellfish. Discussion took place on;
» History of the Mourne Inshore fisheries » Reasons behind the reduction in quota from 100 tonnes to 30 tonnes » Question if Inshore fisheries should be MSC certified – fact finding mission for other fishermen
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Meeting with skippers onboard FV Havilah – Mr Andrew Orr, Mr Stephen McCulloch
» Discussion took place about the abundance of Spratt in the Irish sea at present, eating the cod roe » Skippers were asked how they make the decision to land at a particular port – Weather, catch size, processing all factors in this decision. » Enforcement & monitoring was discussed – how often they were boarded, by whom and inspection type » Level of Bi Catch if any » Any instances of catching Basking Sharks or Minke Whales – None in 30 years of fishing haven’t seen any in the nets » Tolerance levels of estimated catches and landings were discussed what percentage of tolerance they have to work to. » Suggestion of CCTV on board to cut out paperwork as has been trialled in Scotland – Skippers both feel it would be more hassle than it’s worth » Sea Bed Damage – Discussion took place regarding clump weights on nets, damage to sea bed not an issue as they have sensors on the nets and years of experience
Conference call with Isle of Man fisheries Directorate staff 1. Impending legislation in the Isle of Man may affect commercial fisheries operation in Manx waters 2. Establishment of access rights may cause difficulty for IoM authority in their quest to develop offshore renewable energy in Manx waters 3. IoM authority is not sufficiently recognized/involved in the management of the stock that spawns in its waters. They only receive notice and/or invitation to meetings concerning the stock at the last minute and are frequently overlooked. 4. IoM fishers no longer have a direct interest in the fishery – the size of fish are generally not suitable for Manx smokeries and the fishing season is too short causing a glut of fish and raw material shortage for the smoking sector on IoM. 5. 5. IoM have implemented the herring closure in its waters since 1973 and this has proved instrumental on the current apparent recovery of the stock. However the closed are was once much greater but has now shrunk back to an area within IoM territorial sea. 6. NIPSG vessels respect the seasonal/area closures. 7. The IoM receives no rent from the fishery that operates largely within its waters – this situation does not reflect the fact that they are significant custodians of the resource. 8. The main concerns for the authority are lack of involvement in the decision making process for the fishery. 9. There is good compliance now for the vessels in the certification – vessels do not come within 3nm-closed area and this is verified by 2 hourly poll patterns on the VMS. 10. IoM Government would like to be more involved in the decision making process
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4.4.3 Evaluation Techniques Public Consultation A total of 34 stakeholder individuals and organisations having relevant interest in the assessment were identified and consulted during this assessment. The interest of others not appearing on this list was solicited through the postings on the MSC website, and by advertising in the Irish Skipper publication These were felt to be the most appropriate media for making these public announcements as the Irish Skipper publication has significant readership / uptake in the primary stakeholder locations for this fishery and the processes used on the MSC website for tracking and announcing the various stages of the assessment as it progresses - from Full Announcement through to Certification - form an ideal tool through which to channel stakeholder interest and keep them abreast of the important stages of the assessment as a whole. Initial approaches were made by email and followed up by phone. Issues raised during correspondence were investigated during research and information gathering activities, and during interviews. Most stakeholders contacted during this exercise either indicated that they had no direct interest in this fishery assessment, or that they had no particular cause for concern with regard to its assessment to the MSC standard. Process The MSC is dedicated to promoting “well-managed” and “sustainable” fisheries, and the MSC initiative focuses on identifying such fisheries through means of independent third-party assessments and certification. Once certified, fisheries are awarded the opportunity to utilise an MSC promoted eco-label to gain economic advantages in the marketplace. Through certification and eco-labelling the MSC works to promote and encourage better management of world fisheries, many of which have been suggested to suffer from poor management. The MSC Principles and Criteria for Sustainable Fisheries form the standard against which the fishery is assessed and are organised in terms of three principles: » MSC Principle 1 - Resource Sustainability » MSC Principle 2 - Ecosystem Sustainability » MSC Principle 3 - Management Systems A fuller description of the MSC Principles and Criteria and a graphical representation of the assessment tree is presented as Appendix 1a to this report. The MSC Principles and Criteria provide the overall requirements necessary for certification of a sustainably managed fishery. To facilitate assessment of any given fishery against this standard, these Criteria are further split into Sub-criteria. Sub-criteria represent separate areas of important information (e.g. Sub-criterion 1.1.1. requires a sufficient level of information on the target species and stock, 1.1.2 requires information on the effects of the fishery on the stock and so on). These Sub-criteria, therefore, provide a detailed checklist of factors necessary to meet the MSC Criteria in the same way as the Criteria provide the factors necessary to meet each Principle. Below each Sub-criterion, individual ‘Performance Indicators’ (PIs) are identified. It is at this level that the performance of the fishery is measured. Altogether, assessment of this fishery against the MSC standard is achieved through measurement of 31 Performance Indicators. The Principles and their supporting Criteria, Sub-criteria and Performance Indicators that have been used by the assessment team to assess this fishery are incorporated into the scoring sheets (Appendix 1.1).
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Scoring of the attributes of this fishery against the MSC Principles and Criteria involves the following process: » Decision to use the MSC Default Assessment Tree contained within the MSC Certification Requirements (Annex CB) » Description of the justification as to why a particular score has been given to each sub- criterion » Allocation of a score (out of 100) to each Performance Indicator In order to make the assessment process as clear and transparent as possible, the Scoring Guideposts are presented in the scoring table and describe the level of performance necessary to achieve 100 (represents the level of performance for a Performance Indicator that would be expected in a theoretically ‘perfect’ fishery), 80 (defines the unconditional pass mark for a Performance Indicator for that type of fishery), and 60 (defines the minimum, conditional pass mark for each Performance Indicator for that type of fishery). The Assessment Tree and Scoring Guideposts for the Northern Ireland Pelagic Sustainability Group (NIPSG) Irish Sea Herring Fishery are shown as Appendix 1.1 to this report. Scoring outcomes There are two, coupled, scoring requirements that constitute the Marine Stewardship Council’s minimum threshold for a sustainable fishery: » The fishery must obtain a score of 80 or more for each of the MSC’s three Principles, based on the weighted average score for all Criteria and Sub-criteria under each Principle. » The fishery must obtain a score of 60 or more for each Performance Indicator. A score below 80 at the Principle level or 60 for any individual Performance Indicator would represent a level of performance that causes the fishery to automatically fail the assessment. A score of 80 or above for all three Principles results in a pass.
4.4.4 RBF Use Possible use of the RBF was announced at an early stage in the assessment process. In the assessment it became apparent that the RBF was not required for evaluating any P2 outcome indicator. Table 4.4.1 identifies scoring elements and reviews whether or not they are mian.no- main species and data deficient or not.
Table 4.4.1 Scoring elements Component Scoring elements Main/not main Data-deficient or not 1.1.1 Herring in VIIa N of 52 Target stock Not DD degrees 30 minutes 2.1.1 Northeast Atlantic Not main Not DD mackerel 2.1.1 Horse mackerel Not main Not DD
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Stakeholder Comments on Use of RBF None received. RBF Consultation Process Summary No commentary received. Summary of Information Obtained N/A Summary of Activities and Components Discussed / Evaluated N/A Process of Choosing Most Vulnerable Scoring Element N/A
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5. Traceability
5.1 Eligibility Date The Target Eligibility Date for this fishery will be the 1st November 2013. This means that any fish 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 meets with the client’s wishes, for commercial reasons, for the date to be set at the earliest point at which the Certification Requirements allow. The measures taken by the client to account for risks within the traceability of the fishery – and therefore generating confidence in the use of this date for target eligibility – are detailed in the rest of this section.
5.2 Traceability within the Fishery
5.2.1 Description of Tracking, Tracing and Segregation Systems within the Fishery and Management systems in place relating to Traceability Traceability up to the point of first landing has been scrutinised as part of this assessment and the positive results reflect that the systems in place are deemed adequate to ensure fish is caught in a legal manner and is accurately recorded. The report and assessment trees describe these systems in more detail, but briefly traceability can be verified by: » no transshipment; » the fishery is highly restricted spatially and seasonally » accurate reporting – log books and sales notes (regularly inspected and cross- checked); » verified landings data (including data on other retained species) are used for official monitoring of quota up-take and national statistics; » a high level and sophisticated system of at-sea monitoring, control and surveillance, including routine boarding and inspection, surveillance aircraft planes, VMS; and electronic logbooks. » Good cooperation between EU regulatory and enforcement authorities and the Isle of Man authorities » no immunity from prosecution of infringements in other jurisdictions; » reporting prior to landing with limited tolerance; » an appropriate level of inspection of landings prior to unloading. Officially calibrated weighing systems of landing. Periodic inspection of the entire unloading process. The above is considered sufficient to ensure fish and fish products invoiced as such by the fishery originate from within the evaluated fishery and no specific risk factors have been identified.
5.2.2 Evaluation of Risk of Vessels Fishing Outside of UoC There is no elevated risk of vessels fishing outside the UoC. The fishery is spatially restricted and occurs in a restricted season, according to tight controls – not least quota control. Vessels landing other species, or from other areas could not land these as Irish Sea herring.
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5.2.3 Risk of Substitution of Mixing Certified / Non-Certified Catch prior to point of landing There is a low risk of substitution of mixing of certified and non-certified catch. Other herring fisheries such as West of Scotland and Celtic Sea herring are also already certified. Vessels may have small entitlements to herring in the nearby Clyde fishery. However the area of capture for all landed fish can be verified through VMS. Vessels are not permitted to engage in both Irish Sea herring and Clyde herring fisheries on the same trip without in port checks being made at Campbeltown (Scotland) to confirm volumes already aboard. Landing controls are such that the veracity of the stated species and origin of the landed catch can be assured. The Chain of Custody audit and surveillance process will address risks of substitution taking place later in the supply chain.
5.2.4 At-Sea Processing No at sea processing takes place in this fishery. The extent of the fishery certification is the landing of the fresh, chilled product (RSW on board storage) at ports where registration of landings is carried out and discharged weights are registered.
5.2.5 Trans-Shipment No transhipment takes place in this fishery.
5.2.6 Robustness of management systems relating to traceability The management system supporting traceability comprises: » mandatory use of tamper proof VMS on all vessels that can be queried retrospectively » use of electronic log books for reporting » in port verification of volumes of fish held in RSW tanks prior to switching to any other fishery » mandatory use of sales notes to verify purchase of catch » all weighing is carried out using calibrated factory scales » mandatory factory recording allow for cross checking of delivery intake and declared landings » prior notification of landings » well-developed MCS in Northern Ireland and EU waters » Inspection of the Northern Ireland MCS system by EFCA The systems in place are comprehensive and mandatory. They are subject to periodic scrutiny and have been found to be enforced consistently leading to robust system that supports full traceability for landed product.
5.3 Eligibility to Enter Further Chains of Custody Only Irish Sea herring caught in Area VIIa North of 52°30’ caught in the manner defined in the Unit of Certification (Section 3.1) under restrictions detailed throughout the body of the final Public Certification Report for this fishery shall be eligible to enter the Chain of Custody. Chain of Custody should commence following the first point of landing, at which point the product shall be eligible to carry the MSC logo (under restrictions imposed by the MSC Chain of Custody standard). There are no restrictions on the fully certified product entering further chains of custody. The Northern Ireland Pelagic Sustainability Group (NIPSG) does not require
53 version 2.0 (01/06/13) Food Certification International Final Report Northern Ireland Pelagic Sustainability Group (NIPSG) Irish Sea Herring Fishery its own chain of custody certificate. Landings emanating from and comprising catches made by the vessels indicated below are eligible to enter further Chains of Custody:
Name Vessel Reg. No. Havilah N200 Stephanie M N265 Voyager N905
5.3.1 Eligible points of landing Although landings are typically into Northern Irish ports (Warrenpoint, Ardglass, Kilkeel), vessels covered by this assessment are entitled land catches from this fishery into registered ports in other EU countries. In particular the Voyaged may land catches into Killybegs in Ireland, it being too large to enter either Ardglass or Kilkeel. All landings made to other EU ports are subject to the same scrutiny and reporting procedures and there is a well-established mechanism to enable port-of-landing authorities to report the landing to the relevant authorities in a timely fashion. There are no further restrictions defining port of landing, over and above those stated in national fishing regulations (for example vessels must land to registered ports). There is no requirement for the vessels to land at ports named in this report. There are no specific risk factors after the point of landing which need to be highlighted or that may influence chain of custody assessments.
5.3.2 Parties eligible to use the fishery certificate Only UK registered pelagic RSW trawlers who are members of NIPSG may use this certificate.
5.4 Eligibility of Inseparable or Practically Inseparable (IPI) stock(s) to Enter Further Chains of Custody The Celtic Sea and Irish Sea stocks are currently practically inseparable, Celtic Sea herring are likely to exceed 2% of the Irish Sea catch and Celtic Sea herring has been MSC certified (CSHMAC Celtic Sea Herring Trawl Fishery). The current harvest strategy is to manage the Irish Sea as a single unit, while recognizing some degree of mixing among spawning components. Thus the mixing is taken into account as part of the harvest strategy, and is essentially addressed as an uncertainty in the assessment and in setting the harvest control rule. The certification label will relate to the management unit that is scored. Thus some of the Irish Sea herring that may ultimately bear the MSC label will have from a different spawning component. This situation is the same for most other certified herring fisheries and all herring landed from the fishery is entitled to bear the MSC label.
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6. Evaluation Results
6.1 Principle Level Scores Table 6.1.1: Final Principle Scores – Irish Sea herring
Principle Score
Principle 1 – Target Species 84.4 Principle 2 - Ecosystem 89.0 Principle 3 – Management System 81.37 Source: FCI assessment team
6.2 Summary of Scores Table 6.2.1 Scores by performance indicator for Irish Sea herring assessment
Component PI Performance Indicator (PI) No. Score
Outcome 1.1.1 Stock status 100 1.1.2 Reference points 75 1.1.3 Stock rebuilding NA Management 1.2.1 Harvest strategy 85 1.2.2 Harvest control rules & tools 75 1.2.3 Information & monitoring 80 1.2.4 Assessment of stock status 85 Retained 2.1.1 Outcome 100 species 2.1.2 Management 100 2.1.3 Information 90 Bycatch species 2.2.1 Outcome 100 2.2.2 Management 90 2.2.3 Information 80 ETP species 2.3.1 Outcome 80 2.3.2 Management 80 2.3.3 Information 80 Habitats 2.4.1 Outcome 100 2.4.2 Management 90 2.4.3 Information 95 Ecosystem 2.5.1 Outcome 80 2.5.2 Management 90 2.5.3 Information 80 Governance and 3.1.1 Legal & customary framework 95 policy 3.1.2 Consultation, roles & responsibilities 80 3.1.3 Long term objectives 100 3.1.4 Incentives for sustainable fishing 80 3.2.1 Fishery specific objectives 60
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Component PI Performance Indicator (PI) No. Score
3.2.2 Decision making processes 80 Fishery specific 3.2.3 Compliance & enforcement 80 management system 3.2.4 Research plan 80 3.2.5 Management performance evaluation 70 Source: FCI assessment team
6.3 Summary of Conditions
Table 6.3.1: Summary of Conditions Condition Condition Performance Related to number Indicator previously raised condition? (Y/N/ N/A) Limit and target reference points are N/A 1.1.2 1 appropriate for the stock There are well defined and effective N/A 1.2.2 2 harvest control rules in place Short and long term objectives which are N/A consistent with outcomes expressed by 3.2.1 3 MSC Principles 1 & 2 are explicit within the fishery’s management system The fishery specific management system N/A 4 is subject to regular internal and 3.2.5 occasional external review. Source: FCI assessment team
6.3.1 Recommendations Recommendation 1. To support the inclusion of ecosystem considerations in the definition of Reference Points for the management of herring.
Target reference points as established within the ICES FMSY framework do not take into account the ecological role of the stock in the ecosystem. However, the high abundance and importance of herring in the Irish Sea ecosystem suggest that management of this stock should be regarded in the framework of ecosystem approach to fisheries management currently pursued in the EC directives. The assessment team recommends that the NIPSG support the definition of reference points for herring which more explicitly take into account the ecological role of the stock in the ecosystem, because the relevant role played by the herring in the Irish Sea as a significant component of the pelagic community deserves that ecosystem considerations are gradually taken into account. This recommendation is considered to be aligned with responsive management inspiring MSC principles and with the ecosystem approach to fisheries management currently pursued in the EC directives.
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6.4 Determination, Formal Conclusion and Agreement The fishery attained a score of 80 or more against each of the MSC Principles and did not score less than 60 against any MSC Criteria. It is therefore determined that the Northern Ireland Pelagic Sustainability Group (NIPSG) Irish Sea Herring Fishery should be certified according to the Marine Stewardship Council Principles and Criteria for Sustainable Fisheries. Following this decision by the assessment team, and review by stakeholders and peer- reviewers, the determination will be presented to FCI’s decision-making entity that this fishery has passed its assessment and should be certified.
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7. References » Begg G.A., Friedland K.D. and Pearce JB. 1999. Stock identification and its role in stock assessment and fisheries management: an overview. Fisheries Research, 43:1– 8. » Berrow, S., O’Neill, M. and Brogan, D. 1998. Discarding practices and marine mammal bycatch in the Celtic Sea herring fishery. Proceedings of the Royal Irish Academy of Biology and Environment 1: 1-8. » Blanchard, J.L., Dulvy N.K., Ellis, J.E., Jennings S., Pinnegar, J.K., Tidd, A., and Kell, L.T. 2005. Do climate and fishing influence size‐based indicators of Celtic Sea fish community structure? ICES Journal of Marine Science, 62: 405–411. » Borges, L., Rogan, E., and Officer, R. 2005. Discarding by the demersal fishery in the waters around Ireland. Fisheries Research, 76: 1–13. » Brander, K. 1998. Effects of environmental variability on growth and recruitment in cod (Gadus morhua) using a comparative approach. Oceanologica Acta, 23: 485 – 496. » Brander K. M. (1977). Irish Sea Fisheries Management; a review. Laboratory Leaflet number 36. MAFF Lowestoft. » Brophy, D. and Danilowicz, B. 2002. Tracing populations of Atlantic herring (Clupea harengus L.) in the Irish and Celtic Seas using otolith microstructure. ICES Journal of Marine Science, 59: 1305-1313. » Burke, N., Brophy, D., Schön, P-J., and King, P. A. 2009. Temporal trends in stock origin and abundance of juvenile herring (Clupea harengus) in the Irish Sea. ICES Journal of Marine Science, 66: 1749–1753. » DEFRA et al (2013). FISH QUOTAS. UK MANAGEMENT RULES (2013). Issued by Department for Environment, Food and Rural Affairs, Marine Management Organisation, Marine Scotland, Department of Agriculture and Rural Development Northern Ireland, Welsh Government. » Dickey-Collas, M., Nash, R.D.M. and Brown, J. 2001. The location of spawning of Irish Sea herring (Clupea harengus). J. Mar. Biol. Assoc., UK., 81: 713-714. » Hammond, PS, etal, 2002. Abundance of harbour porpoise and other cetaceans in the North Sea and adjacent waters. Journal of Applied Ecology 2002 39, 361–376 » ICES 1994. Report of the study group on herring assessment and biology in the Irish Sea and adjacent waters. ICES C.M. 1994/H:5. 69pp. » ICES 2010. Life-cycle spatial patterns of small pelagic fish in the Northeast Atlantic. ICES Cooperative Research Report no.306.October 2010. » ICES. 2010. Report of the Working Group on Methods of Fish Stock Assessment (WGMG), 20–29 October 2009, Nantes, France. ICES CM 2009/RMC:12. 85 pp. » ICES. 2012. Report of the Benchmark Workshop on Pelagic Stocks (WKPELA 2012), 13–17 February 2012, Copenhagen, Denmark. ICES CM 2012/ACOM:47. 572 pp. » ICES 2012. Horse mackerel (Trachurus trachurus) in Divisions IIa, IVa, Vb, VIa, VIIa-c, e-k, and Subarea VIII (Western stock) ICES Advice 2013 Book 9. » ICES. 2012. Report of the Working Group on Widely Distributed Stocks (WGWIDE). Lowestoft, 21–27 August 2012. ICES C.M. 2012 / ACOM: 15
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» ICES. 2013a. Report of the Herring Assessment Working Group for the Area South of 62 N (HAWG), 12-21 March 2013, ICES Headquarters, Copenhagen. ICES CM 2013/ACOM:06. 1270pp. » ICES. 2013b. Herring in Division VIIa North of 52º30’N (Irish Sea). Book 5.4.14 Advice June 2013 » Kiely, O., Ligard, D., McKibben, M., Connolly, N. and Baines, M., 2000. Grey Seals : Status and Monitoring in the Irish and Celtic Seas Coastal Resources Centre, National University Of Ireland, Cork. » Lees, K. and Mackinson, S., 2007. An Ecopath model of the Irish Sea: ecosystems properties and sensitivity analysis. Sci. Ser. Tech Rep., Cefas Lowestoft, 138: 49pp. » Molloy, J.P., Barnwall, E. and Morrison, J. 1993. Herring tagging experiments around Ireland in 1991. Dpt. of Marine. Dublin. Fish. Leaf. No. 154. 1993. » Morrison, J.A. and Bruce, T. 1981. Scottish herring tagging experiments in the Firth of Clyde 1975-1979 and evidence of affinity between Clyde herring and those in adjacent areas. ICES CM 1981/H:53. » Pierce G, 2001. Pelagic fisheries in Scotland (UK) and Galicia (Spain): observer studies to collect fishery data and monitor by-catches. At www.abdn.ac.uk/marfish/marmamm/pelagic.htm. » Pinnegar J.K., Jennings, S., O’Brien, C.M. & Polunin N.V.C. (2002) Long‐term changes in the trophic level of the Celtic Sea fish community and fish market price distribution. Journal of Applied Ecology, 39: 377–390. » Pinnegar, J.K., Trenkel, V.M., Tidd, A.N., Dawson, W.A. and Du Buit, M.H. (2003). Does diet in Celtic Sea fishes reflect prey availability? Journal of Fish Biology, 63 (Supplement A): 197–212. » SCANS - II– see www.smru.st-andrews.ac.uk and http://biology.st- andrews.ac.uk/scans2/documents/issue9_Dec06.pdf » SEC (2007). Evaluation of Closed Area Schemes. Subgroup on Management of Stocks (SGMOS) of the Scientific, technical and Economic Committee for Fisheries (STECF) (SGMOS-07-03). ISPRA » Trenkel, V.M., Pinnegar, J.K., Dawson, W.A., Du Buit, M.H. and Tidd, A.N., (2005) Spatial and temporal predation patterns in the Celtic Sea. Marine Ecology‐Progress Series, 299: 257–268. » WGBYC 2011. Report of the Working Group on bycatch of protected species. ACOM:24 ICES 2011. » WGCSE (2009). Report of the Working Group Celtic Sea Ecosystems. ICES. » WGECO (2008). Report of the Working Group on Ecosystem effects of Fishing Activities. ICES CM 2008/ACOM:41 » WGECO (2010). Report of the Working Group on Ecosystem effects of Fishing Activities. ICES CM 2010/ACOM:23 » WGRED (2008). Report of the Working Group for Regional Ecosystem Description. ICES CM 2008/ACOM:47 » Wood J. D. & Hopper A.G (1984). A report on the UK herring fisheries in the 1980s. Seafish Industry Authority Development Unit. Technical Report no. 245.
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Appendix 1. Scoring & Rationale
Appendix 1a – MSC Principles & Criteria
Figure A1 – Graphic of MSC Principles and Criteria
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Below is a much-simplified summary of the MSC Principles and Criteria, to be used for over- view purposes only. For a fuller description, including scoring guideposts under each Performance Indicator, reference should be made to the full assessment tree, complete with scores and justification, contained in Appendix 1.1 of this report. Alternately a fuller description of the MSC Principles and Criteria can be obtained from the MSC website (www.msc.org). Principle 1 A fishery must be conducted in a manner that does not lead to over-fishing or depletion of the exploited populations and, for those populations that are depleted, the fishery must be conducted in a manner that demonstrably leads to their recovery. Intent: The intent of this Principle is to ensure that the productive capacities of resources are maintained at high levels and are not sacrificed in favour of short-term interests. Thus, exploited populations would be maintained at high levels of abundance designed to retain their productivity, provide margins of safety for error and uncertainty, and restore and retain their capacities for yields over the long term. Status » The stock is at a level that maintains high productivity and has a low probability of recruitment overfishing. » Limit and target reference points are appropriate for the stock (or some measure or surrogate with similar intent or outcome). » Where the stock is depleted, there is evidence of stock rebuilding and rebuilding strategies are in place with reasonable expectation that they will succeed. Harvest strategy / management » There is a robust and precautionary harvest strategy in place, which is responsive to the state of the stock and is designed to achieve stock management objectives. » There are well defined and effective harvest control rules in place that endeavour to maintain stocks at target levels. » Sufficient relevant information related to stock structure, stock productivity, fleet composition and other data is available to support the harvest strategy. » The stock assessment is appropriate for the stock and for the harvest control rule, takes into account uncertainty, and is evaluating stock status relative to reference points.
Principle 2 Fishing operations should allow for the maintenance of the structure, productivity, function and diversity of the ecosystem (including habitat and associated dependent and ecologically related species) on which the fishery depends Intent: The intent of this Principle is to encourage the management of fisheries from an ecosystem perspective under a system designed to assess and restrain the impacts of the fishery on the ecosystem. Retained species / Bycatch / ETP species » Main species are highly likely to be within biologically based limits or if outside the limits there is a full strategy of demonstrably effective management measures.
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» There is a strategy in place for managing these species that is designed to ensure the fishery does not pose a risk of serious or irreversible harm to retained species. » Information is sufficient to quantitatively estimate outcome status and support a full strategy to manage main retained / bycatch and ETP species.
Habitat & Ecosystem » The fishery does not cause serious or irreversible harm to habitat or ecosystem structure and function, considered on a regional or bioregional basis. » There is a strategy and measures in place that is designed to ensure the fishery does not pose a risk of serious or irreversible harm to habitat types. » The nature, distribution and vulnerability of all main habitat types and ecosystem functions in the fishery area are known at a level of detail relevant to the scale and intensity of the fishery and there is reliable information on the spatial extent, timing and location of use of the fishing gear.
Principle 3 The fishery is subject to an effective management system that respects local, national and international laws and standards and incorporates institutional and operational frameworks that require use of the resource to be responsible and sustainable. Intent: The intent of this principle is to ensure that there is an institutional and operational framework for implementing Principles 1 and 2, appropriate to the size and scale of the fishery. Governance and policy » The management system exists within an appropriate and effective legal and/or customary framework that is capable of delivering sustainable fisheries and observes the legal & customary rights of people and incorporates an appropriate dispute resolution framework. » Functions, roles and responsibilities of organisations and individuals involved in the management process are explicitly defined and well understood. The management system includes consultation processes. » The management policy has clear long-term objectives, incorporates the precautionary approach and does not operate with subsidies that contribute to unsustainable fishing. Fishery specific management system » Short and long term objectives are explicit within the fishery’s management system. » Decision-making processes respond to relevant research, monitoring, evaluation and consultation, in a transparent, timely and adaptive manner. » A monitoring, control and surveillance system has been implemented. Sanctions to deal with non-compliance exist and there is no evidence of systematic non- compliance. » A research plan provides the management system with reliable and timely information and results are disseminated to all interested parties in a timely fashion.
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Appendix 1.1 Performance Indicator Scores and Rationale Evaluation Table for PI 1.1.1
The stock is at a level which maintains high productivity and has a low PI 1.1.1 probability of recruitment overfishing
Scoring Issue SG 60 SG 80 SG 100
a It is likely that the It is highly likely that There is a high degree of stock is above the the stock is above the certainty that the stock is above point where point where recruitment the point where recruitment recruitment would be would be impaired. would be impaired.
Guidepost impaired.
Met? Y Yes Yes
The spawning-stock biomass has been above Blim since 2003. Fishing mortality has
been significantly reduced since 2003. Recruitment is increasing and estimated above the average of the time-series since 2006 (2004 year class). Although it is not clear that the current limit reference point is sufficiently precautionary (see PI 1.1.2), the current biomass is well above any Blim candidate. Therefore, at current high stock levels, there is a high degree of certainty that recruitment is not impaired by low SSB, meeting the SG100.
Justification
b The stock is at or There is a high degree of fluctuating around its certainty that the stock has target reference point. been fluctuating around its target reference point, or has been above its target reference
Guidepost point, over recent years.
Met? Yes Yes
The spawning-stock biomass has been above MSY Btrigger since 2006 and is likely to be above the long term median SSB (BMSY). Fishing mortality has decreased since 2003 to the lowest in the time-series and is now around FMSY. Recruitment is increasing and estimated above the average of the time-series since 2006 (2004 year class).
Justification
» ICES. 2012. Report of the Benchmark Workshop on Pelagic Stocks (WKPELA 2012), 13–17 February 2012, Copenhagen, Denmark. ICES CM 2012/ACOM:47. 572 pp. » ICES. 2013a. Report of the Herring Assessment Working Group for the Area References South of 62 N (HAWG), 12-21 March 2013, ICES Headquarters, Copenhagen. ICES CM 2013/ACOM:06. 1270pp. » ICES. 2013b. Herring in Division VIIa North of 52º30’N (Irish Sea). Book 5.4.14 Advice June 2013
Stock Status relative to Reference Points
Type of reference Value of reference Current stock status relative to point point reference point
Target >Btrigger 9500 t SSB SSB2014/Btrigger =22864/9500= 2.4
reference -1 FMSY 0.26 year F2013/FMSY = 0.22/0.26 = 0.85 point 17445 t SSB SSB2014/BMSY =22864/17445= 1.3
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The stock is at a level which maintains high productivity and has a low PI 1.1.1 probability of recruitment overfishing
BMSY (Analytically determined, but not used)
Limit Blim 6000 t SSB SSB2014 = 22864/6000 = 3.8 reference point
OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 1.1.2
PI 1.1.2 Limit and target reference points are appropriate for the stock
Scoring Issue SG 60 SG 80 SG 100
a Generic limit and Reference points are target reference points appropriate for the are based on stock and can be justifiable and estimated. reasonable practice appropriate for the
Guidepost species category.
Met? Yes Yes
Reference points are based on fishing mortality and spawning stock biomass, which have been estimated from the stock assessment with appropriate assumptions about the stock recruitment relationship. These are standard indicators for stock and fishery status and appropriate for all herring stocks. SG60 and SG80 are met.
Justification
b The limit reference The limit reference point is set point is set above the above the level at which there level at which there is is an appreciable risk of an appreciable risk of impairing reproductive capacity impairing reproductive following consideration of
Guidepost capacity. precautionary issues.
Met? No No
The limit reference point for biomass has been set to the lowest observed SSB for the previous ICA assessment. This is a standard Bloss approach for ICES where there is no clear stock recruitment relationship, and no evidence that recruitment has been impaired. It should be noted that for the new stock assessment, some SSB values are estimated now to be below this point. While Bloss is reasonable practice if no recruitment impairment has been observed, it is not particularly precautionary because it depends upon the lowest number of observations in the time series (usually a single point). Therefore this does not meet SG100. In this case, however, the assessment shows a decrease in recruitment in those periods where the SSB was low. This did not prevent recovery, and could also indicate a change in variance. The recent benchmark assessment (ICES 2012) indicated that a stock recruitment relationship could be fitted to the available data and analytical estimates of reference points obtained. These results indicate that default reference points applying the level of precaution that MSC requires might be higher than the limit reference point currently being used. Because the current limit reference point is not justified and has not been demonstrated to apply the level of precaution consistent with the MSC standard,
Justification SG80 has not been met.
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PI 1.1.2 Limit and target reference points are appropriate for the stock
c The target reference The target reference point is point is such that the such that the stock is stock is maintained at a maintained at a level consistent level consistent with with BMSY or some measure or BMSY or some measure surrogate with similar intent or or surrogate with outcome, or a higher level, and similar intent or takes into account relevant outcome. precautionary issues such as the ecological role of the stock
Guidepost with a high degree of certainty.
Met? Yes No
The MSY Btrigger has been set at a precautionary level above Blim (Btrigger = 1.58*Blim) based on previous assessments and expert judgement. This value is cited as provisional. Given that Blim may not be adequately precautionary to meet the MSC standard, this value is set too low to be an appropriate target. However, being a trigger point, it forms part of the harvest control rule and defines a lower bound for the BMSY region rather than the target itself. BMSY as estimated in the recent benchmark assessment is in the region of 12-29,000t, depending on assumptions used for the stock recruitment relationship. The long-term target biomass should result from the application of the harvest
control rule, and in particular the target fishing mortality which is set at FMSY. This is particularly appropriate for complex meta-population stocks such as herring caught in the Irish Sea. Applying the HCR, the resulting long-term biomass is likely to be above the Btrigger level.
Justification
d For key low trophic level stocks, the target reference point takes into account the ecological role of the
uidepost
G stock.
Met? Not relevant
Irish Sea herring does not meet any of the three sub-criterion in GCB 2.3.13 (see Section 3.3), and therefore is not a key low trophic level stock as defined.
Justification
» ICES. 2012. Report of the Benchmark Workshop on Pelagic Stocks (WKPELA 2012), 13–17 February 2012, Copenhagen, Denmark. ICES CM 2012/ACOM:47. 572 pp. » ICES. 2013a. Report of the Herring Assessment Working Group for the Area References South of 62 N (HAWG), 12-21 March 2013, ICES Headquarters, Copenhagen. ICES CM 2013/ACOM:06. 1270pp. » ICES. 2013b. Herring in Division VIIa North of 52º30’N (Irish Sea). Book 5.4.14 Advice June 2013
OVERALL PERFORMANCE INDICATOR SCORE: 75
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PI 1.1.2 Limit and target reference points are appropriate for the stock
CONDITION NUMBER (if relevant): 1
Evaluation Table for PI 1.1.3
Where the stock is depleted, there is evidence of stock rebuilding within a PI 1.1.3 specified timeframe
The stock is no depleted, and therefore this performance issue is not scored.
Justification
ICES 2013b. Herring in Division VIIa North of 52º30’N (Irish Sea) Book 5.4.14 References Advice June 2013.
OVERALL PERFORMANCE INDICATOR SCORE: NA
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 1.2.1
PI 1.2.1 There is a robust and precautionary harvest strategy in place
Scoring Issue SG 60 SG 80 SG 100
a The harvest strategy is The harvest strategy is The harvest strategy is expected to achieve responsive to the state responsive to the state of the stock management of the stock and the stock and is designed to objectives reflected in elements of the harvest achieve stock management the target and limit strategy work together objectives reflected in the target reference points. towards achieving and limit reference points. management objectives reflected in the target and limit
Guidepost reference points.
Met? Yes Yes No
Components of the harvest strategy consist of a limited entry (a pelagic license), a TAC and seasonal closed areas. The seasonal closed areas are Morne Area 1 (21st September – 31st December) and Manx Area 2 (21st September - 15th November) (Council Regulation No. 2723/1999). In addition, there are standard mesh size and technical conservation measures. The harvest strategy is responsive to the state of the stock both in terms of setting annual TACs in response to the stock assessment. In addition, the closed areas were implemented to reduce fishing pressure on spawning components and juveniles. The potential mixing with the Celtic spawning components is taken into account in setting the TAC and other management actions. Therefore, management has acted to protect or reduce the impact on components of the population. These harvest strategy elements have successfully worked together to achieved management objectives. This meets SG80. Although the objectives are being met, these have been implemented in response to failure of the previous strategy. Some parts of this previous strategy still exist. There remains over-capacity generally in the pelagic sector, although this has been substantially reduced. The main response to perceived overfishing has been to reduce the overall harvest level (TAC), but this falls short of a design, which might, for example, include planned responses to and consideration of factors such as climate change. Because there has been no clear design procedure, so SG100 is not met. Adjacent Stock Considerations
The Celtic Sea herring stock is managed as a separate unit with its own harvest strategy, objectives, and reference points. The stock is not overexploited and the stock is in a good state. The size of the Irish Sea catch which could be allocated to the Celtic Sea is small compared to the Celtic Sea TAC (maximum c. 6%). It does not yet form part of a design for the harvest strategy, which would contribute to
Justification SG100.
b The harvest strategy is The harvest strategy The performance of the harvest likely to work based on may not have been strategy has been fully prior experience or fully tested but evaluated and evidence exists plausible argument. evidence exists that it to show that it is achieving its is achieving its objectives including being objectives. clearly able to maintain stocks
Guidepost at target levels.
Met? Yes Yes No
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PI 1.2.1 There is a robust and precautionary harvest strategy in place
Evidence exists that the harvest strategy is achieving its objectives. The primary objective was to rebuild the stock to MSY levels, which has been achieved since 2006. Currently, the fishing mortality is estimated to be around FMSY, which is being maintained. This clearly meets SG80. The performance of the harvest strategy has not yet been fully evaluated. Parts of the harvest strategy have not been implemented yet, notably a long term management plan is still under development. While evidence is available showing
that the stock has been successfully rebuilt, whether the stock will be maintained at an appropriate level has yet to be tested. SG100 is not met. Adjacent Stock Considerations There is evidence that the separate Celtic Sea harvest strategy is working, and
Justification there is no evidence of a negative effect from the Irish Sea fishery.
c Monitoring is in place that is expected to determine whether the harvest strategy is working.
Guidepost
Met? Yes
Monitoring is in place and can determine whether the overall harvest strategy is working. The overall stock is monitored by means of a stock assessment, based on good data coverage from fishing independent surveys and good catch monitoring (age, weight sampling). A critical issue for herring is maintenance of various spawning areas. This is being
monitored through acoustic surveys to ensure the fishery is not depleting any one area. In addition, the spawning component mixing and distribution is being re- evaluated. Adjacent Stock Considerations
Justification The Celtic Sea is fully monitored independently of the Irish Sea.
d The harvest strategy is periodically reviewed and improved as necessary.
Guidepost
Met? Yes
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PI 1.2.1 There is a robust and precautionary harvest strategy in place
ICES periodically reviews the harvest strategy and develops advice that can lead to improvement. The recent shift of overall EU strategy to a MSY based approach has helped improve this fishery’s performance. In addition, research is being undertaken on stock spawning components and their spatial distribution, which should eventually lead to improvements in the harvest strategy over time. Area closures are evidence of some improvement in this respect. Therefore, SG100 is met. Adjacent Stock Considerations
SGHERWAY/WESTHER conducted a review of stock structure and harvest strategy and concluded the division of stocks was appropriate as part of the current strategy, taking spawning components and adjacent stocks. As a result of this review, no changes were recommended. This programme was based on evaluation of all new research, some of which was conducted to address this issue, and
Justification available fisheries data.
» O’Sullivan, D., O’Keeffe, E., Berry, A., Tully, O. and Clarke, M. (2013) An Inventory of Irish Herring Spawning Grounds. Irish Fisheries Bulletin No. 42, 2013. June 2013. The Marine Institute, Fisheries Ecosystems Advisory Services, Rinville, Oranmore, Co. Galway. » ICES 2010. Report of the Study Group on the evaluation of assessment and management strategies of the western herring stocks (SGHERWAY), 14‐18 June 2010, Dublin, Ireland. ICES CM 2010/SSGSUE:08.194 pp. » ICES. 2012. Report of the Benchmark Workshop on Pelagic Stocks References (WKPELA 2012), 13–17 February 2012, Copenhagen, Denmark. ICES CM 2012/ACOM:47. 572 pp. » ICES. 2013a. Report of the Herring Assessment Working Group for the Area South of 62 N (HAWG), 12-21 March 2013, ICES Headquarters, Copenhagen. ICES CM 2013/ACOM:06. 1270pp. » ICES. 2013b. Herring in Division VIIa North of 52º30’N (Irish Sea). Book 5.4.14 Advice June 2013 » ICES 2013c. Herring in Divisions VIIa (South of 52°30’N) and VIIg,h,j,k (Celtic Sea and South of Ireland). Book 5.4.15 Advice June 2013.
OVERALL PERFORMANCE INDICATOR SCORE: 85
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 1.2.2
PI 1.2.2 There are well defined and effective harvest control rules in place
Scoring Issue SG 60 SG 80 SG 100
a Generally understood Well defined harvest harvest rules are in control rules are in place that are place that are consistent with the consistent with the harvest strategy and harvest strategy and which act to reduce ensure that the the exploitation rate as exploitation rate is limit reference points reduced as limit are approached. reference points are
Guidepost approached.
Met? Yes No
There is historical evidence that fishery has acted to reduce exploitation rate when the stock was designated as overfished. This has led to the stock rebuilding since 2006. However, management intervention was not timely. Therefore, a generally understood harvest control rule exists to limit harvest and reduce the harvest rate should the stock recruitment be put at risk, meeting SG60. However, the reduction in the exploitation rate when SSB < Btrigger is only generally understood, not well- defined, so SG80 is not met. A long term management plan is being developed, but has not yet been implemented. On 21 May 2013 the Pelagic RAC, WWF UK and Agri-Food and Biosciences Institute organized a workshop aimed at developing a long-term management plan for Irish Sea herring under the auspices of the GAP 2 research project. This development is on-going, but will hopefully yield a HCR which
conforms to MSC certification requirements. Adjacent Stock Considerations The Celtic Sea herring fishery operates its own separate well-defined harvest control rule. The Celtic Sea HCR is based on the estimated SSB in the Celtic Sea
Justification area. This will take account of the juveniles caught in the Irish sea albeit indirectly.
b The selection of the The design of the harvest harvest control rules control rules takes into account takes into account the a wide range of uncertainties. main uncertainties.
Guidepost
Met? Yes No
Justifi FMSY, which is used to set the harvest level, has been estimated from the stock cation assessment and from simulation work. ICES has reported the FMSY as “well estimated”. The simulations certainly have taken the main uncertainties (observation error, recruitment variation) into account. Although the MSY estimate takes account of standard uncertainties such as observation error, there is no special consideration of risk. The monitoring system and subsequent setting of the TAC should account for main uncertainties. Specifically, the lack of a clear reduction in fishing mortality should stock indicators suggest that the stock is at risk of overfishing prevent the HCR meeting SG100. Adjacent Stock Considerations The harvest control rule is based upon the SSB within the Irish Sea. This is separate from the Celtic Sea as there is little or no mixing of mature adults. The juvenile Celtic herring catches should act as a buffer for the smaller Irish sea stock. For the Celtic
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PI 1.2.2 There are well defined and effective harvest control rules in place
Sea, catches in the Irish Sea should lead to perception of slightly lower recruitment, which would lead to corresponding lower catches in the Celtic Sea areas. Therefore, separate HCRs should be robust to the current level of mixing as long as there is no long term change. Any long term changes should be detectable with the current level of monitoring. Unless stock structure is explicitly accounted for in the HCR, it will be difficult to meet the SG100.
c There is some Available evidence Evidence clearly shows that the evidence that tools indicates that the tools tools in use are effective in used to implement in use are appropriate achieving the exploitation levels harvest control rules and effective in required under the harvest are appropriate and achieving the control rules. effective in controlling exploitation levels exploitation. required under the
Guidepost harvest control rules.
Met? Yes Yes No
Available evidence indicates tools effective. The primary tools are TAC (limits on total catch) and closed areas. An observer program suggests that catches monitored appropriately (discarding is rare). VMS is required on vessels, which allows seasonal closed areas to be enforced. The required exploitation level has been demonstrably achieved, meeting SG80. The main uncertainty is reliance on a TAC which does not distinguish between several spawning components. It is unclear that current controls will be effective in all circumstances. For example, changes in fishing location could increase catches of the Manx spawning herring without any change in the Irish Sea TAC. Although it is likely that this would be detected and could lead to adjustments in the way the TAC is administered, as it stands it is not clear the current system will always be fully effective. In addition, management has taken action that interferes with its ability to monitor the stock. The introduction of the Manx seasonal closed area has
increased uncertainty in the stock assessment. Therefore SG100 is not met. Adjacent Stock Considerations TACs are managed separately between the Irish and Celtic Seas. Appropriate levels of fishing mortality have been achieved in both stocks using the current tools.
Justification With the current stock distribution, the tools therefore appear to be effective.
» ICES. 2012. Report of the Benchmark Workshop on Pelagic Stocks (WKPELA 2012), 13–17 February 2012, Copenhagen, Denmark. ICES CM 2012/ACOM:47. 572 pp. » ICES. 2013a. Report of the Herring Assessment Working Group for the Area South of 62 N (HAWG), 12-21 March 2013, ICES Headquarters, References Copenhagen. ICES CM 2013/ACOM:06. 1270pp. » ICES. 2013b. Herring in Division VIIa North of 52º30’N (Irish Sea). Book 5.4.14 Advice June 2013 » ICES 2013c. Herring in Divisions VIIa (South of 52°30’N) and VIIg,h,j,k (Celtic Sea and South of Ireland). Book 5.4.15 Advice June 2013.
OVERALL PERFORMANCE INDICATOR SCORE: 75
CONDITION NUMBER (if relevant): 2
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Evaluation Table for PI 1.2.3
PI 1.2.3 Relevant information is collected to support the harvest strategy
Scoring Issue SG 60 SG 80 SG 100
a Some relevant Sufficient relevant A comprehensive range of information related to information related to information (on stock structure, stock structure, stock stock structure, stock stock productivity, fleet productivity and fleet productivity, fleet composition, stock abundance, composition is composition and other fishery removals and other available to support data is available to information such as the harvest strategy. support the harvest environmental information), strategy. including some that may not be
directly related to the current
Guidepost harvest strategy, is available.
Met? Yes Yes No
Various stock discrimination techniques have shown that juveniles originating from the Celtic Sea are present in the Irish Sea during the annual acoustic survey and fishery. The stocks are separated based on their time of spawning. Within the Irish Sea the majority of spawning occurs in autumn, while Celtic Sea spawning takes place predominantly in winter and autumn. Quantitative estimates of this mixing and the effect of this mixing on the assessment are available (ICES 2012), including effects on spawning and growth. Stock mixing was found to be spatially dynamic with the majority of mixing occur-ring to the west of the Isle of Man. The level of mixing to the east of the Isle of Man, in the area of the Douglas bank spawning ground, was estimated to be much lower. This spatial picture of mixing is mirrored by the observation that the majority of juvenile fish (1–2 rings) are found to the west of the Isle of Man. The proportion of mixing varied annually in the acoustic and commercial samples. The extent of mixing observed in the commercial landings will be influenced by local spawning area closures and the spatial and temporal dynamics of the fleet and migrating herring. It is estimated over the study period on average ~1350 t of annual VIIaN landings were of winter spawning fish, representing on average ~30% of total TAC. Because the stocks cannot be entirely separated in the Irish Sea, the assessment has to be carried out as a mixed population fishery. This is standard practice for pelagic stocks, such as herring and mackerel, which consist of a number of spawning components. Components themselves are monitored through survey information, but notably catches cannot be allocated to individual components. Nevertheless, uncertainties are taken into account in the harvest strategy, by setting a relatively low TAC, reducing the catch of juveniles and seasonal closed areas, so that information is sufficient to support the harvest strategy, meeting SG80. Hence the population structure is complex and as a result information is not comprehensive, although information is available which is not related to the current harvest strategy. Because information is not comprehensive, SG100 is not met.
Adjacent Stock Considerations Celtic Sea herring fishery has its own data collection comparable with the Irish Sea, although the fishery is significantly larger. The juvenile catch in the Irish Sea is relatively small (<6% current Celtic Sea TAC). Information is still sufficient to test the
Justification harvest strategy and ensure that it is effective.
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PI 1.2.3 Relevant information is collected to support the harvest strategy
b Stock abundance and Stock abundance and All information required by the fishery removals are fishery removals are harvest control rule is monitored and at least regularly monitored at a monitored with high frequency one indicator is level of accuracy and and a high degree of certainty, available and coverage consistent and there is a good monitored with with the harvest control understanding of inherent sufficient frequency to rule, and one or more uncertainties in the information support the harvest indicators are available [data] and the robustness of control rule. and monitored with assessment and management sufficient frequency to to this uncertainty. support the harvest
Guidepost control rule.
Met? Yes Yes No
Justifi The harvest control rule needs catch, abundance index and age composition data. cation The harvest control rule is based on fishing mortality and SSB estimated from an age structure stock assessment. There are some concerns over the quality of historic landings information, especially in the 1970s and 1980s. Recent landings data are considered to be of acceptable quality. Detailed information on the number of samples, number of fish measured and aged by country and quarter are reported annually in the relevant working group report. Sampling coverage of this stock is exceptionally high where almost every landing is sampled. Age samples are 700–1300% in access of the Data Collection Framework requirements, although samples were not taken in 2009. Otherwise, monitoring and verification of catch levels with high frequency or high degree of certainty. Slippage has not been observed, and the fishery is considered low risk. An annual acoustic survey is conducted, and has been extended in recent years. These data show high interannual variation, but this reflects real variation in stock movement and density. There is also a larval survey, which is used, and a groundfish survey, which is not used as it is not thought to reflect abundance. With good coverage of fishery removals and a reliable fishery-independent abundance index more than sufficient for the current HCR, the fishery meets the SG80. The inherent uncertainties are also, to an extent, understood. However, without routine sampling of catches to assess the on-going year-to-year stock mixing, data are insufficient to meet SG100. Adjacent Stock Considerations The Celtic Stock stock abundance indicators are independent from the Irish Sea indicators. However, some removals are likely mis-allocated to the Irish Sea stock when they belong to the Celtic Sea. This mis-allocation of removals is likely to be less than 6% of the catch in the Celtic Sea. Since the misallocation is of juveniles, the fishery independent abundance indices based on SSB should not be affected by this, and more generally estimates of SSB and F should be robust to this mis-allocation (see PI 1.2.4).
c There is good information on all other fishery removals from the stock.
Guidepost
Met? Yes
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PI 1.2.3 Relevant information is collected to support the harvest strategy
There are some concerns over the quality of historic landings information, especially in the 1970s and 1980s, which are described in the stock annex. Recent landings data are considered to be of acceptable quality. Discarding however is not thought to be a feature of this fishery. At sea observer data are collected since 2010 (~11% of fishing trips sampled annually) with no discard observed. The data are adequate for stock assessment and to control catches through the TAC, meeting SG80.
Adjacent Stock Considerations There is no evidence that Irish Sea herring are caught in the Celtic Sea fishery. This could lead to removals from the Irish Sea stock being overestimated. Misallocation of catches from the Celtic Sea is low and the harvest control rule should be robust to this level of error.
Justification
» ICES 2010. Report of the Study Group on the evaluation of assessment and management strategies of the western herring stocks (SGHERWAY), 14‐18 June 2010, Dublin, Ireland. ICES CM 2010/SSGSUE:08. 194 pp. » ICES. 2012. Report of the Benchmark Workshop on Pelagic Stocks (WKPELA 2012), 13–17 February 2012, Copenhagen, Denmark. ICES CM References 2012/ACOM:47. 572 pp. » ICES. 2013a. Report of the Herring Assessment Working Group for the Area South of 62 N (HAWG), 12-21 March 2013, ICES Headquarters, Copenhagen. ICES CM 2013/ACOM:06. 1270pp. » ICES 2013c. Herring in Divisions VIIa (South of 52°30’N) and VIIg,h,j,k (Celtic Sea and South of Ireland). Book 5.4.15 Advice June 2013.
OVERALL PERFORMANCE INDICATOR SCORE: 80
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 1.2.4
PI 1.2.4 There is an adequate assessment of the stock status
Scoring Issue SG 60 SG 80 SG 100
a Guide The assessment is The assessment is appropriate post appropriate for the for the stock and for the harvest stock and for the control rule and takes into harvest control rule. account the major features relevant to the biology of the species and the nature of the fishery.
Met? Yes No
Justifi The assessment is appropriate for the stock. It makes use of the available catch, age, cation weight and survey data. It captures most of the major features relevant to modeling the stock and it has been determined that the model explains the available data well. The stock assessment is able to monitor growth, stock distribution and recruitment patterns. This meets SG80. However, some major features, notably stock structure, are addressed but not directly. It is not clear whether the current model could be used to describe the spatial structure of the stock or conduct joint stock assessment with other West of Britain components the without significant change. Therefore the assessment does not yet meet SG100. Adjacent Stock Considerations The Celtic Sea stock has a separate stock assessment and harvest control rule. These are implemented in a similar way to the Irish Sea based on the available data. Neither stock assessment explicitly addresses the spatial issues raised here, limiting their ability to meet SG100.
b The assessment estimates stock status relative to reference points.
Guidepost
Met? Yes
The assessment estimates current fishing mortality and spawning stock biomass, both of which can be directly compared to the MSY reference points for these
values. This meets SG60. Adjacent Stock Considerations Mis-allocation of catch does not affect the evaluation of Celtic Sea herring stock status because this is dependent on SSB, which is monitored independently of the
Justification Irish Sea.
c The assessment The assessment takes The assessment takes into identifies major uncertainty into account uncertainty and is sources of uncertainty. account. evaluating stock status relative to reference points in a
Guidepost probabilistic way.
Met? Yes Yes No
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PI 1.2.4 There is an adequate assessment of the stock status
The stock assessment is based on FLSAM, which is a state space model implemented within a FLR software platform. The model is fitted using AD Model builder, which appropriate software for this type of non-linear model. The model itself accounts for both observation and process error, accounting for the probability of outcomes and is therefore fully probabilistic and accounts for uncertainty. However, probabilities are only cursorily reported in the management advice, and therefore no explicit use of risk is made within the decision-making. Therefore, because the stock status is not explicitly probabilistic, SG100 is not met. Adjacent Stock Considerations Mis-allocation of catch is a significant source of uncertainty for both the Irish Sea and Celtic Sea herring stocks. This is likely one of the causes for significant retrospective bias is SSB and recruitment estimates in the Celtic Sea and Irish Sea assessments.
Because of mixing, fishery independent estimates of younger ages as well as catches are poor, Because the catch of juveniles is poorly estimated, it may be some years before past recruitment is well estimated. This will add to uncertainty, but the effects of this uncertainty in both assessments are well understood and can be accounted for in the advice. This error is difficult to assess probabilistically without appropriate
Justification data, suggesting more information might be necessary to meet the SG100.
d The assessment has been tested and shown to be robust. Alternative hypotheses and depost assessment approaches have
Gui been rigorously explored.
Met? Yes
The recent benchmark assessment considered three assessment models. The bench is the latest of series of benchmark assessments which consider alternative approaches and have demonstrably led to on-going improvements in the stock assessments. The previous ICA assessment had been rejected. The new SAM model addresses a variety of concerns that have been raised with respect to interpretation of the data and appears to be robust to these concerns. Therefore, SG100 is met.
Justification
e The assessment of The assessment has been stock status is subject internally and externally peer to peer review. reviewed.
Guidepost
Met? Yes No
The internal review is rigorous. The stock assessment is reviewed by a technical working group (HAWG), where diagnostics are considered in developing an acceptable configuration for the stock assessment model. Management advice is developed and approved by the STECF, and this is used as a basis for advice. All information, results and conclusions are published and available in the public domain. This meets SG80. External review is limited. Although there is evidence of some external review of the working group’s deliberations, it is not clear that this specifically includes stock status or management advice. Furthermore, the software itself is not well documented, and
Justification therefore it is unclear how rigorous any review can be, so SG100 is not met.
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PI 1.2.4 There is an adequate assessment of the stock status
» ICES 2010. Report of the Study Group on the evaluation of assessment and management strategies of the western herring stocks (SGHERWAY), 14‐18 June 2010, Dublin, Ireland. ICES CM 2010/SSGSUE:08. 194 pp. » ICES. 2012. Report of the Benchmark Workshop on Pelagic Stocks (WKPELA 2012), 13–17 February 2012, Copenhagen, Denmark. ICES CM 2012/ACOM:47. 572 pp. References » ICES. 2013a. Report of the Herring Assessment Working Group for the Area South of 62 N (HAWG), 12-21 March 2013, ICES Headquarters, Copenhagen. ICES CM 2013/ACOM:06. 1270pp. » ICES. 2013b. Herring in Division VIIa North of 52º30’N (Irish Sea). Book 5.4.14 Advice June 2013 » ICES 2013c. Herring in Divisions VIIa (South of 52°30’N) and VIIg,h,j,k (Celtic Sea and South of Ireland). Book 5.4.15 Advice June 2013.
OVERALL PERFORMANCE INDICATOR SCORE: 85
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 2.1.1 The fishery does not pose a risk of serious or irreversible harm to the PI 2.1.1 retained species and does not hinder recovery of depleted retained species
Scoring SG 60 SG 80 SG 100 Issue a Main retained Main retained There is a high degree of species are likely to species are highly certainty that retained
be within biologically likely to be within species are within based limits (if not, biologically based biologically based limits and go to scoring issue c limits (if not, go to fluctuating around their below). scoring issue c target reference points.
Guidepost below).
Met? Yes Yes Yes
The fishery is a pelagic trawl fishery that targets dense aggregations of herring. The fishery is highly temporally and spatially concentrated. The fishery does not operate close to the seabed and therefore does not capture any demersal species. There are no retained species in the fishery. Mackerel and/or scad may exceptionally be retained in very small numbers. Retention is rare and insignificant in its potential
Justification impact. b Target reference points are defined for retained species.
Guidepos t
Met? Yes
There are no retained species in the fishery.
Justification c If main retained If main retained species are outside species are outside the limits there are the limits there is a measures in place partial strategy of that are expected to demonstrably ensure that the effective fishery does not management
hinder recovery and measures in place rebuilding of the such that the fishery depleted species. does not hinder recovery and
Guidepost rebuilding.
Met? Yes Yes
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The fishery does not pose a risk of serious or irreversible harm to the PI 2.1.1 retained species and does not hinder recovery of depleted retained species
There are no retained species in the fishery.
Justificatio n d 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
Guidepost recovery.
Met? Yes
There are no retained species in the fishery.
Justificatio n
» Landings data for NIPSG fleet under assessment in the Irish Sea herring fishery, 2010-2012. References » DARD (pers comms) 2013. » AFBI (pers comms) 2013.
OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 2.1.2 There is a strategy in place for managing retained species that is PI 2.1.2 designed to ensure the fishery does not pose a risk of serious or irreversible harm to retained species
Scoring SG 60 SG 80 SG 100 Issue
a There are measures There is a partial There is a strategy in place in place, if strategy in place, if for managing retained necessary, that are necessary, that is species. expected to maintain expected to maintain the main retained the main retained species at levels species at levels which are highly which are highly likely to be within likely to be within
biologically based biologically based limits, or to ensure limits, or to ensure the fishery does not the fishery does not hinder their recovery hinder their recovery
Guidepost and rebuilding. and rebuilding.
Met? Yes Yes Yes
There are no retained species in the UoC. Mackerel and or horse mackerel may be retained in insignificant numbers very exceptionally. The strategy for managing retained catch involves reporting of all catches landed along with herring. Review of data for the fishery for 2010/2011 and 2012 revels that there were no retained catches in the fishery. Under DARD/EU rules catches of all species must be reported. There is a management plan in place for mackerel and the fishing mortality is managed through an overall TAC which is normally set in accordance with ICES advice. The EU-Norway agreement aims to ensure that removals do not exceed the overall TAC and national quotas are agreed upon at the annual coastal states meetings. The management plan features both biomass and fishing mortality reference points and a well-defined harvest control rule. The strategy for minimizing retained catch is deliberately designed to ensure pelagic fisheries avoid catches of stocks that are not intended and therefore all catches taken of mackerel and/or horse mackerel count against quota entitlement. The strategy is backed up by a comprehensive monitoring, control and surveillance programme that includes prior notification of landings, in port and at sea inspections, electronic logbook reporting and vessel monitoring systems. These MCS measures are important elements of the strategy and are deliberately intended to ensure that no other catches can be landed without the management system detecting such events. Additional technical controls apply to the fishery such as minimum landing sizes and minimum mesh sizes. The herring is a targeted fishery and vessels leave harbor with intent of catching and landing Irish Sea herring. At operational level, the fleet utilise modern electronic aids to identify target shoals.
Justification
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There is a strategy in place for managing retained species that is PI 2.1.2 designed to ensure the fishery does not pose a risk of serious or irreversible harm to retained species
b The measures are There is some Testing supports high considered likely to objective basis for confidence that the strategy work, based on confidence that the will work, based on plausible argument partial strategy will information directly about the
(e.g., general work, based on some fishery and/or species experience, theory information directly involved. or comparison with about the fishery similar and/or species
Guidepost fisheries/species). involved.
Met? Yes Yes Yes
There is high confidence that the strategy will work. The fishery is highly spatially and temporally concentrated and no other abundant pelagic species that may be captured by the pelagic trawl gear in use are present in the same areas at the same time that the fishery is prosecuted. Practically all catches are landed into Northern Ireland and DARD have verified that there are no catches of other species. This is supported by observer coverage for the fleet under assessment (AFBI, pers comms). . The strategy is appropriate to the level of risk that this fishery presents to
Justification retained catch species.
c There is some There is clear evidence that evidence that the the strategy is being partial strategy is implemented successfully. being implemented
Guidepost successfully.
Met? Yes Yes
There is no retained catch. Both landings data for the certified fleet and observer coverage data confirm that there are no retained species in the catch and this has been confirmed by DARD and observer coverage. This is taken as clear evidence that the strategy is implemented successfully. The strategy is appropriate to the
level of risk that this fishery presents to retained catch species.
Justificatio n
d There is some evidence that the strategy is achieving its overall objective.
Guidepost
Met? Yes
Landings data that show all species captured with Irish Sea herring by the certified fleet has been available to the team. No other species are reported. DARD have informed the assessment that inspections have confirmed the landings declarations and that there are no significant numbers of any species landed along with Irish
Sea herring in the pelagic trawl fishery.
Justificatio n
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There is a strategy in place for managing retained species that is PI 2.1.2 designed to ensure the fishery does not pose a risk of serious or irreversible harm to retained species e It is likely that shark It is highly likely that There is a high degree of finning is not taking shark finning is not certainty that shark finning is place. taking place. not taking place.
Guidepos t
Met? Not relevant Not relevant Not relevant
Scoring issue need not be scored if no retained species are sharks.
Justification
» Landings data for fleet under assessment in the Irish Sea herring fishery, 2010-2012. References » DARD (pers comms) 2013. » AFBI (pers comms) 2013.
OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 2.1.3 Information on the nature and extent of retained species is adequate PI 2.1.3 to determine the risk posed by the fishery and the effectiveness of the strategy to manage retained species
Scoring SG 60 SG 80 SG 100 Issue a Qualitative Qualitative Accurate and verifiable information is information and information is available on available on the some quantitative the catch of all retained
amount of main information are species and the retained species available on the consequences for the status taken by the fishery. amount of main of affected populations. retained species
Guidepost taken by the fishery.
Met? Yes Yes Yes
There are no retained species in the fishery. DARD have provided the assessment
tio team with reported landed catch data for the vessels where Irish Sea herring were landed during the three year period 2010-2012. No other species were landed along with IS herring.
Justifica n b Information is Information is Information is sufficient to adequate to sufficient to estimate quantitatively estimate
qualitatively assess outcome status with outcome status with a high outcome status with respect to biologically degree of certainty. respect to based limits. biologically based
Guidepost limits.
Met? Yes Yes Yes
The status of any stocks potentially affected by the herring fishery under assessment (mackerel, horse mackerel) is known. The relative role in the fishery under assessment in the context of fishing mortality on these stocks is known with a high degree of certainty. Impacts are known to be insignificant from a review of data provided by DARD and AFBI.
Justification c Information is Information is Information is adequate to adequate to support adequate to support support a strategy to
measures to a partial strategy to manage retained species, manage main manage main and evaluate with a high retained species. retained species. degree of certainty whether the strategy is achieving its
Guidepost objective.
Met? Yes Yes No
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Information on the nature and extent of retained species is adequate PI 2.1.3 to determine the risk posed by the fishery and the effectiveness of the strategy to manage retained species
Information supports a full strategy to manage retained species. Landings are reported by species however the fact that small volumes of other species may not always be recorded (e.g. volumes of <50kg) means that there is some uncertainty with respect to whether the strategy may be achieving its objective. Additionally, although considered an unlikely and exceptional event, the possibility that there is slippage of unwanted catches and that this is not reported means there is further
Justification uncertainty concerning the final level of fishing mortality for any affected species.
d Sufficient data Monitoring of retained continue to be species is conducted in collected to detect sufficient detail to assess any increase in risk ongoing mortalities to all level (e.g. due to retained species. changes in the outcome indicator
score or the operation of the fishery or the effectiveness of the
Guidepost strategy)
Met? Yes No
While there are no significant catches of any other species that are retained, monitoring is unlikely to capture small volumes e.g.<50kg of any species that may be taken in the fishery. Therefore the on-going level of mortality of mackerel or horse mackerel retained be considered to be monitored in absolute detail.
Justificatio n
» ICES 2012. Horse mackerel (Trachurus trachurus) in Divisions IIa, IVa, Vb, References VIa, VIIa-c, e-k, and Subarea VIII (Western stock) ICES Advice 2013 Book 9. » ICES. 2012. Report of the Working Group on Widely Distributed Stocks (WGWIDE). Lowestoft, 21–27 August 2012. ICES C.M. 2012 / ACOM: 15
OVERALL PERFORMANCE INDICATOR SCORE: 90
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 2.2.1 The fishery does not pose a risk of serious or irreversible harm to the PI 2.2.1 bycatch species or species groups and does not hinder recovery of depleted bycatch species or species groups
Scoring SG 60 SG 80 SG 100 Issue
a Main bycatch Main bycatch species There is a high degree of
species are likely to are highly likely to be certainty that bycatch be within biologically within biologically species are within based limits (if not, based limits (if not, biologically based limits. go to scoring issue b go to scoring issue b
Guidepost below). below).
Met? Yes Yes Yes
There is a high degree of certainty that there are no bycatch species in the fishery. Discarding of undersize herring (the target stock) may occur through slippage from time to time, however herring is considered under Principal 1. Because it is a bulk fishery and the mechanized manner in which catches are taken aboard and landed to shore (via pumps), there is no capacity for grading and discarding of any catch while at sea. Vessels utilize modern electronics including sonar to aid in target shoal discrimination; unintended catch is therefore very rare. Information from a DARD observer programme (DARD, pers comms) suggests that slippage of catches is exceptionally rare and has not been recorded in over 62 observed hauls since 2005. In consequence there is a high degree of certainty that there are no bycatch species. There may be occasional bird bycatch in the fishery. This is reported anecdotally and is a feature for many pelagic fisheries. Bird bycatch is incidental in nature and may
occur through diving birds becoming enmeshed in the gear once it has been hauled to the surface and birds attempt to feed on the fish opportunistically. While no data are available to specifically evaluate the impact of the fishery in this regard, information from analogous fisheries indicates that bird bycatch is infrequent and is highly unlikely to present a significant threat to any populations.
Justification
b If main bycatch If main bycatch species are outside species are outside biologically based biologically based limits there are limits there is a mitigation measures partial strategy of in place that are demonstrably expected to ensure effective mitigation
that the fishery does measures in place not hinder recovery such that the fishery and rebuilding. does not hinder recovery and
Guidepost rebuilding.
Met? Yes Yes
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The fishery does not pose a risk of serious or irreversible harm to the PI 2.2.1 bycatch species or species groups and does not hinder recovery of depleted bycatch species or species groups
There are no main bycatch species.
Justification c If the status 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
Guidepost recovery.
Met? Yes
There are no main bycatch species in the fishery.
Justificatio n
» Landings data for fleet under assessment in the Irish Sea herring fishery, 2010-2012. References » DARD (pers comms) 2013. » AFBI (pers comms) 2013. » Fisheries Directorate, Isle of Man 2013 (pers. comms.)
OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 2.2.2 There is a strategy in place for managing bycatch that is designed to PI 2.2.2 ensure the fishery does not pose a risk of serious or irreversible harm to bycatch populations
Scoring SG 60 SG 80 SG 100 Issue
a There are measures There is a partial There is a strategy in place in place, if strategy in place, if for managing and minimizing necessary, that are necessary, that is bycatch. expected to maintain expected to maintain the main bycatch the main bycatch species at levels species at levels which are highly which are highly likely to be within likely to be within
biologically based biologically based limits, or to ensure limits, or to ensure the fishery does not the fishery does not hinder their recovery hinder their recovery
Guidepost and rebuilding. and rebuilding.
Met? Yes Yes Yes
There is a strategy in place for managing this fishery’s impact on bycatch species. From an operational perspective, NIPSG vessels use sophisticated on-board electronics to aid in shoal identification. Use of electronics is standard practice for locating shoals and also allows for a degree of discrimination in terms of species, shoal size, density and mix. Under normal operational conditions, experienced fishing skippers are capable of reliably interpreting sonar data to aid them in determining whether shoals are of the target stock, or if they are comprised of a high proportion of mixed stocks or undersized fish. The NIPSG Irish Sea herring fishery is a particularly targeted fishery. In this context, vessels fish at the most opportune times to pursue the fish, which is when they form dense homogenous shoals. There is no significant mixing between adult herring and any other species, although it is noted that in coastal waters of the Irish Sea, sprat may be found mixed with juvenile herring. The fishery does not take place in these areas nor does it target aggregations of juvenile fish. Communications between NIPSG vessels during the herring season ensures that information in relation to shoals and undersize fish (criteria that can increase the risk of slippage) is shared rapidly and openly between the small number of vessels, two of which fish in unison. In the event of mixed catches occurring however, the onshore processing units are quite capable of handling mixed catches, therefore the presence of unwanted species in the catch is not an event that would force a vessel to slip an entire haul of fish. NIPSG vessels do not carry grading equipment onboard vessels. It is a bulk fishery whereby catch handling is entirely automated. There is no scope for vessels to grade fish according to size or species as catches are coming aboard.
Justification
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There is a strategy in place for managing bycatch that is designed to PI 2.2.2 ensure the fishery does not pose a risk of serious or irreversible harm to bycatch populations
b The measures are There is some Testing supports high considered likely to objective basis for confidence that the strategy work, based on confidence that the will work, based on plausible argument partial strategy will information directly about the
(e.g. general work, based on some fishery and/or species experience, theory information directly involved. or comparison with about the fishery similar and/or species
Guidepost fisheries/species). involved.
Met? Yes Yes No
There is an objective basis for confidence that the strategy will work. Knowledge in relation to temporal and spatial aspects of the fishery as well as observer data and other stakeholder information (DARD, pers. Comms.) indicates that there is no bycatch. On this basis the strategy is considered likely to work. However it has not explicitly been tested and therefore SG100 is not met.
Justification
c There is some There is clear evidence that evidence that the the strategy is being partial strategy is implemented successfully. being implemented
Guidepost successfully.
Met? Yes No
Observer data confirms there is no bycatch or that it is exceptionally rare and negligible in its impact. There is evidence that the fishery is exceptionally clean – as reflected in landings data. There are no opportunities to separate fish once brought
aboard so discarding of partial catches is not possible. Stakeholder information confirms that previous incidences of dead fish being washed up on the Isle of Man have not occurred in recent years since the fishery has been consolidated and fished by only three vessels over a short season. SG100 is not considered to be met on account of uncertainty over management of possible slippage events.
Justification
d There is some evidence that the strategy is achieving its overall objective.
Guidepos t
Met? Yes
The fishery does not capture any other species in significant volumes and evidence
from stakeholders suggests that slippage is exceptional in this fishery. The herring stock continues to build in recent years and catches have remained within the advice. No other stocks are referred to as being negatively impacted through the operation of the Irish Sea herring fishery, either through retained catch or discarding in any literature made available to the assessment team.
Justification
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There is a strategy in place for managing bycatch that is designed to PI 2.2.2 ensure the fishery does not pose a risk of serious or irreversible harm to bycatch populations
» DARD (pers comms) 2013. References » AFBI (pers. comms.) 2013. » Fisheries Directorate, Isle of Man 2013 (pers. comms.)
OVERALL PERFORMANCE INDICATOR SCORE: 90
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 2.2.3 Information on the nature and the amount of bycatch is adequate to PI 2.2.3 determine the risk posed by the fishery and the effectiveness of the strategy to manage bycatch
Scoring SG 60 SG 80 SG 100 Issue
a Qualitative Qualitative Accurate and verifiable information is information and information is available on available on the some quantitative the catch of all bycatch
amount of main information are species and the bycatch species available on the consequences for the status taken by the fishery. amount of main of affected populations. bycatch species
Guidepost taken by the fishery.
Met? Yes Yes No
Reasonable levels of information to support a bycatch management strategy are available from past AFBI observer trips. Data are collected in the fishery through the AFBI on-going observer scheme that aims to achieve 5% coverage of effort. There is a large body of more general knowledge and information in relation to herring pelagic trawl fisheries in the northeast Atlantic. Inference from other similar fisheries for other herring stocks in the north Atlantic for which there are additional data available also further supports the understanding of the nature and scale of the bycatch issue in the NIPSG North Sea herring fishery. The implications for any potentially affected populations are known.
This supports an understanding of the fishery in the context bycatch species and quantities and supports scoring at SG80. However more general information is not considered accurate or verifiable and does not relate to all bycatch species or the potential implications for any affected populations.
Justification
b Information is Information is Information is sufficient to
adequate to broadly sufficient to estimate quantitatively estimate understand outcome outcome status with outcome status with respect status with respect respect to biologically to biologically based limits to biologically based based limits. with a high degree of
Guidepost limits certainty.
Met? Yes Yes No
Data from observer trips by AFBI is adequate to estimate outcome status with respect to biologically based limits for any species potentially affected. However, based on 5% coverage of effort and the lack of an operational slippage reporting log on-board the assessed vessels, SG100 is considered not to be met.
Justificatio n
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Information on the nature and the amount of bycatch is adequate to PI 2.2.3 determine the risk posed by the fishery and the effectiveness of the strategy to manage bycatch
c Information is Information is Information is adequate to adequate to support adequate to support support a strategy to
measures to a partial strategy to manage retained species, manage bycatch. manage main and evaluate with a high bycatch species. degree of certainty whether the strategy is achieving its
Guidepost objective.
Met? Yes Yes No
Information in relation to the scale, spatial location and timing of the fishery provide a means by which to monitor the overall risk of bycatch. Together with information collected from the AFBI observer programme and at sea monitoring and inspection programmes (MCS), and information in relation to potentially affected stocks, it is considered that available information is adequate to support the strategy to manage
Justification bycatch species.
d Sufficient data Monitoring of bycatch data is continue to be conducted in sufficient detail collected to detect to assess ongoing any increase in risk mortalities to all bycatch to main bycatch species. species (e.g., due to changes in the outcome indicator
scores or the operation of the fishery or the effectively of the
Guidepost strategy).
Met? Yes No
It is understood that there are no main bycatch species, based on the view of scientists and enforcement personnel, supported by those directly involved in the
fishery including skippers and processors. Information in relation to the scale, spatial location and timing of the fishery provide a potential means by which to monitor the overall risk of bycatch to particular species, should the bycatch component change in this fishery in the future. However, there therefore there is no independent verification of bycatch or slippage in the NIPSG fleet fishery for Irish Sea herring.
Justification
» DARD (pers comms) 2013. References » AFBI (pers comms) 2013.
OVERALL PERFORMANCE INDICATOR SCORE: 80
CONDITION NUMBER (if relevant):
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Evaluation Table for 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
Scoring SG 60 SG 80 SG 100 Issue a Known effects of the The effects of the There is a high degree of fishery are likely to fishery are known certainty that the effects of be within limits of and are highly likely the fishery are within limits of national and to be within limits of national and international
international national and requirements for protection requirements for international of ETP species. protection of ETP requirements for species. protection of ETP
Guidepost species.
Met? Yes Yes No
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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
A range of ETP species are known to occur within the Irish Seal where the fishery operates. Amongst these are both Grey and Harbour seal and Harbour porpoise; all of which are protected under Council Directive 92/43/EEC (the ‘Habitats Directive’). Other protected species known to occur include the basking shark which is CITES appendix I listed and is prohibited catch under EU Council Regulation 39/2013. Both Allis shad and sturgeon are also listed under the Habitats Directive, while sturgeon is listed on CITES Appendix II. The basking shark was included in the Wildlife & Countryside Act (1998) and more recently the Bonn Convention in Migratory Species (2005). Leading in 2006 to the prohibition of deliberate capture and landing in EC waters under CFP regulations and more recently to an annually renewed ban on retention on board of any specimens beginning with EU Council Regulation 23/2010. The vast majority of recent basking shark sightings in EU waters have been concentrated on the West Coast of Scotland and around the Isle of Man in the Irish Sea. As the Basking Shark shares are diet with herring, there is a theoretical possibility of interaction with the NIPSG fleet while they are engaged in the herring fishery in the Irish Sea. In spite of this there have been no reported interactions – despite significant observer coverage, re-enforced by stakeholder comments received during assessment interviews. This is likely explained by spatial and temporal limits to the fishery and low overlap with basking shark concentration and periods of abundance around the Isle of Man. Few data re available in relation to seal bycatch. However analogous information is available with respect to other UK herring fisheries. Under the Conservation of Seals Act 1970, the Natural Environment Research Council (NERC) has a duty to provide scientific advice to government on matters related to the management of seal populations. NERC’s Special Committee on Seals (SCOS) provide advice annually which is informed by the latest scientific information provided by the Sea Mammal Research Unit (SMRU - St Andrews). In its annual submissions for recent years, SCOS does not point to a significant interaction (direct mortality) between pelagic herring trawl fisheries and either species of seal. This concurs with the general understanding that while individual captures may occur from time to time, seal bycatch is not a regular occurrence. The UK has been active in annual reporting of bycatch in capture fisheries the under the requirements of EU Council Regulation 812/2004 that lays down measures concerning incidental catches of cetaceans in fisheries. While incidental captures of harbour porpoise and possibly common dolphins are possible or even likely from time to time, no significant interactions have not been reported under the 812 monitoring programme, concerning the fishery under certification. The report of the ICES Working Group on Bycatch of Protected species refers to instances of catchers of river herring or shad (Alosa spp) in pelagic trawl fisheries in the USA and in European waters. While the present fishery is not referred to explicitly, it is acknowledged that there is potential for herring fisheries to have significant interaction with shad. Shad
are protected under EU law. No data indicating catch of shad in the Irish Sea herring fishery has been indicated by observer information or stakeholder comment. No concern has been expressed by scientists or stakeholders on the basis of observer
ication reports or anecdotal information for the fishery in relation to shad.
Justif
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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
Under Council regulation 812/2004, BIM have conducted monitoring onboard vessels from the republic of Ireland whilst operating in the VIIa herring fishery. Data from a limited number of trips undertaken during 2010 reveal no cetacean or other interactions with ETP species. UK data for a number of years reveal no bycatch of cetaceans in the fishery.
b Known direct effects Direct effects are There is a high degree of are unlikely to create highly unlikely to confidence that there are no unacceptable create unacceptable significant detrimental direct impacts to ETP impacts to ETP effects of the fishery on ETP
Guidepost species. species. species.
Met? Yes Yes No
There is no significant bycatch of ETP species in the fishery. According to Berrow et al (2004), no incidences of capture of cetaceans occurred during observer trips in the adjacent Celtic Sea herring fishery during the study period. Accordingly, the fishery is highly unlikely to create unacceptable impacts for any ETP populations. This is corroborated by observer reports, reporting under Council Regulation 812/2004 and general understanding of the ETP species footprint of pelagic trawl herring fisheries. Occasional interactions may occur but these do not necessarily always lead to mortality of affected individuals, although this is a likely outcome through drowning in fishing gear. Despite the likely outcome, the overall situation is likely to be within limits of acceptability based on knowledge of the animals
Justification involved and the relatively low frequency of interaction. c Indirect effects have There is a high degree of
been considered and confidence that there are no are thought to be significant detrimental unlikely to create indirect effects of the fishery unacceptable on ETP species.
Guidepost impacts.
Met? Yes No
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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
Indirect effects could emanate from depletion of the target species which could be a key food source for some species, pollution or through physical disturbance, underwater noise or other technical interactions. Given the species involved – mostly highly mobile and opportunistic feeders that are not reliant exclusively on herring for a food source, it is highly unlikely that the fishery reduces the herring stock to a point where it would adversely affect ETP populations. The target stock has been subject to an effective and precautionary management regime in recent years. The current stock assessment indicates that the spawning stock biomass has been above the upper MSY b-trigger point since 2007. There is a high degree of certainty that the stock has been well within the target region over the last 4 years and is projected to remain in this region in 2014.
The fisheries take place well away from shore where seal pupping haul outs may be located. It is known that pinnipeds and cetaceans have sensitive hearing, however they become rapidly accustomed to ships noise and indeed this may attract them to a vessels whereabouts. Vessels aim to minimize pollution from fuel and ship generated wastes and all oils
Justification and solid wastes are processed or disposed of ashore.
» http://www.bim.ie (Search for Pilot Observer Programme – Direct Link not working) » DARD (pers. Comms.) » CITES appendix II » Wildlife & Countryside Act (1998) » Conservation of Seals Act 1970 » Council Regulation 23/2012 » Council Regulation 92/43 EEC References » http://www.smru.st-andrews.ac.uk/documents/678.pdf » WGBYC 2011. Report of the Working Group on bycatch of protected species. ACOM:24 ICES 2011. » ASCOBANS- www.ascobans.org » Berrow, S. etal, 1998. Discarding practices and marine mammal bycatch in the Celtic Sea herring fishery. Proceedings of the Royal Irish Academy of Biology and Environment 1: 1-8. » COUNCIL REGULATION (EC) No 812/2004 – on laying down measures concerning incidental catches of cetaceans in fisheries and amending Regulation (EC) No 88/98
OVERALL PERFORMANCE INDICATOR SCORE: 80
CONDITION NUMBER (if relevant):
96 version 2.0 (01/06/13) Food Certification International Final Report Northern Ireland Pelagic Sustainability Group (NIPSG) Irish Sea Herring Fishery
Evaluation Table for 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. Scoring SG 60 SG 80 SG 100 Issue a There are measures There is a strategy in There is a comprehensive in place that place for managing strategy in place for minimise mortality of the fishery’s impact managing the fishery’s ETP species, and on ETP species, impact on ETP species, are expected to be including measures including measures to highly likely to to minimise mortality, minimise mortality, which is achieve national and which is designed to designed to achieve above international be highly likely to national and international
requirements for the achieve national and requirements for the protection of ETP international protection of ETP species. species. requirements for the protection of ETP
Guidepost species.
Met? Yes Yes No
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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. There is a strategy in place for managing the impact of the fishery on ETP species. The fishery operates within a clear legal framework which limits the volume of the harvest as well as the spatial location and timing of the fishery. From a legal stance, there are clear provisions setting out the status of ETP animals under UK, EU and International legislation and Convention. The UK has ratified CITES and is considered to be fully compliant under the EU environmental legislation. The UK is also a member of ASCOBANS. The aim of ASCOBANS is to promote close cooperation amongst contracting nations with a view to achieving and maintaining a favourable conservation status for small cetaceans. There is a clear undertaking to research the impacts that the Irish Sea pelagic trawl fishery for herring in VIIa may be having on ETP species. To date this has been achieved by AFBI (and to a lesser extent BIM) observer recording while on pelagic fishing trips. The UK has implemented an observer programme in order to meet the requirements of EU Council Regulation 812 of 2004. Under Article 6, Member States are required to report annually on the implementation of the Regulation, and the annual report must include estimates of the overall incidental catches of cetaceans in each of the fisheries concerned. Implementation of the requirements of the regulation resulted in AFBI observers making an average of 6 observer trips in the fishery per annum in recent years. Annual reports in relation to the implementation of the regulation are available. The consistent conclusion is that there is little bycatch of cetaceans in pelagic trawl fisheries. Considerable effort has been expended by Sea Mammal Research Unit observers since the 82/2004 been operational. According to the low number of
observed instances of cetacean interaction, it is considered highly likely that the management strategy will achieve national and international requirements for the protection of ETP species. According to Berrow et al (2004), no incidences of capture of cetaceans occurred during observer trips in the adjacent Celtic Sea herring fishery during the study period.
Justification
b The measures are There is an objective The strategy is mainly based considered likely to basis for confidence on information directly about work, based on that the strategy will the fishery and/or species plausible argument work, based on involved, and a quantitative
(e.g., general information directly analysis supports high experience, theory about the fishery confidence that the strategy or comparison with and/or the species will work. similar involved.
Guidepost fisheries/species).
Met? Yes Yes No
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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. The fishery is limited by quota and targets herring that form dense shoals. The fisheries are relatively clean and catches are made in relatively short hauls that are targeting specific shoals, which have been previously identified using sonar. ETP species are known to occur in the areas fished but most do not occur in large numbers are not widely distributed. There is low spatial / temporal overlap and any interactions are likely to involve only individual specimens. Interactions do not always lead to mortality as there is some scope for animals to be released from pelagic trawls when the net is hauled aboard. Due to the generally short hauls there is a greater potential for post capture survival for specimens including basking shark, if captured (considered very unlikely and an exceptional event).. The management response to the potential issue of ETP bycatch is appropriate both in scope and in the measures that it implements in order to avoid impacts. Based on
knowledge of ETPs that may be affected by this fishery, as well as the low level of interaction and comparisons with other pelagic trawl fisheries for herring, there is an objective basis for stating that the measures in place are unlikely to cause unacceptable impacts to ETPs. However there has not been a quantitative analysis (SG10).
Justification
c There is evidence There is clear evidence that that the strategy is the strategy is being being implemented implemented successfully.
successfully.
Guidepos t
Met? Yes No
Overall levels of bycatch in this fishery are exceptionally low, for both bycatch and ETP species. There is high degree of compliance by the UK with EU directives and regulations concerning protected species and monitoring of the effects of fisheries on cetaceans. There are no reports of cetacean, pinniped or shark mortality that coincide with the operation of this fishery. Both populations of seals are believed to
be stable or increasing in the Irish Sea. There are concerns over the level of harbor porpoise bycatch in fisheries however the main threat to porpoise is from static net fisheries, not pelagic trawls. The fishery itself has shown a very high degree of compliance with quota and fishery rules in recent years. There is no indication of systematic illegal activity or non-
Justification compliance with regulations by any NIPSG member vessels. d There is evidence that the strategy is achieving its objective.
Guidepos t
Met? No
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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. There is insufficient direct evidence that the strategy implemented by the assessed fleet is achieving objectives. In this regard there are limited observer reports and the fleet do not operate a voluntary reporting scheme whereby interactions with
ETP species are recorded and reported.
Justification
» Berrow, S., O’Neill, M. and Brogan, D. 1998. Discarding practices and marine mammal bycatch in the Celtic Sea herring fishery. Proceedings of the Royal Irish Academy of Biology and Environment 1: 1-8. References » COUNCIL REGULATION (EC) No 812/2004 – on laying down measures concerning incidental catches of cetaceans in fisheries and amending Regulation (EC) No 88/98
OVERALL PERFORMANCE INDICATOR SCORE: 80
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 2.3.3 Relevant information is collected to support the management of fishery impacts on ETP species, including: Information for the development of the management strategy; PI 2.3.3 Information to assess the effectiveness of the management strategy; and Information to determine the outcome status of ETP species. Scoring SG 60 SG 80 SG 100 Issue a Information is Sufficient information Information is sufficient to sufficient to is available to allow quantitatively estimate qualitatively estimate fishery related outcome status of ETP
the fishery related mortality and the species with a high degree mortality of ETP impact of fishing to of certainty. species. be quantitatively estimated for ETP
Guidepost species.
Met? Yes Yes No
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Relevant information is collected to support the management of fishery impacts on ETP species, including: Information for the development of the management strategy; PI 2.3.3 Information to assess the effectiveness of the management strategy; and Information to determine the outcome status of ETP species. There are a number of sources of data in relation to ETP interaction. Under regulation 812/2004 the UK operates an observer programme that aims to establish typical catch rates for cetacean species in a number of fisheries using pelagic trawl gears. The obligation to apply minimum levels of observer coverage is largely complied with, although difficulties have been experienced by all member nations in fully implementing the requirement of the regulation. Although regulation 812/2004 specifies observer coverage levels per region and fishery, there is an on-going debate at scientific and policy levels as to the appropriateness of continuing with some of the prescribed target observer coverage levels, with a view to possibly amending the regulation. The assessment team strongly recommends that the fishery continues compliance compliance with regulation 812/2004 until such time that changes to the regulation and its impacts on this fishery are made. Additional sources of data in relation to ETP interaction are observer programmes operated by Marine Scotland Science, BIM (Ireland) and CEFAS in other herring fisheries around the UK and Ireland. The assessment team note the discontinuance of observer programmes in Scottish pelagic fisheries at the present time in response to the low level of risk that the fishery is believed to present to ETP (and other) species. However, while operating, the UK discard observer programme has recorded occasional catches of seals and zero catches of cetaceans (ICES 2011; Pierce 2001). All observer programmes operated to date under 812/2004 reveal little or no bycatch of protected species in the herring fisheries of the Celtic Sea, North Sea and Irish Sea, as well as western waters. Accurate catch information is collected annually for the NIPSG fleet and there is good information in relation to the spatial operation of the fishery. Data are adequate for estimating fishery related mortality for ETP species. Accurate catch information is collected annually for the NIPSG fleet and there is good information in relation to the spatial operation of the fishery. Data are adequate for estimating fishery related mortality for ETP species. As a participant in ASCOBANS, the UK provides annual national reports with respect to activities that are relevant in the context of managing human impacts on cetacean populations. The reports are a useful reference and summarise annual activities and data that are relevant in the context of estimating
Justification fishery impacts. b Information is Information is Accurate and verifiable adequate to broadly sufficient to information is available on
understand the determine whether the magnitude of all impacts, impact of the fishery the fishery may be a mortalities and injuries and on ETP species. threat to protection the consequences for the and recovery of the status of ETP species.
Guidepost ETP species.
Met? Yes Yes No
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Relevant information is collected to support the management of fishery impacts on ETP species, including: Information for the development of the management strategy; PI 2.3.3 Information to assess the effectiveness of the management strategy; and Information to determine the outcome status of ETP species. There is adequate information in relation to the ETP species that may be affected by the fishery and the mechanisms of impact. There are adequate quantities of relevant data of sufficient quality to conclude that the fishery is unlikely to affect populations of ETP species, either directly or indirectly. While not conducted with the level of resources applied to a stock assessment for commercial fish species; estimates for ETP populations have been arrived at through a range of methodologies and are only considered best available estimates. There is reliable and on-going collection of data in relation to the fishery and its direct impacts on ETP species, including total catches, spatial extent and timing of the fishery. Information is highly likely to be sufficient to determine the implications for
Justification affected ETP species. c Information is Information is Information is adequate to adequate to support sufficient to measure support a comprehensive measures to trends and support a strategy to manage impacts, manage the impacts full strategy to minimize mortality and injury
on ETP species. manage impacts on of ETP species, and ETP species. evaluate with a high degree of certainty whether a strategy is achieving its
Guidepost objectives.
Met? Yes Yes No
There is adequate on-going collection of information in relation to catches of target species, as well as the spatial location, timing and extent of the fishery. Sufficient information has been collected in on-going observer programmes in order to conclude that the present fishery does not present a significant risk to ETP populations and to support an appropriate strategy to manage impacts. The observer programme run by SMRU/AFBI/BIM in recent years have generated sufficient data
to conclude that the pelagic trawl herring fishery presents a relatively low risk to cetacean species. AT SG80, for populations of other ETP species including pinnipeds and basking shark, sufficient data are recorded using on-board ETP logs to support a full strategy to manage impacts on ETP species. The data are compiled annually by the NIPSG and are available to interested parties outside of the NIPSG.
Justification » http://www.ascobans.org/pdf/ac19/AC19_2-10_NationalReportUK.pdf » Manx Basking Shark Watch » Hammond, PS, etal, 2002. Abundance of harbour porpoise and other cetaceans in the North Sea and adjacent waters. Journal of Applied Ecology 2002 39, 361–376 » SCANS - II– see www.smru.st-andrews.ac.uk and http://biology.st- References andrews.ac.uk/scans2/documents/issue9_Dec06.pdf » Pierce G, 2001. Pelagic fisheries in Scotland (UK) and Galicia (Spain): observer studies to collect fishery data and monitor by-catches. At » http://www.abdn.ac.uk/marfish/marmamm/pelagic.htm » http://www.ices.dk/reports/ACOM/2010/SGBYC/sgbyc_final_2010.pdf
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Relevant information is collected to support the management of fishery impacts on ETP species, including: Information for the development of the management strategy; PI 2.3.3 Information to assess the effectiveness of the management strategy; and Information to determine the outcome status of ETP species. » Kiely, O., Ligard, D., McKibben, M., Connolly, N. and Baines, M., 2000. Grey Seals : Status and Monitoring in the Irish and Celtic Seas Coastal Resources Centre, National University Of Ireland, Cork. » Atlas of the Distribution and relative abundance of Marine Mammals in Irish Offshore Waters 2005-2001. Irish Whale and Dolphin Group. Marine mammal atlas
OVERALL PERFORMANCE INDICATOR SCORE: 80
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 2.4.1 The fishery does not cause serious or irreversible harm to habitat PI 2.4.1 structure, considered on a regional or bioregional basis, and function
Scoring SG 60 SG 80 SG 100 Issue
a The fishery is The fishery is highly There is evidence that the unlikely to reduce unlikely to reduce fishery is highly unlikely to
habitat structure and habitat structure and reduce habitat structure and function to a point function to a point function to a point where where there would where there would be there would be serious or be serious or serious or irreversible irreversible harm.
Guidepost irreversible harm. harm.
Met? Yes Yes Yes
Herring shoals are targeted by the NIPSG fleet when they form dense shoals and are located at some point in the water column above the seabed, mainly during the hours of darkness, which is when the fishery mainly takes place. Herring is a pelagic species, which apart from demersal spawning events, spend their entire lifecycle above the seabed where they feed on a variety of copepods and carry out large migrations in pursuit of zooplankton aggregations. Herring are most abundant in areas of open water, where they tend to aggregate in large three-dimensional shoals above the seabed. Because they are a shoaling pelagic species, herring are most efficiently caught using mid-water trawls, which are used to fish the upper layers of the water column. The NIPSG fleet target herring with pelagic trawl gear that is not designed or intended to come into contact with the seabed. No heavy ground ropes, chains or wires reinforced with rubber rollers are necessary and the upper and lower leading edges of the nets usually are made of heavy rope that is not armoured in any way. Because of this, even the briefest encounter between fishing gear and the seabed can cause extensive damage to fishing gear. Pelagic trawl doors (when single vessel fishing) or large clump weights when pair trawling (up to 2 tonnes) are normally used to submerge a pelagic trawl and to prevent the net rising as the net is towed at speeds of up to 5 knots. Trawl doors or weights do not normally or intentionally make contact with the seabed during fishing operations. Trawl gear geometry and net position in the water column is closely monitored using electronic net mensuration equipment. Data available to skipper in real-time includes the depth of the headline and the footrope, as well as clearance from the footrope to the seabed. Vessels are also fitted with forward-looking sonar meaning they have a clear view of the seabed for up to 1 mile ahead of the vessels path. This assists skippers in avoiding seabed contacts by providing advance warning of obstructions, thereby providing sufficient time to take action to avoid damaging and expensive interaction between fishing gear and the seabed. Given that there is no contact with the seabed and that the fishery is spatially and
temporally concentrated, there is an insignificant level of risk that the fishery may cause harm to seabed habitats and environment. While the fishery may co-inside with a number of marine conservation areas and designated Natura 2000 sites in the UK, including the Pisces reef complex (see DEFRA EU sites) the fishery is highly unlikely to interact with or cause any significant
Justification effects to the conservation interests of these.
» OSPAR Maps of Sensitive seabed communities in the Northeast Atlantic. References At: www.ngo.grida.no/wwfneap/Projects/MPA.htm » DEFRA - UK European marine sites
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The fishery does not cause serious or irreversible harm to habitat PI 2.4.1 structure, considered on a regional or bioregional basis, and function
OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 2.4.2 There is a strategy in place that is designed to ensure the fishery does PI 2.4.2 not pose a risk of serious or irreversible harm to habitat types
Scoring SG 60 SG 80 SG 100 Issue
a There are measures There is a partial There is a strategy in place in place, if strategy in place, if for managing the impact of necessary, that are necessary, that is the fishery on habitat types.
expected to achieve expected to achieve the Habitat Outcome the Habitat Outcome 80 level of 80 level of performance. performance or
Guidepost above.
Met? Yes Yes Yes Herring aggregate in mid-water during feeding and only aggregate close to the seabed when spawning. Fishing operations target the discrete shoals in mid-water, normally well above the seabed. The pelagic trawl fishery seeks to actively avoid contact with the seabed in order not to damage expensive fishing gear that is not designed to withstand seabed contact. Measures that minimise fishing gear/ seabed interaction are in place across the fleet, including: » The use of electronics, such as depth sounders, sonar and trawl position monitoring systems. Forward looking scanning sonar on all vessels reveal seabed topography and contours up to 1.5miles ahead of the vessel, allowing sufficient time to change course or raise the net when approaching seabed obstructions are observed. Rapid changes to the position of the net can be made from the bridge using trawl winches or by adjusting vessel speed. All vessels use trawl monitoring sensors attached to the net, and monitors on the bridge display data on the height and spread of the net opening, depth of footrope of the net, and clearance between footrope and seabed. » Use of current technology with respect to displaying real time seabed bathymetry together with GPS navigational systems » Real time radio communication between vessels and sharing of information with respect to shola movements in real time while vessels are pairing
The most experienced skippers are normally present on the bridge and in control of the fishing operation, meaning that accidental contacts with the seabed are highly unlikely to occur. Vessels are known to comply with area closures (isle of Man spawning closure, 3nm fishery exclusion zone for larger vessels) and sensitive and/or ecologically
Justification sensitive areas are avoided where regulations prevent fishing. b The measures are There is some Testing supports high considered likely to objective basis for confidence that the strategy work, based on confidence that the will work, based on plausible argument partial strategy will information directly about the
(e.g. general work, based on fishery and/or habitats experience, theory information directly involved. or comparison with about the fishery similar and/or habitats
Guidepost fisheries/habitats). involved.
Met? Yes Yes No
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There is a strategy in place that is designed to ensure the fishery does PI 2.4.2 not pose a risk of serious or irreversible harm to habitat types
The method of fishing employed is well known and knowledge of the behaviour of herring shoals is also well developed. There is good information on the spatial location and timing of the fishery. Detailed information on the benthos is becoming available through on-going research for Scotland’s Marine Atlas, under UK commitments to OSPAR, the GIS project Marine Europe Seabed Habitat (MESH), and UK SeaMap 2010. However, there is incomplete information in relation to the distribution of sensitive habitats in all of the areas where the fishery may take place.
Justification There is no recording of seabed contact events on-board NIPSG vessels.
c There is some There is clear evidence that evidence that the the strategy is being partial strategy is implemented successfully. being implemented
Guidepost successfully.
Met? Yes Yes
Vessels do not fish on or close to the seabed. There are no interactions with seabed habitats. The pelagic environment is not degraded or impacted by the fishery. VMS records confirm compliance by the fleet with area closures.
Justification
d There is some evidence that the strategy is achieving its objective.
Guidepos t
Met? No
There is insufficient monitoring of seabed habitats in the Irish Sea in order to evaluate on-going status and whether or not strategies intended to prevent seabed
habitat impacts are likely to be successful. There is clear evidence of damage to seabed habitats in many parts of the Irish Sea through sustained and repeated demersal trawling activities over decades. The relative role of pelagic fisheries in this is unclear and there is on-going uncertainty over the future stats of Irish Sea habitats in the main as a result of direct physical impacts of fishing.
Justification » MESH, www.searchmesh.net » OSPAR Commission 2010. Quality Status Report 2010. OSPAR Commission, London. 108 + vii pp. At www.ospar.org References » 2011. Scotland’s Marine Atlas www.scotland.gov.uk/Publications » UK Sea Map 2010 http://jncc.defra.gov.uk/page-2117 » Irish Sea Pilot report (Irish Sea Pilot) OVERALL PERFORMANCE INDICATOR SCORE: 90
CONDITION NUMBER (if relevant):
Evaluation Table for PI 2.4.3
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Information is adequate to determine the risk posed to habitat types PI 2.4.3 by the fishery and the effectiveness of the strategy to manage impacts on habitat types
Scoring SG 60 SG 80 SG 100 Issue
a There is basic The nature, The distribution of habitat understanding of the distribution and types is known over their types and vulnerability of all range, with particular distribution of main main habitat types in attention to the occurrence
habitats in the area the fishery are known of vulnerable habitat types. of the fishery. at a level of detail relevant to the scale and intensity of the
Guidepost fishery.
Met? Yes Yes Yes The distribution of habitat types is available from various surveys and studies (OSPAR, MESH) - and the information is improved upon with ongoing research e.g. http://www.oceans2025.org/. Although seabed mapping for the area in which the
fishery operates is incomplete at a scale that is relevant to managing impacts of some fishing activities, this is of little consequence to this assessment, as the fishery occurs in mid-water and does not directly impact on benthic habitats. Mapping of vulnerable seabed habitats, such as leaking submarine gases, carbonate mounds and burrowing megafauna can be accessed at DEFRA - UK European marine sites.
Justification
b Information is Sufficient data are The physical impacts of the adequate to broadly available to allow the gear on the habitat types understand the nature of the impacts have been quantified fully. nature of the main of the fishery on impacts of gear use habitat types to be on the main habitats, identified and there is including spatial reliable information
overlap of habitat on the spatial extent with fishing gear. of interaction, and the timing and location of use of the
Guidepost fishing gear.
Met? Yes Yes Yes
The fishing gear does not impact or make contact with the seabed. There are no physical impacts. There are no known impacts of the fishing gear on the pelagic
habitat; the only possible physical impact of the gear on benthic habitat would be through net entanglement if the gear was to make contact with the seafloor. The nets would snap and break easily, and since nets are expensive, any contact with the seafloor is strenuously avoided. There are no records of gear losses in the fishery by the certified fleet and gear loss is not believed to occur.
Justification
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Information is adequate to determine the risk posed to habitat types PI 2.4.3 by the fishery and the effectiveness of the strategy to manage impacts on habitat types c Sufficient data Changes in habitat continue to be distributions over time are collected to detect measured. 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
Guidepost measures).
Met? No No
Scored at SG80. Changes in habitat distributions for all sensitive habitats in the North Sea are not measured over time at a scale that is relevant to fisheries impact management.
Justification
References
OVERALL PERFORMANCE INDICATOR SCORE: 95
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 2.5.1 The fishery does not cause serious or irreversible harm to the key PI 2.5.1 elements of ecosystem structure and function
Scoring SG 60 SG 80 SG 100 Issue a The fishery is The fishery is highly There is evidence that the unlikely to disrupt unlikely to disrupt the fishery is highly unlikely to the key elements key elements disrupt the key elements underlying underlying underlying ecosystem
ecosystem structure ecosystem structure structure and function to a and function to a and function to a point where there would be a point where there point where there serious or irreversible harm. would be a serious would be a serious or
Guidepost or irreversible harm. irreversible harm.
Met? Yes Yes No
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There is a good evidence base for understanding the status of the ecosystem in the Irish Sea, where the fisheries takes place. This evidence indicates that the fisheries are highly unlikely to disrupt key elements of the ecosystem. The key interaction with the ecosystem is the removal of the target species, which serves as a prey species for a wide range of fish, birds and marine mammals. The ecosystem role of the stock is preserved by ensuring the stock stays at or above precautionary levels. There have been no indications that the current harvest strategies for these stocks or their management plans and recent fishery removals have posed an unacceptable risk or impact to Irish Sea herring or predator or prey populations. Serious or irreversible harm to ecosystem structure may be indicated by trophic cascade, depletion of top predators, and severely truncated size composition of communities, gross changes in species biodiversity or changes in genetic diversity. Serious harm to ecosystem function may be indicated by depletion of prey species, especially low trophic species such as small pelagic (sprat/sardine/herring). In previous sections of the assessment report, evidence has been provided that demonstrates how the direct effects of the fishery do not cause serious or irreversible harm to retained and discarded species, endangered or protected species and seabed habitats. Indirect effects of fishing on marine ecosystems can include shifts in community structure and/or effects on the food web. There are few focused studies that have reviewed the impacts of fisheries on aspects of the Irish Sea ecosystem. WGRED (2008) however provides a useful summary of the main physical and biological features of the Irish Sea and evaluates the impacts of fisheries in the context of the wider Celtic Seas (of which the Irish Sea is a component) ecosystem. The overriding trend for fish populations in the Celtic Seas (including the Irish Sea) in recent years has been for decreases in abundance of key demersal species that predate smaller fish, while smaller pelagic species that feed at a lower trophic level have increased in abundance. According to WGECO (2008) most fishery resources in the Celtic Sea ecoregion are heavily exploited and the level of fishing mortality remains high on most species. There is good evidence of impacts of the fisheries extending across the ecosystem of the region and to date mitigation measures and regulations have not halted these declines. OSPAR (2010) compare aspects of fish community composition, structure and function (abundance, biomass and productivity, size composition, species richness, species evenness, life-history trait composition) in Region III (includes the Irish Sea) for the previous five years (2004-2009) with that of an eight-year reference period (1984-1991). Detrimental changes in abundance, biomass and productivity as well as size composition are clearly evident for fish communities throughout the region. While not directly relevant to the Irish Sea, Pinnegar et al (2003), Blanchard et al (2005) and Trenkel et al. (2004) assessed the relative effect of fisheries on the ecosystem of the adjacent Celtic Sea. It is concluded that the size structure of the fish community has changed significantly with a decrease in the relative abundance of large piscivorous demersal species, such as cod and hake, with a coincident increase in smaller pelagic species that feed at a lower trophic level. Zooplankton abundance has also declined throughout the region in recent years and the overall substantial decline in Calanus copepod abundance, which was assessed to be below the long‐term mean, may have longer term consequences given the fish community shift towards smaller pelagic species feeding on zooplankton (ICES, 2010). There is some evidence that suggests the decline in copepod abundance may be as a consequence of increased feeding pressure of smaller fish - itself an indirect effect of removal of larger predatory fish species through fishing (WGECO,2008). Climate change factors are also implicated. In the Irish Sea, herring is very close to its most southerly distribution in the Northeast Atlantic and is therefore expected to be vulnerable to environmental fluctuations. Warm sea temperatures result in a fast‐ growing and fast‐maturing stock, but high sea temperatures are expected to have
Justification a negative effect on recruitment. This has been as has been demonstrated by
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The fishery does not cause serious or irreversible harm to the key PI 2.5.1 elements of ecosystem structure and function Brander (1998) for other species at the southern limits of their distribution. However, temporal analyses of the effects of fishing and climate variation suggest that fishing has had a greater effect on fish community size‐structure than have changes in temperature (WGCSE, 2009). While there is clear evidence that there have been changes to the ecosystems within the Celtic Sea ecoregion in recent years, and that these are most likely the result of fishing activity, the fisheries that are considered to have be the principal cause of observed changes are those for demersal species. The Irish Sea herring is a pelagic stock and a significant link between the fishery for herring and observed reductions in demersal fish species abundance along with changes to fish community structure in the Irish Sea or adjacent waters has not been established. Available evidence indicates that smaller pelagics feeding at lower trophic levels have increased in abundance in recent years, due in part to heavy fishing pressure for demersal species. The key impact of the Irish Sea herring fishery with the ecosystem is the direct removal of the target species which is a low trophic species that serves as a prey species for a wide range of fish, birds and marine mammals. The dependence of other species groups on herring is reasonably well understood in a general context, even if the nature and extent of dependencies have not been investigated and described in detail for the Irish Sea. Despite this, generally available evidence supports the belief that that Irish Sea herring provide an important link between trophic levels. The relatively high numbers of cetaceans present in the Irish Sea and wider ecoregion, as well as abundant bird colonies, seal communities and some top predators including sharks, evidences this. Ecosystem risks associated with the removal of the target species have been considered under P1. The SSB is well above Bpa, defined as the point where there is a low probability of low recruitment and which is considered appropriate and likely to protect the fishery from over fishing. The current assessment shows the stock continues to improve. SSB is at the highest level since the 1970’s and continues to increase. Fishing mortality is estimated to be at the lowest level since the start of the assessment data in the 1960’s. There are no indications that the current harvest strategy /rebuilding plan and recent fishery removals have posed an unacceptable risk to herring predator or dependent predator populations. Further understanding of the role of target species in wider ecosystem balance is provided by reference to periods of low SSB during the early 1980’s and 2004-2005. In the context of the relatively major ups and downs that the Irish Sea herring stock has exhibited over the past 30- 40 years, it appears unlikely that fishery related removals have a dominant effect on the underlying ecosystem. There is no evidence that the fishery causes or contributes to serious or irreversible harm as might be indicated by evidence of trophic cascade, changes in species or genetic diversity or severely truncated size composition of any dependent or associated communities of fish, birds, invertebrates or marine mammals.
» Trenkel, V.M., Pinnegar, J.K., Dawson, W.A., Du Buit, M.H. and Tidd, A.N., (2005) Spatial and temporal predation patterns in the Celtic Sea. Marine Ecology‐Progress Series, 299: 257–268. References » Blanchard, J.L., Dulvy N.K., Ellis, J.E., Jennings S., Pinnegar, J.K., Tidd, A., and Kell, L.T. 2005. Do climate and fishing influence size‐based indicators of Celtic Sea fish community structure? ICES Journal of Marine Science, 62: 405–411.
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The fishery does not cause serious or irreversible harm to the key PI 2.5.1 elements of ecosystem structure and function » Borges, L., Rogan, E., and Officer, R. 2005. Discarding by the demersal fishery in the waters around Ireland. Fisheries Research, 76: 1–13. » Brander, K. 1998. Effects of environmental variability on growth and recruitment in cod (Gadus morhua) using a comparative approach. Oceanologica Acta, 23: 485 – 496. » ICES 2010. Life-cycle spatial patterns of small pelagic fish in the Northeast Atlantic. ICES Cooperative Research Report no.306.October 2010. » OSPAR (2010) Quality Status Report 2010. http://qsr2010.ospar.org/media/assessments/p00465_JAMP_QSR_fisheries_ assessment.pdf » Pinnegar J.K., Jennings, S., O’Brien, C.M. & Polunin N.V.C. (2002) Long‐ term changes in the trophic level of the Celtic Sea fish community and fish market price distribution. Journal of Applied Ecology, 39: 377–390. » Pinnegar, J.K., Trenkel, V.M., Tidd, A.N., Dawson, W.A. and Du Buit, M.H. (2003). Does diet in Celtic Sea fishes reflect prey availability? Journal of Fish Biology, 63 (Supplement A): 197–212. » WGCSE (2009). Report of the Working Group Celtic Sea Ecosystems. ICES. » WGECO (2008). Report of the Working Group on Ecosystem effects of Fishing Activities. ICES CM 2008/ACOM:41 » WGECO (2010). Report of the Working Group on Ecosystem effects of Fishing Activities. ICES CM 2010/ACOM:23 » WGRED (2008). Report of the Working Group for Regional Ecosystem Description. ICES CM 2008/ACOM:47
OVERALL PERFORMANCE INDICATOR SCORE: 80
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 2.5.2 There are measures in place to ensure the fishery does not pose a risk PI 2.5.2 of serious or irreversible harm to ecosystem structure and function
Scoring SG 60 SG 80 SG 100 Issue
a There are measures There is a partial There is a strategy that in place, if strategy in place, if consists of a plan, in place. necessary. necessary.
depost
Gui
Met? Yes Yes No There is a partial strategy in place to ensure the fishery does not pose a risk of serious or irreversible harm to ecosystem structure and function. The partial strategy comprises a range of measures that work together to achieve the outcome of avoiding serious or irreversible ecosystem harm. General regulatory measures in place that serve to limit adverse impacts of the fishery on the ecosystem include EC 2002; EC 1993; EC, 2006 & EC, 2000. There is a Long Term Management Plan in development for the Irish Sea herring stock. The fishery is subject to a quota that is revised annually according to scientific advice. ICES advice takes into account the ecosystem risk that is associated with the fishery. This recognises the importance of the herring stock as prey species for other communities in the Irish and Celtic Sea. Other ecosystem risks that may be associated with the fishery (retained catch of other species, bycatch, biodiversity and habitats) are managed by a range of measures that are considered to address potential issues effectively enough to meet the standard and to ensure there is no appreciable risk of serious or irreversible harm.
The fishery is subject to effective MCS that ensures all landings are recorded and there is high compliance in the fishery. Collectively the measures that are applied to the fishery take into account available information and are considered to be adequate to represent a partial strategy for restraining impacts. There is not a strategy that consists of an ecosystem management plan in place
Justification however (SG100).
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There are measures in place to ensure the fishery does not pose a risk PI 2.5.2 of serious or irreversible harm to ecosystem structure and function b The measures take The partial strategy The strategy, which consists into account takes into account of a plan, contains measures potential impacts of available information to address all main impacts the fishery on key and is expected to of the fishery on the elements of the restrain impacts of ecosystem, and at least ecosystem. the fishery on the some of these measures are ecosystem so as to in place. The plan and achieve the measures are based on well- Ecosystem Outcome understood functional 80 level of relationships between the performance. fishery and the Components and elements of the ecosystem.
This plan provides for development of a full
strategy that restrains impacts on the ecosystem to ensure the fishery does not cause serious or irreversible
Guidepost harm.
Met? Yes Yes No
The partial strategy considers available information including stock assessments, impacts of environmental parameters on recruitment of Irish Sea herring, mixing between Celtic Sea and Irish Sea stocks as well as natural and fishing mortality. The measures specifically implemented in the fishery such as TAC, area closures and a high level of MCS are expected to ensure that the outcome indicator at SG80 level
Justification of performance continue to be met on an on-going basis. c The measures are The partial strategy is The measures are considered likely to considered likely to considered likely to work work, based on work, based on based on prior experience, plausible argument plausible argument plausible argument or (e.g., general (e.g., general information directly from the
experience, theory experience, theory or fishery/ecosystems involved. or comparison with comparison with similar similar fisheries/ecosystems fisheries/ecosystems
Guidepost ). ).
Met? Yes Yes Yes
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There are measures in place to ensure the fishery does not pose a risk PI 2.5.2 of serious or irreversible harm to ecosystem structure and function Being a fishery that targets a low trophic species, the principal potential impact of the fishery is depletion of the herring stock itself, which is an important prey species. However the herring stock biomass is now at its highest recorded level since the early
1970’s and is now well above Bpa. The fishery features very low levels of impact with other biotic elements of the Celtic Sea ecosystem and a review of available information indicates that there is no evidence that the fishery is causing serious or irreversible harm to ecosystem structure or function (WGRED, 2008; WGCSE, 2009; WGECO, 2008, 2009).
Justification
d There is some There is evidence that the evidence that the measures are being
measures comprising implemented successfully. the partial strategy are being implemented
Guidepost successfully.
Met? Yes Yes
There is evidence that the management strategy is effective – the stock has been rebuilding after the herring stock SSB became depleted through over fishing in 2004/5. The stock is continuing to recover and biomass is continuing to increase, aided by rational and controlled exploitation. There is no evidence of significant detrimental effects on other ecosystem components (see 2.1.1, 2.2.1, 2.3.1, 2.4.1). There is no evidence of overshoot of TAC. There is no evidence of systematic non
Justification compliance and the fishery is associated with a high level of compliance.
» ICES 2013. Adice for herring in VIIa N north of 52 degrees 30’. ICES, Copenhagen. » DARD 2013(pers comms) EC (1993). » European Commission (1993)CFP Control Regulation – Reg 2847/1993 http://eur- lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:1993R2847:199807 01:EN:PDF » EC (2000). Reg 1543/2000 Council Regulation (EC) No 1543/2000 of 29 June 2000 establishing a Community framework for the collection and management of the data needed to conduct the common fisheries policy. http://eur- lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2000:176:0001:0016:EN: References PDF » EC (2002) Council Regulation No 2371/2002 of 20 December 2002 on the conservation and sustainable exploitation of fisheries resources under the Common Fisheries Policy. http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32002R2371: EN:HTML » EC (2006). European Commission (2006). CFP Regulation – Reg 861/2006. COUNCIL REGULATION (EC) No 861/2006 of 22 May 2006 establishing Community financial measures for the implementation of the common fisheries policy and in the area of the Law of the Sea. http://eur- lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2006:160:0001:0011:EN: PDF
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There are measures in place to ensure the fishery does not pose a risk PI 2.5.2 of serious or irreversible harm to ecosystem structure and function » WGCSE (2009). Report of the Working Group Celtic Sea Ecosystems http://www.ices.dk/reports/ACOM/-2009/WGCSE/01_General_2009.pdf » WGECO (2008). Report of the Working Group on Ecosystem effects of Fishing Activities. ICES CM 2008/ACOM:41 » WGECO (2010). Report of the Working Group on Ecosystem effects of Fishing Activities. ICES CM 2010/ACOM:23 » WGRED (2008). Report of the Working Group for Regional Ecosystem Description. ICES CM 2008/ACOM:47
OVERALL PERFORMANCE INDICATOR SCORE: 90
CONDITION NUMBER (if relevant):
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Evaluation Table for PI 2.5.3 There is adequate knowledge of the impacts of the fishery on the PI 2.5.3 ecosystem
Scoring SG 60 SG 80 SG 100 Issue
a Information is Information is adequate to identify adequate to broadly the key elements of understand the key the ecosystem (e.g., elements of the
trophic structure and ecosystem. function, community composition, productivity pattern
Guidepost and biodiversity).
Met? Yes Yes There is limited specific information available with regard to key biotic and abiotic elements of the Irish Sea ecosystem. In the context that the Irish Sea is part of the wider Celtic Seas ecoregion, WGRED (2008) provides a detailed summary of current knowledge with respect to the environmental conditions of the Celtic Seas including seabed topography and circulation, physical and chemical oceanography (temperature, salinity, pH) and freshwater input freshwater input as well as broad scale climatic and oceanographic factors that affect the region. JNCC (2004) provides more detailed information in relation to abiotic and biotic aspects of the Irish Sea and this provides some means for benchmarking ecological conditions prevailing during the 2000’s. Fish communities and trophic webs in the Irish sea are described in WGCSE (2009) but there has been little updating of this work since that period. Other related aspects
of the Celtic Seas ecosystem discussed in the report including seabirds, marine mammals and large elasmobranchs as well as fishery related impacts. The report provides a useful if limited summary of knowledge with regard to the Celtic Seas ecosystem (including the Irish Sea) and refers to the results of a wide range of studies that have investigated relevant aspects in greater detail. Overall information
Justification is adequate to broadly understand the key elements of the Irish Sea ecosystem. b Main impacts of the Main impacts of the Main interactions between fishery on these key fishery on these key the fishery and these ecosystem elements ecosystem elements ecosystem elements can be
can be inferred from can be inferred from inferred from existing existing information, existing information information, and have been and have not been and some have been investigated. investigated in investigated in detail.
Guidepost detail.
Met? Yes Yes No
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There is adequate knowledge of the impacts of the fishery on the PI 2.5.3 ecosystem Impacts of the fishery on key ecosystem elements can largely be inferred from existing information. Existing information points to the long time series of demersal fisheries of the Irish Sea having given rise to shifts in fish community abundance, structure and assemblages in the Celtic Sea (WGCSE, 2009; WGRED, 2008; WGECO, 2008). The fact that the herring fishery is a targeted fishery that catches very little by way of other species strongly supports the understanding that the main impacts of this fishery are associated with the removal of the target species and that other potential impacts are likely to be negligible or constrained by management measures in place within the fishery. Serious or irreversible harm to ecosystem structure as would be indicated by trophic cascade, depletion of top predators, severely truncated size composition of communities, gross changes in species biodiversity or changes in genetic diversity are not evident or referred to in documentation reviewed during the assessment as having resulted from the operation of the fishery under assessment. The fact that the Irish Sea herring stock has been rebuilt to the highest level since the 1970’s lend further support to this.
Some aspects of the potential impact of the fishery on ecosystem elements have been investigated in detail including spatial and temporal distribution of the fishery, capture of non-target fish species and interaction with ETP species and top predators (AFBI pers comms, Berrow et al 2008; Anon 2008-2011).
Justification
c The main functions of The impacts of the fishery on the Components (i.e., target, Bycatch, Retained target, Bycatch, and ETP species are
Retained and ETP identified and the main species and functions of these Habitats) in the Components in the ecosystem are ecosystem are understood.
Guidepost known.
Met? Yes No
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There is adequate knowledge of the impacts of the fishery on the PI 2.5.3 ecosystem Herring are a low trophic species that provide an important link between zooplankton and organisms that feed at higher trophic levels. As such it is an important prey species for a wide range of piscivorous fish that occur in the Celtic and Irish Seas (WGECO, 2008). There are no significant bycatch or retained species in this fishery, although the trophic web of the Irish Sea has not been described in detail, the main functions of this component in sustaining higher trophic strata is known (WGRED, 2008). Bycatch of ETP species is negligible in the fishery, however, interactions between cetaceans and fisheries when competing for common resources in the Celtic Seas have not been investigated in detail. Information on cetacean abundance, seasonal variability and feeding is necessary to support management. A number of recent studies have improved knowledge in relation to these issues, including some Marine Institute Sea Change funded projects (e.g. Marine Mammals and Megafauna in Irish waters - Behaviour, Distribution and Habitat use (PBA/ME/07/005(02)). Results better inform management in the future. The general function of the pelagic habitat is providing essential ecosystem goods and services to biological communities of the Celtic Sea are understood. The fishery does not interact in any significant manner with seabed habitats. Main functions of Principle 2 components are understood in terms of providing ecosystem goods and services and there is adequate level of knowledge in relation to these to indicate scoring at SG80. However the impacts of the fisheries have not been fully identified and there are significant gaps in knowledge in relation to specific impacts of these fisheries in relation to unrecorded fishing mortality (slippage) for target, retained and bycatch species. Greater levels of evidence in respect of these
Justification issues in particular would be necessary to justify scoring any higher (at SG100).
d Sufficient information Sufficient information is is available on the available on the impacts of impacts of the fishery the fishery on the on these Components and elements
Components to allow to allow the main some of the main consequences for the consequences for the ecosystem to be inferred. ecosystem to be
Guidepost inferred.
Met? Yes No Sufficient data are available in relation to the impacts of catches of retained species; bycatch species; endangered, threatened and protected species as well as interaction with seabed habitats to allow a qualitative and quantitative evaluation of the consequences for the ecosystem (for retained and bycatch species, habitat interaction); while it is sufficient to infer likely consequences arising from impacts on
marine mammal populations. The main consequences for the ecosystem as a result of the fisheries are highly likely to be restricted to consequences arising from removal of a proportion of the herring stocks. There is no significant bycatch, retained species are well documented and there is no significant habitat interaction. Ecosystem consequences can therefore be
Justification expected to be low.
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There is adequate knowledge of the impacts of the fishery on the PI 2.5.3 ecosystem
e Sufficient data Information is sufficient to continue to be support the development of collected to detect strategies to manage any increase in risk ecosystem impacts. level (e.g., due to changes in the outcome indicator
scores or the operation of the fishery or the effectiveness of the
Guidepost measures).
Met? Yes No
Data from the fisheries, as well as in relation to biological and oceanographic elements of the Irish Sea ecosystem continue to be collected on a routine basis by CEFAS, AFBI and the Marine Institute, amongst other organisations sharing an interest in the Irish Sea and/or the herring stock in VIIa. Data are regularly presented, reviewed and considered in a variety of ICES working groups, as well as within more specific research projects. It is expected that research efforts and data collection undertakings will continue into the future and will be augmented by data from fisheries for both stocks in relation to removals as well as spatial and temporal aspects of the fisheries. It is considered that current quantities and quality of data available and that are collected on an on-going basis are highly likely to be sufficient to allow for detection of an increase in risk to any ecosystem components. Data in relation to the fishery and biotic and abiotic ecosystem elements continue to be collected on a routine basis. It is expected that ongoing data collection data is sufficient to clearly identify any increased levels of risk to the ecosystem from the operation of the fishery. Greater analysis of existing and new datasets could however facilitate specific Irish Sea ecosystem investigations and would most likely assist in developing a detailed ecosystem model for the Irish Sea. This could then be used to better inform management, support the development of clear strategies to manage ecosystem impacts and would also be more representative of an ecosystem approach to managing the fisheries within the Irish Sea. SG100 is not met with on account of shortcomings in information and analysis that would support a greater
Justification degree of ecosystem based management of Irish Sea fisheries.
» WGECO (2008). Report of the Working Group on Ecosystem effects of Fishing Activities. ICES CM 2008/ACOM:41 » WGECO (2010). Report of the Working Group on Ecosystem effects of Fishing Activities. ICES CM 2010/ACOM:23 References » WGRED (2008). Report of the Working Group for Regional Ecosystem Description. ICES CM 2008/ACOM:47 » WGRED (2008). Report of the Working Group for Regional Ecosystem Description. ICES CM 2008/ACOM:47
OVERALL PERFORMANCE INDICATOR SCORE: 80
CONDITION NUMBER (if relevant):
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Evaluation Table for 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 PI 3.1.1 Principles 1 and 2; and Observes the legal rights created explicitly or established by custom of people dependent on fishing for food or livelihood; and Incorporates an appropriate dispute resolution framework. Scoring Issue SG 60 SG 80 SG 100
a There is an effective There is an effective There is an effective national national legal system national legal system legal system and binding and a framework for and organised and procedures governing cooperation with other effective cooperation cooperation with other parties parties, where with other parties, which delivers management necessary, to deliver where necessary, to outcomes consistent with MSC deliver management management Principles 1 and 2. outcomes consistent outcomes consistent with MSC Principles 1 with MSC Principles 1 and 2 and 2.
Guidepost
Met? Yes Yes Yes
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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 PI 3.1.1 Principles 1 and 2; and Observes the legal rights created explicitly or established by custom of people dependent on fishing for food or livelihood; and Incorporates an appropriate dispute resolution framework. At level of international law, the UK ratified the United Nations Convention on the Law of the Sea (UNCLOS) convention in 1996. The principle legislative instrument for fisheries management in the EU is the Common Fisheries Policy, which aims at achieving sustainable fisheries management across the EU. This clearly aims to achieve both P1 (stock management) and P2 (wider ecosystem impacts). For example, the regulation states: The scope of the CFP extends to conservation, management and exploitation of living aquatic resources ………. bearing in mind ……UNCLOS. The objective of the CFP should therefore be to provide for sustainable exploitation of living aquatic resources …….. in the context of sustainable development, taking account of the environmental, economic and social aspects in a balanced manner. Underneath the umbrella of the EU CFP, there are many binding regulations covering all aspects of fisheries, which are amended and updated as required. For example, some of the key recent pieces of legislation include the regulations on IUU and on control & enforcement. The UK and Northern Ireland national legislation implements all aspects of the reformed EU Common Fisheries Policy and establishes licensing, MCS and penalty procedures and as such aims at achieving sustainable fisheries in accordance to MSC P1 and P2. The requirement for cooperation for other parties in this fishery is less than in some other pelagic fisheries because the target species is not highly migratory, therefore there is no requirement for a coastal states agreement. Furthermore, the division of quota is established under the binding EU principle of relative stability meaning that the quota is consistently shared between member states according to a fixed ratio informed by historical track record in the fishery. In this case the TAC is divided between the UK and the Republic of Ireland. In recent years the quota has been traded (after initial allocation) between the Republic of Ireland and UK (Northern Irish POs), typically in return for nephrops or whitefish quota. There are also clear and binding rules governing the allocation of quota within the UK between the devolved administrations of Wales, Scotland and Northern Ireland. Much of this fishery occurs in the territorial waters of the Isle of Man. To fish within the 3-12nm zone UK registered vessels must hold an additional Isle of Man fishing permit which is issued bi-annually. There is a binding fishing agreement to ensure
cooperation between the UK and Isle of Man governments on issues of fisheries management. The most recent of these is from 2012. This sets out the principles of fair access to each administration’s waters by vessels of both the UK and Isle of Man and stipulates that the Isle of Man government will keep rules and laws for the management of fisheries within its territorial seas in line with the UK commitments
Justification under the EU Common Fisheries policy.
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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 PI 3.1.1 Principles 1 and 2; and Observes the legal rights created explicitly or established by custom of people dependent on fishing for food or livelihood; and Incorporates an appropriate dispute resolution framework. b The management The management The management system system incorporates or system incorporates or incorporates or subject by law is subject by law to a is subject by law to a to a transparent mechanism for mechanism for the transparent mechanism the resolution of legal disputes resolution of legal for the resolution of that is appropriate to the disputes arising within legal disputes which is context of the fishery and has the system. considered to be been tested and proven to be effective in dealing with effective. most issues and that is appropriate to the
Guidepost context of the fishery.
Met? Yes Yes Yes
Due to the small scale of the fishery, the fact that it takes place entirely within EU waters (or within IoM waters where an effective agreement applies – see below) and with only a maximum of 2 member states participating there is a lower likelihood of legal dispute between countries. There is no requirement for a Coastal States Agreement, as in other Pelagic Fisheries, which have increased potential for dispute. Within EU Pelagic fisheries there is a good record of unity, enhanced by the establishment of Regaional Advisory Councils at the time of the last CFP reform (2002). Since then the Pelagic RAC has proven effective at providing opportunities for the industry and managers to collaborate, typically via Producer Organisations, in a proactive manner to avoid disputes arising. Outside of the EU context, there is a fishery agreement between the UK and the Isle of Man which clearly states that if parties are unable to resolve a dispute then a binding decision will be taken by an arbitrator appointed by the president of the Chartered Institute of Arbitrators, with the costs borne equally by all parties to the dispute. Disputes within Northern Ireland, for example between Producer Organisations could be resolved through normal legal channels. Any evidence of fishery infringements detected by the North Irish (DARD) enforcement officers would
be passed to the Northern Irish Public Prosecution Service (PPS) and fishers would have full right of appeal. There is no recent record of legal dispute to provide evidence of efficacy, however it is appropriate to the context of the fishery (large scale / high value) that should it be necessary, the Northern Ireland judicial process would apply. This process is in constant use and as such has been tested and proven to be
Justification effective.
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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 PI 3.1.1 Principles 1 and 2; and Observes the legal rights created explicitly or established by custom of people dependent on fishing for food or livelihood; and Incorporates an appropriate dispute resolution framework. d The management The management The management system has a system has a system has a mechanism to formally commit mechanism to mechanism to observe to the legal rights created generally respect the the legal rights created explicitly or established by legal rights created explicitly or established custom of people dependent on explicitly or by custom of people fishing for food and livelihood in established by custom dependent on fishing a manner consistent with the of people dependent for food or livelihood in objectives of MSC Principles 1 on fishing for food or a manner consistent and 2. livelihood in a manner with the objectives of consistent with the MSC Principles 1 and objectives of MSC 2.
Guidepost Principles 1 and 2.
Met? Yes Yes No
126 version 2.0 (01/06/13) Food Certification International Final Report Northern Ireland Pelagic Sustainability Group (NIPSG) Irish Sea Herring Fishery
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 PI 3.1.1 Principles 1 and 2; and Observes the legal rights created explicitly or established by custom of people dependent on fishing for food or livelihood; and Incorporates an appropriate dispute resolution framework. The EU CFP sets out a formal commitment to the legal and customary rights of people dependent on fishing, through a commitment to relative stability (meaning Member States are consistently allocated the same proportion of particular stocks): “In view of the precarious economic state of the fishing industry and the dependence of certain coastal communities on fishing, it is necessary to ensure relative stability of fishing activities by the allocation of fishing opportunities among the Member States, based upon a predictable share of the stocks for each Member State.” How the allocation is divided within member states is then laid out at national level in the National Strategy Plan (in accordance with EC no 1198/2006). The UK National Strategic Plan for the European Fisheries Fund (2007 -2013) explicitly considers fishing communities and includes a number of socio-economic objectives, which can be achieved whilst remaining consistent with P1 & 2 (stock management & ecosystem) objectives. These are primarily included under Theme 4, whose principle objective “is tackle social exclusion and promote long term prosperity in communities traditionally dependent on the catching sector”. This national strategy was developed by both UK and devolved administrations. In terms of relevant customary fishing rights for those depending on fishing for food or livelihood, the Mourne coastal fishery warrants mention. This fishery was highlighted for consideration by one of the stakeholders that the assessment team
met with during the site visit. This Northern Irish coastal fishery targets VIIaN herring using drift gill nets from ‘skiff’ vessels no more than 12m LOA. This fishery receives a set allocation of the VIIaN quota which safeguards this traditional inshore fishery. In recent years this has been set at 30t for a short seasonal fishery. Fishers wishing to partake in the fishery must apply for a permit each autumn season.
Justification The quota allocation provided to this inshore fishery is comparatively small, and far smaller than it has been historically, when over 1,000t was allocated to the fishery and there is now demand for a greater share of the overall TAC. Historically small inshore vessels have been poorly represented in the fisheries management process in the UK and it is also claimed that the scale of historic catches by the inshore sector have been routinely underestimated and therefore quota allocations to inshore fisheries have failed to recognise the inshore sector’s track record. According to DARD (pers comms.) the reallocation of quota share from the coastal fishery to the main VIIaN herring fishery has taken place over a number of years making use of quota which had not been taken up in the Mourne fishery. It is only in recent years with the increase in herring quota and the increase in herring price that the demand of inshore fishers to participate in the Mourne Fishery has increased, including from a number of fishers without historical track record in the fishery. Around half of the fishers active in the Mourne fishery are part time and many are also young fishermen, relatively new to the fishery. In July 2013 a UK high court ruling found that the UK government could reallocate underutilized quota from large vessels in Producer Organisations back to smaller inshore vessels. However, as the VIIaN herring quota is fully utilized it is not anticipated that this ruling will lead to any change in the existing allocation to the Mourne fishery. However, DARD are seeking to enable an additional amount of quota to be leased by the Mourne fishery.
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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 PI 3.1.1 Principles 1 and 2; and Observes the legal rights created explicitly or established by custom of people dependent on fishing for food or livelihood; and Incorporates an appropriate dispute resolution framework. However, DARD are seeking to enable an additional amount of quota to be leased by the Mourne Fishery. There has been no forcible removal of quota from coastal communities, and the Mourne fishermen are eligible to buy or lease quota as any other fisherman in an open market. The coastal communities are not indigenous populations dependent on fishing for food, indeed those in the Irish Sea herring fishery under assessment have their background in the Mourne coastal fishery. Representatives of the Isle of Man Fisheries Directorate (within the Department of Environment Food and Agriculture) also highlighted the fact that Isle of Man fishers do not have access to the herring catch within their waters – aside from a very small coastal fishery. It is understood that historically Isle of Man fishers did have a larger share of catches but that their allocation reduced when quota was allocated to EU Producer Organisations, which the Isle of Man (outside the EU) did not have access to. However, in the context of the MSC this issue does not relate to the customary rights of those dependent of fishing for food or livelihood. More generally, the Manx Fish Producers Organisation was established in 2003, for the management of quota, however this occurred after initial allocation of quota for Irish Sea herring had taken place. Whilst the fisheries management system clearly recognises the inshore sector, including ring fencing some quota for smaller vessels, it does not formally commit to safeguard traditional fishing communities or traditional fishing methods. This scoring issue is therefore scored at SG80.
» DEFRA et al (2013). FISH QUOTAS. UK MANAGEMENT RULES (2013). Issued by Department for Environment, Food and Rural Affairs, Marine Management Organisation, Marine Scotland, Department of Agriculture and Rural Development Northern Ireland, Welsh Government.
» EC 2002. Council Regulation No 2371/2002 of 20 December 2002 on the conservation and sustainable exploitation of fisheries resources under the Common Fisheries Policy. Official Journal of the European Union L 358, 59- 80. References » http://www.pelagic-rac.org/ » The United Kingdom National Strategic Plan For The European Fisheries Fund (2007 – 2013) » The United Kingdom Operational Programme For The European Fisheries Fund (2007-2013) » DARD pers comms » Isle of Man Fisheries Directorate pers comms.
OVERALL PERFORMANCE INDICATOR SCORE: 95
CONDITION NUMBER (if relevant): n/a
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Evaluation Table for 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
Scoring Issue SG 60 SG 80 SG 100
a Organisations and Organisations and Organisations and individuals individuals involved in individuals involved in involved in the management the management the management process have been identified. process have been process have been Functions, roles and identified. Functions, identified. Functions, responsibilities are explicitly roles and roles and defined and well understood for responsibilities are responsibilities are all areas of responsibility and generally understood. explicitly defined and interaction. well understood for key areas of responsibility
Guidepost and interaction.
Met? Yes Yes No
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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
The functions, roles and responsibilities are explicitly defined and well understood for key areas of responsibility and interaction. These are set out below. Management responsibility: EU / DG Mare takes overall responsibility for management of Irish Sea Herring with decisions on TAC and technical conservation measures ultimately taken at an EU level. Within the UK DEFRA / MMO takes overall responsibility for fisheries policy and licensing. Within the devolved administration of Northern Ireland the Fisheries & Environment Division of DARD has administrative responsibility for sea fisheries in Northern Ireland waters including enforcement of fisheries legislation and fishing vessel licensing; the administering of fisheries grant schemes (under the Fisheries Act (Northern Ireland) 1966 as amended). Within the Isle of Man jurisdiction the Fisheries Directorate (within the Department of Environment Food and Agriculture) has overall responsibility for management although in this fishery they are not engaged in the stock management, they do play an important role in elements of spatial management and protection of spawning / nursery grounds. Control and Enforcement: All enforcement of landings in Northern Ireland is carried out by DARD enforcement officers. Inspections within the Irish Sea can be carried out by DARD enforcement officers or the Royal Navy Fishery Protection Squadron, or if in waters of the Republic of Ireland by the Sea Fisheries Protection Authority (SFPA), or in the waters of the Isle of Man by the Isle of Man Fisheries Directorate. Oversight of enforcement activity is carried out an EU level by European Fisheries Control Agency in Vigo. Science: The majority of routine scientific work and supporting surveys on Irish Sea herring is carried out by AFBI (of DARD). However, as the stock is an EU managed quota species all stock assessments are an output of the ICES herring assessment working group (HAWG). This brings scientists from both the Irish Marine Institute and Marine Scotland (Science), as well as those from other member states together to conclude the assessment process. Stakeholder Representation: The vessels covered by this assessment are either members of The Northern Ireland Fish Producers Organisation (NIFPO) or ANIFPO. In turn, representatives NIFPO and ANIFPO are represented at the Pelagic Regional Advisory Council (RAC). By this conduit, stakeholders in the fishery are able to contribute to the management decision making process. The final element of the management decision making process that is playing an important role at present is the GAP II funded project, administered by the Pelagic RAC, which is currently playing an active role in developing a management plan,
including harvest control rules for the Irish Sea Herring Fishery. This project mainly involves stakeholders in the fishery from Northern Ireland, although it is understood that representative of the Isle of Man Fisheries Directorate were also invited to attend. There is further mention of the work of this project under ‘Decision-making processes’ (PI 3.2.2). This grouping is ad hoc, so may not be well defined and its roles may not
Justification be well understood by all stakeholders. For this reason SG100 is not met.
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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
b The management The management The management system system includes system includes includes consultation processes consultation processes consultation processes that regularly seek and accept that obtain relevant that regularly seek and relevant information, including information from the accept relevant local knowledge. The main affected parties, information, including management system including local local knowledge. The demonstrates consideration of knowledge, to inform management system the information and explains the management demonstrates how it is used or not used. system. consideration of the
Guidepost information obtained.
Met? Yes Yes No
At a European level there is an active consultation process on key fishery decisions. A list of fishery consultations is provided on the main europa web portal (http://ec.europa.eu/dgs/maritimeaffairs_fisheries/consultations/index_en.htm ). This includes a summary of contributions and in some cases, synthesis of results. As part of its decision making process DARD also seek the views of members of the public on key policy decisions. These are prominently advertised on the DARD website (further details in the scoring issue below). Overall, at multiple layers of the governance structure there appears to be good evidence of consultation mechanisms although less evidence of explanations as to
Justification how this information is used or not used.
c The consultation The consultation process process provides provides opportunity and opportunity for all encouragement for all interested and affected interested and affected parties parties to be involved. to be involved, and facilitates
Guidepost their effective engagement.
Met? Yes No
By way of example, DARD currently has an open consultation on the Introduction of a System of Electronic Notice of Variations to Fishing Licenses. This is advertised on the department’s website. To facilitate effective engagement the department has also issued in hard copy of the consultation covering letter and consultation report form to DARD licensed vessel owners or their nominees; CEO’s of ANIFPO and NIFPO; and Representatives of the Fish Catching Sector. However, in the context of this fishery there is perhaps greater potential to encourage more engagement with the Isle of Man fishing authorities and consider how best to
Justification facilitate their effective engagement.
» http://ec.europa.eu/fisheries/cfp/control/who_does_what/index_en.htm » European Fisheries Control Agency http://cfca.europa.eu/pages/home/home.htm References » Royal Navy Fishery Protection Squadron http://www.royalnavy.mod.uk/Operations/Enduring-Operations/UK/Fishery- Protection
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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 » DARD Fisheries & Environment Division http://www.dardni.gov.uk/index/fisheries.htm » Agri-Food & Biosciences Institute http://www.afbini.gov.uk/ » Pelagic Regional Advisory Council http://www.pelagic-rac.org/
OVERALL PERFORMANCE INDICATOR SCORE: 80
CONDITION NUMBER (if relevant): n/a
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Evaluation Table for PI 3.1.3
The management policy has clear long-term objectives to guide decision- PI 3.1.3 making that are consistent with MSC Principles and Criteria, and incorporates the precautionary approach
Scoring Issue SG 60 SG 80 SG 100
a Long-term objectives Clear long-term Clear long-term objectives that to guide decision- objectives that guide guide decision-making, making, consistent decision-making, consistent with MSC Principles with the MSC consistent with MSC and Criteria and the Principles and Criteria Principles and Criteria precautionary approach, are and the precautionary and the precautionary explicit within and required by approach, are implicit approach are explicit management policy. within management within management
Guidepost policy policy.
Met? Yes Yes Yes
The United Kingdom National Strategic Plan for the European Fisheries Fund (2007 – 2013) sets out clear long term objectives to guide decision making. This also covers the devolved administrations (including Northern Ireland). These objectives are explicit and are consistent with the MSC principles and criteria and clearly stipulate the precautionary approach. These are required by overarching EU management policy (Article 15 of Council Regulation (EC) No 1198/2006). The objectives set out in the National Strategic Plan are laid out in themes. The first of these themes is the
sustainable exploitation of fishery resources, under which are the principle objectives: » to promote sustainable fisheries consistent with a diverse and resilient marine environment; » to ensure that fisheries management within the UK is seen as an example of
Justification best practice;
References DEFRA (2008). The United Kingdom National Strategic Plan for the European Fisheries Fund (2007 – 2013).
OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant): n/a
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Evaluation Table for PI 3.1.4
The management system provides economic and social incentives for PI 3.1.4 sustainable fishing and does not operate with subsidies that contribute to unsustainable fishing
Scoring Issue SG 60 SG 80 SG 100
a The management The management The management system system provides for system provides for provides for incentives that are incentives that are incentives that are consistent with achieving the consistent with consistent with outcomes expressed by MSC achieving the achieving the outcomes Principles 1 and 2, and outcomes expressed expressed by MSC explicitly considers incentives in by MSC Principles 1 Principles 1 and 2, and a regular review of and 2. seeks to ensure that management policy or perverse incentives do procedures to ensure they do not arise. not contribute to unsustainable
Guidepost fishing practices.
Met? Yes Yes No
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The management system provides economic and social incentives for PI 3.1.4 sustainable fishing and does not operate with subsidies that contribute to unsustainable fishing
The justification for this PI is similar to all fisheries operating under the umbrella of the EU Common Fisheries Policy and scoring is therefore the same as other similar pelagic fisheries. Since the 2002 revision of the CFP, subsidies that contribute to unsustainable fishing have stopped. There is no support to increase capacity, or to compensate for low catches. There are some minor forms of subsidy which could be identified for this fishery, however, in the opinion of the assessment team these do not contribute to unsustainable fishing and are consistent with MSC principles 1 and 2. These are: » The industry does not pay directly for management or science (although this is funded through taxation) which could be construed as effective subsidy. » A preferential tax system is applied to diesel across all EU primary production sectors, which could be considered a subsidy relative to other economic sectors, but this is difficult to argue for fisheries as a whole as European countries apply a far higher level of taxation on fuel than any other economic block in the world (with the exception of Japan). » The EC’s structural funding mechanisms to the fishery sector –the European Fisheries Fund (EFF) – provides targeted financial support to the sector, but funding restrictions have been significantly tightened (focus on improvements in safety and environmental impact). No detrimental subsides, which contribute to unsustainable fishing practices have been identified for this fishery. At national level, the management system provides economic and social incentives for sustainable fishing. These include: » Significant penalties exist for overshoot of member quota share, including immediate criminal proceedings. Such penalties act as an economic and social incentive for compliance. The most recent review of the CFP does give increased consideration of the question of address the question of incentives much more explicitly. Themes in the latest reform proposals also include increased industry responsibility and even self- management – again motivated by the need to incentives fishermen to become involved in the stewardship of their resource. However, overall, within the context of the EU CFP it is concluded that explicit consideration of incentives is not yet included in regular review although the assessors do conclude that the management system provides for incentives. And seeks to ensure that negative incentives do not arise. In addition, the boats covered by this assessment operate to an ITQ system in respect of the eligibility to exploit UK pelagic quota. This gives skippers and owners greater discretion as to how they organise the harvesting of available quota. In
addition, skippers know their annual allocation of quota in advance of fishing. This means that fishing operations can be carefully planned and timed best to maximise market value, and fish at times of best fishing efficiency. Minor overshoots of quota can be accommodated within the tradeable quota system to ensure that quota is fully used, but that there is reduced likelihood of slippage if an individual exceeds quota
Justification on a given haul. » Common Fisheries Policy EC (2371/2002) » European Fisheries Fund (EC) No 1198/2006 References
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The management system provides economic and social incentives for PI 3.1.4 sustainable fishing and does not operate with subsidies that contribute to unsustainable fishing » COM(2011) 417. Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions; Reform of the Common Fisheries Policy. » COM(2011) 425 final. Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the Common Fisheries Policy
OVERALL PERFORMANCE INDICATOR SCORE: 80
CONDITION NUMBER (if relevant): n/a
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Evaluation Table for 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
Scoring Issue SG 60 SG 80 SG 100
a Objectives, which are Short and long-term Well defined and measurable broadly consistent with objectives, which are short and long-term objectives, achieving the consistent with which are demonstrably outcomes expressed achieving the outcomes consistent with achieving the by MSC’s Principles 1 expressed by MSC’s outcomes expressed by MSC’s and 2, are implicit Principles 1 and 2, are Principles 1 and 2, are explicit within the fishery’s explicit within the within the fishery’s management system fishery’s management management system.
Guidepost system.
Met? Yes No No
As the harvest control rule has yet to be adopted (see P1), there is no fishery specific EU regulation setting out the short and long term objectives for this fishery. As such, there is no fishery specific long term management plan, either in the form of a harvest control rule or a broader scale plan setting out overall objectives. In spite of this there are clear objectives which are implicit within the fisheries management system which aim to meet the outcomes expressed by MSC principles 1 & 2. These objectives, although not fishery specific are binding under the principles of subsidiarity, meaning that management decisions are informed by higher level policy commitments at an EU level. Some of these are explicit, such as the EU Member States, political commitment to manage their fish stocks for MSY made at the World Summit on Sustainable Development in Johannesburg in 2002. Following on from this in July 2006 the Commission published a Communication outlining how it proposed to move towards managing EU fish stocks for MSY. Fishing opportunities for quota species, including Irish Sea herring are determined according to this commitment. Additionally, the higher level regulations do contain relevant ecosystem objectives, such as those contained in the CFP regulation and these serve as binding objectives
Justification for all relevant EU fisheries including this one.
» EC 2002. Council Regulation No 2371/2002 of 20 December 2002 on the conservation and sustainable exploitation of fisheries resources under the Common Fisheries Policy. Official Journal of the European Union L 358, 59- References 80. » COM (2006)360 final. Communication from the Commission to the Council and the European Parliament: Implementing sustainability in EU fisheries through maximum sustainable yield, Brussels, 4.7.2006.
OVERALL PERFORMANCE INDICATOR SCORE: 60
CONDITION NUMBER (if relevant): 3
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Evaluation Table for PI 3.2.2
The fishery-specific management system includes effective decision-making processes that result in measures and strategies to achieve the objectives, PI 3.2.2 and has an appropriate approach to actual disputes in the fishery under assessment.
Scoring Issue SG 60 SG 80 SG 100
a There are some There are established decision-making decision-making processes in place that processes that result in result in measures and measures and strategies to achieve strategies to achieve the fishery-specific the fishery-specific
Guidepost objectives. objectives.
Met? Yes Yes
Fishery decisions are informed by scientific advice. This process involves AFBI scientists presenting survey results and analysis to the ICES herring assessment working group (HAWG). Once adopted this is presented by ACOM and is further reviewed and translated into management advice by the EU STECF. The final decision on TAC is therefore reached at the EU council of ministers December Council Meeting which determine fishing opportunities for the subsequent year. This is an established process that is well understood by stakeholders in European fisheries and in recent years this has resulted in decisions about Irish Sea herring which have been in line with the scientific advice (with the exception of 2011 when the TAC was set above the level of the management advice). Given that so much of the fishery takes place in the waters of the Isle of Man (who are not EU members) it is interesting to note that there are some decisions which may impact on the management of the fishery that are taken by the Isle of Man government, effectively through a different decision making process. Perhaps most notable of these would be decisions over closed areas in the Isle of Man’s own waters. The Isle of Man Government have expressed an interest in being more involved in the fishery decision making process, although it is recognized that the majority of decisions are taken at a European level. More recently, some important decisions on the development of the harvest control rule are being taken by the Gap 2 project. However, this is not seen as being a
management decision-making body and the proposed harvest control rule would be submitted first to the Pelagic RAC, then to ICES for evaluation and finally to EU STECF and the European Council where the decision would be taken to adopt the rule. Furthermore the Gap 2 project is not intended influence in decisions over quota allocations, closed areas or any other technical conservation measures. So no
Justification decision making has been devolved to a stakeholder grouping.
b Decision-making Decision-making Decision-making processes processes respond to processes respond to respond to all issues identified serious issues serious and other in relevant research, identified in relevant important issues monitoring, evaluation and research, monitoring, identified in relevant consultation, in a transparent, evaluation and research, monitoring, timely and adaptive manner consultation, in a evaluation and and take account of the wider transparent, timely and consultation, in a implications of decisions. adaptive manner and transparent, timely and take some account of adaptive manner and the wider implications take account of the of decisions. wider implications of
Guidepost decisions.
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The fishery-specific management system includes effective decision-making processes that result in measures and strategies to achieve the objectives, PI 3.2.2 and has an appropriate approach to actual disputes in the fishery under assessment.
Met? Yes Yes No
In the 1990s there was a poor record of setting fishing opportunities in line with
scientific advice. Since 2002, there has been much improved setting of fishing opportunities in line with scientific advice, although in opportunities were set slightly above advice in 4 years from 2008 to 2012. The HAWG identifies important issues, and these would be clearly captured in advice with decision-makers likely to respond. The CFP requires that the Commission shall take into account the advice from the
Justification STECF when presenting proposals on fisheries management.
c Decision-making processes use the precautionary approach and are based on best available information.
Guidepost
Met? Yes
The commitment to the precautionary approach is enshrined in all EU decision making processes and the Common Fisheries Policy. Decisions on EU fishing opportunities clearly state that for fisheries where stock status is unknown, precautionary quotas will be set. Indeed it was partly the past setting of a more precautionary quota that has provided some of the impetus for the recent stock
Justification assessment work and the development of the harvest control rule.
d Some information on Information on fishery Formal reporting to all fishery performance performance and interested stakeholders and management management action is provides comprehensive action is generally available on request, information on fishery available on request to and explanations are performance and management stakeholders. provided for any actions and describes how the actions or lack of action management system associated with responded to findings and findings and relevant relevant recommendations recommendations emerging from research, emerging from monitoring, evaluation and research, monitoring, review activity. evaluation and review
Guidepost activity.
Met? Yes Yes No
It is possible to review the advice for the fishery over many years on the ICES website (the outputs of the HAWG provide more detail) and it is also possible to see the management response to advice over many years by comparing the advised TAC with the agreed TAC. In this way it is possible to get a picture of how management
has responded to advice. Similarly it is possible to see if additional issues raised have been responded to by management, such as where advice highlights an apparent compliance issue, or a particular environmental impact. However, there is no formal reporting of the actual management decision-making process i.e. minutes of key EU Council meetings which determine the level or the share of quotas are not formally
Justification published – at least not in a way that is accessible to all.
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The fishery-specific management system includes effective decision-making processes that result in measures and strategies to achieve the objectives, PI 3.2.2 and has an appropriate approach to actual disputes in the fishery under assessment.
e Although the The management The management system or management authority system or fishery is fishery acts proactively to avoid or fishery may be attempting to comply in legal disputes or rapidly subject to continuing a timely fashion with implements judicial decisions court challenges, it is judicial decisions arising from legal challenges. not indicating a arising from any legal disrespect or defiance challenges. of the law by repeatedly violating the same law or regulation necessary for the sustainability
Guidepost for the fishery.
Met? Yes Yes No
There is no local stakeholder body or forum which could be used to proactively avoid legal disputes although the small nature of the fishery and the fact that the 2 producer organisions (POs) work together indicates that there is a good working relationship
between parties. This is particularly indicated by the fact that boats from different producer organisations pair trawl together. Additionally the Pelagic RAC provides an important stakeholder forum for pelagic fishers which helps to avoid disputes arising. Consequently, the assessment team are not aware of any judicial decisions arising from legal challenges – but if there were these would be expected to be complied
Justification with.
» EC 2002. Council Regulation No 2371/2002 of 20 December 2002 on the conservation and sustainable exploitation of fisheries resources under the Common Fisheries Policy. Official Journal of the European Union L 358, 59- References 80. » http://www.pelagic-rac.org/ » GAP II project: http://gap2.eu/
OVERALL PERFORMANCE INDICATOR SCORE: 80
CONDITION NUMBER (if relevant): n/a
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Evaluation Table for PI 3.2.3
Monitoring, control and surveillance mechanisms ensure the fishery’s PI 3.2.3 management measures are enforced and complied with
Scoring Issue SG 60 SG 80 SG 100
a Monitoring, control and A monitoring, control A comprehensive monitoring, surveillance and surveillance control and surveillance system mechanisms exist, are system has been has been implemented in the implemented in the implemented in the fishery under assessment and fishery under fishery under has demonstrated a consistent assessment and there assessment and has ability to enforce relevant is a reasonable demonstrated an ability management measures, expectation that they to enforce relevant strategies and/or rules. are effective. management measures, strategies
Guidepost and/or rules.
Met? Yes Yes No
A monitoring, control and surveillance system is in place in this fishery including VMS, e-log books, inspections at sea – by whichever enforcement body has jurisdiction over the waters they are fishing (UK, Isle of Man or Republic of Ireland) – obligatory hailing prior to landing, landing restricted to designated ports, a ban on transshipment, landing inspections, cross-referencing of landing declarations and sales notes, factory through put inspections. The system was recently inspected by
a mission from the EU Control & Enforcement Coordination Centre (Daly & Skrey 2013). This concluded that minimum inspection benchmarks were achieved in 2012. The assessors have not scored the system as comprehensive as the level of inspection of landings was lower than in comparable fisheries, although DARD highlight that this is based on an appropriate analysis of risk and that the level of
Justification inspection also meets the EU requirement.
b Sanctions to deal with Sanctions to deal with Sanctions to deal with non- non-compliance exist non-compliance exist, compliance exist, are and there is some are consistently applied consistently applied and evidence that they are and thought to provide demonstrably provide effective applied. effective deterrence. deterrence.
Guidepost
Met? Yes Yes No
There are clear sanctions to deal with noncompliance and the many potential non- compliances are well understood by industry, such as inaccuracies in landing declarations, or failure to comply with technical regulations, such as mesh size, infringements of closed areas. The fishers in the fleet under assessment referred to
a high level of control and a clear threat of prosecution, in event of non-compliance. In order to standardize infringements across member states the EU has established a list of serious infringements of the rules of the common fisheries policy. EU
fication countries must include in their legislation effective, proportionate and dissuasive sanctions, and ensure that the rules are respected, this is currently being translated
Justi into the national control programme.
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Monitoring, control and surveillance mechanisms ensure the fishery’s PI 3.2.3 management measures are enforced and complied with
c Fishers are generally Some evidence exists There is a high degree of thought to comply with to demonstrate fishers confidence that fishers comply the management comply with the with the management system system for the fishery management system under assessment, including, under assessment, under assessment, providing information of including, when including, when importance to the effective required, providing required, providing management of the fishery. information of information of importance to the importance to the effective management effective management
Guidepost of the fishery. of the fishery.
Met? Yes Yes No
The EU inspection report concludes that there is a good level of compliance across the Northern Irish Pelagic fleet (Daly & Skrey 2013). Northern Irish enforcement officials (DARD pers comms) conclude that the level of compliance is good and officials from the Isle of Man Directorate of Fisheries are also satisfied that vessels are not infringing on closed areas within the Isle of Man jurisdiction and that vessels
Justification leaving IoM waters are not subsequently under-reporting catches (pers. comms).
d There is no evidence of systematic non- compliance.
Guidepost
Met? Yes
Neither the EU inspection report (Daly & Skrey 2013), nor the Northern Irish enforcement officials (DARD pers comms), nor the enforcement officials from the Isle of man Directorate of Fisheries (pers. comms) have provided any evidence of systematic non-compliance. Furthermore, the HAWG stock assessment report does not provide any indication of unaccounted mortality – which would be indicative of
Justification under-reporting.
» Daly. J. & Skrey. H. (2013). Mission Report; Special rules for the weighing of certain pelagic species. Exchange of control documents with another member state. UK-C2-2013-01-A. Unpublished.
References » Council Regulation (EC) No 1224/2009 establishing a Community control system for ensuring compliance with the rules of the common fisheries policy. » Isle of Man Directorate of Fisheries (pers. comms.) » DARD pers comms
OVERALL PERFORMANCE INDICATOR SCORE: 80
CONDITION NUMBER (if relevant): n/a
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Evaluation Table for PI 3.2.4
The fishery has a research plan that addresses the information needs of PI 3.2.4 management
Scoring Issue SG 60 SG 80 SG 100
a Research is A research plan A comprehensive research plan undertaken, as provides the provides the management required, to achieve management system system with a coherent and the objectives with a strategic strategic approach to research consistent with MSC’s approach to research across P1, P2 and P3, and Principles 1 and 2. and reliable and timely reliable and timely information information sufficient to sufficient to achieve the achieve the objectives objectives consistent with consistent with MSC’s MSC’s Principles 1 and 2.
Guidepost Principles 1 and 2.
Met? Yes Yes No
In common with most European pressure stocks, managed by an EU quota, most research is coordinated via ICES. ICES strategically establishes study groups based on information requirements identified by national delegates, including through industrial representations. Members of various ICES Working Groups focused on such elements as climate change, plankton, multi-species fisheries (ecosystem), etc. All review research, identify research requirements and undertake appropriate work. There is good communication between Working Groups (via ACOM), and between researchers through their specialist interests. Research / investigation is undertaken in relation to specific requirements, which generally come from the recommendations of the Stock Assessment Working Group. Members of the ICES community keep abreast of developments within the scientific community of relevance to the fishery under consideration. This ICES community is wider than Europe and includes relevant research elsewhere. Research contracts are left to other organisations, including Universities, (e.g. through the EC) to supplement scientific understanding relevant to the fishery and related ecosystem. The assessment team have been provided with the AFBI fisheries research work programme (AFBI DARD funded work programme -fisheries consolidated Ver 1). This highlights how the Irish Sea herring survey is included in the work plan for AFBI and is agreed annually with DARD. Research recommendations have come of the ICES WESTHER and SGHERWAY projects and these have resulted in follow on work, including the 2012 benchmark
Justification assessment. In particular this research activity has considered stock definition.
b Research results are Research results are Research plan and results are available to interested disseminated to all disseminated to all interested parties. interested parties in a parties in a timely fashion and timely fashion. are widely and publicly available.
Guidepost
Met? Yes Yes No
All recommendations from the ICES working group have been uploaded onto the ICES recommendations database, however this database is not publically available. All ICES research outputs are available on-line, and these are made available in a timely fashion.
Justification
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The fishery has a research plan that addresses the information needs of PI 3.2.4 management
» ICES research publications: References http://www.ices.dk/publications/Pages/default.aspx……
OVERALL PERFORMANCE INDICATOR SCORE: 80
CONDITION NUMBER (if relevant): n/a
Evaluation Table for PI 3.2.5
There is a system of monitoring and evaluating the performance of the fishery-specific management system against its objectives PI 3.2.5 There is effective and timely review of the fishery-specific management system
Scoring Issue SG 60 SG 80 SG 100
a The fishery has in The fishery has in The fishery has in place place mechanisms to place mechanisms to mechanisms to evaluate all evaluate some parts of evaluate key parts of parts of the management the management the management system.
Guidepost system. system
Met? Yes Yes No
The overall management system (the common fisheries policy) is subject of periodic performance evaluation and review in the form of a root and branch reform. These occur roughly every 10 years. ICES annual advice in effect provides an annual review of the performance of the management system against the stock status and fishing mortality routine review of performance of management. Vigo EU CFCA (name changed to EFCA in 2012) – Joint Deployment Plans – these very much act as a monitoring and evaluation tool, albeit the focus is on sharing best practice and capacity building for enforcement among member states. As noted above in 3.2.3 the assessors have been provided with a copy of the latest inspection report from an EFCA mission (Daly & Skrey 2013). The EFCA themselves undergo independent external evaluation. There has been an evaluation of herring closed areas by STECF (SEC 2007). The STECF also undertakes evaluation of other key parts of the management system – for example the implementation by member states of the data collection framework. There is no fishery specific evaluation of the management system – this short coming nd Justification is addressed in the 2 scoring issue of this performance indicator (below).
b The fishery-specific The fishery-specific The fishery-specific management system management system is management system is subject is subject to subject to regular to regular internal and external occasional internal internal and occasional review.
Guidepost review. external review.
Met? Yes No No
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There is a system of monitoring and evaluating the performance of the fishery-specific management system against its objectives PI 3.2.5 There is effective and timely review of the fishery-specific management system
A review of Irish Sea herring fisheries was conducted by MAFF Lowestoft in 1977 (Brander 77). The assessors are not aware of a more up to date fishery specific evaluation / review of Irish Sea Fisheries. It would be expected that the management plan resulting from the GAP 2 funded
project, coordinated by the pelagic RAC would be reviewed by ICES prior to adoption by the EU. Once formally adopted it would also be expected that this would stipulate the timing for a management evaluation to be carried out to review the overall performance of the fishery specific management plan, including the performance of the harvest control rules and other fisheries specific management measures such as
Justification closed areas.
» EU CFP reform portal: http://ec.europa.eu/fisheries/reform/background/index_en.htm
» Brander. K. M (1977). The Management of Irish Sea Fisheries – a review. Ministry of Agriculture, Fisheries & Food. Directorate of fisheries Research. Laboratory Leaflet no.36. ISSN 0072-6699. » Daly. J. & Skrey. H. (2013). Mission Report; Special rules for the weighing of certain pelagic species. Exchange of control documents with another References member state. UK-C2-2013-01-A. Unpublished. » SEC (2007). Evaluation of Closed Area Schemes. SUBGROUP ON MANAGEMENT OF STOCKS (SGMOS), OF THE SCIENTIFIC,TECHNICAL AND ECONOMIC COMMITTEE FOR FISHERIES (STECF). 5 -9 NOVEMBER 2007 IN ISPRA. » Scientific, Technical and Economic Committee for Fisheries (STECF) – Evaluation of 2012 MS Technical Reports under DCF (1) (STECF-13-07). 2013. Publications Office of the European Union, Luxembourg, EUR 26090 EN, JRC 83658, 183 p.
OVERALL PERFORMANCE INDICATOR SCORE: 70
CONDITION NUMBER (if relevant): 4
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Appendix 1.3 Conditions
Condition 1
Performance PI 1.1.2 Limit and target reference points are appropriate for the stock Indicator Score 75
The limit reference point for biomass has been set to the lowest observed SSB for the previous ICA assessment. This is a standard Bloss approach for ICES where there is no clear stock recruitment relationship, and no evidence that recruitment has been impaired. It should be noted that for the new stock assessment, some SSB values are estimated now to be below this point. While Bloss is reasonable practice if no recruitment impairment has been observed, it is not particularly precautionary because it depends upon the lowest number of observations in the time series (usually a single point). Therefore this does not meet SG100b. Rationale In this case, however, the assessment shows a decrease in recruitment in those periods where the SSB was low. This did not prevent recovery, and could also indicate a change in variance. The recent benchmark assessment (ICES 2012) indicated that a stock recruitment relationship could be fitted to the available data and analytical estimates of reference points obtained. These results indicate that default reference points applying the level of precaution that MSC requires might be higher than the limit reference point currently being used. Because the current limit reference point is not justified and has not been demonstrated to apply the level of precaution consistent with the MSC standard, SG80b has not been met. Condition A limit reference point must be adopted by management that is set above the level at which there is an appreciable risk of impairing reproductive capacity based on the available evidence. Year 1: Evidence of progress in defining appropriate candidate limit reference points as part of the Milestones development of the harvest control rule (see Condition 2). Score 75. Year 3: ICES report on evaluation of the limit reference point. Score 75. Year 4: Limit reference point adopted and incorporated into management advice. The development of the LRP should take place as part of the development of the HCR (Condition 2). The client needs to show that any adopted LRP is sufficiently precautionary that based on the current stock assessment, it cannot be linked to any decrease in recruitment and that this conclusion has the support of ICES. Score 80. Client action plan Client accepts this condition and undertakes to work with relevant stakeholders through the NPWG (northern Pelagic Working Group) and PRAC (pelagic Regional Advisory Council)
forums to support the definition of precautionary reference points in regard to the ecological role of the Irish Sea herring stock. In addition the NIPSG will attend any future scientific benchmarking exercise on Irish Sea herring and undertake to support ICES in their work on defining appropriate precautionary reference points.
Consultation on Pelagic RAC, DARD, EU Commission condition
Condition 2
Performance PI 1.2.2 There are well defined and effective harvest control rules in place Indicator Score 75
There is historical evidence that fishery has acted to reduce exploitation rate when the stock was designated as overfished. This has led to the stock rebuilding since 2006. However, management intervention was not timely. Therefore, a generally understood harvest control rule exists to limit harvest and reduce the harvest rate should the stock recruitment be put at risk, meeting SG60a. However, the reduction in the exploitation rate when SSB < B is only generally understood, not Rationale trigger well-defined, so SG80a is not met.
A long term management plan is being developed, but has not yet been implemented. On 21 May 2013 the Pelagic RAC, WWF UK and Agri-Food and Biosciences Institute organized a workshop aimed at developing a long-term management plan for Irish Sea herring under the auspices of the GAP 2 research project. This development is on-going, but will hopefully yield a HCR which conforms to MSC certification requirements. A well-defined harvest control (management plan) needs to be in place. There should be evidence Condition that the harvest control rule will result in the fishery meeting its long-term objectives (as defined in the reference points), and the HCR should reduce exploitation as the limit reference point is approached (see also Condition 1).
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Performance PI 1.2.2 There are well defined and effective harvest control rules in place Indicator Year 1: Evidence of progress in defining appropriate candidate harvest control rules. Score 75. Year 3: ICES report on evaluation of the harvest control rule to test whether it is precautionary or not. Milestones Score 75.
Year 4: Harvest control rule is in place and is used to set the exploitation rate. Score 80.
Client accepts this condition and undertakes to provide the Certification Body with evidence that it has promoted to UK Fisheries Administrations and the Pelagic RAC the setting of an Client action plan annual TAC for Irish Sea herring which does not override any Long Term Management Plan being developed. The management plan will require the TAC to be set in accordance with a precautionary fishing mortality, which will also comply with the Fmsy framework. The NIPSG undertake to promote the exploitation of the stock at Fmsy to other stakeholders involved in this fishery through dialogue at the NPWG and the Pelagic RAC Consultation on Pelagic RAC, DARD, EU Commission condition
Condition 3
3.2.1 Short and long term objectives which are consistent with outcomes Performance expressed by MSC Principles 1 & 2 are explicit within the fishery’s Indicator management system. Score 60
It cannot currently be concluded that there are fishery specific objectives explicit with the management Rationale system (in order to meet SG80). In order to find the objectives which guide decision making it is necessary to refer to higher level policy documents, which are not fishery specific and are therefore concluded to be ‘implicit’ (SG60). The work underway to develop a Harvest Control Rule (via the Gap II project) is an important step Condition toward implementing fishery specific objectives. Once evaluated as precautionary this would be expected to be implemented via a binding EU legislative instrument (such as an EC regulation on a Long Term Management Plan). In doing so, it should be explicitly stated what are the wider fishery specific objectives, such as in relation to ecosystem impacts. Year 1: A plan or proposal should be drawn up outlining how fishery specific objectives will be developed and incorporated into a binding management system. Resulting score: 60 Year 2: Work to develop fishery specific objectives (both short and long term and for P1 & P2) should begin. Resulting score: 60 Year 3: Consultation on and (where necessary) refinement of objectives should be completed by the Milestones end of year 3. Additionally a definite plan and timeline should be available of how such objectives will be incorporated into binding management. Resulting score: 60 Year 4: The process of incorporating fishery specific objectives into binding management documentation should be underway. Resulting score: 60 Year 5 (by recertification): Legally binding fishery specific short and long term objectives, consistent with achieving the outcomes of MSC principles 1 & 2 should be implemented. Resulting score: 80 Client accepts this condition and undertakes to address the matter via the Long Term Management Plan (LTMP) for the stock. Together with AFBI, the NIPSG has committed to Client action plan having a LTMP in place by autumn 2014, in advance of the Irish Sea herring fishery commencing. The NIPSG further commit to facilitating and organising an annual LTMP review meeting in advance of the start of each herring season, which will be designed to review the LTMP, identify and apply any amendments needed that ensure that all MSC principles are adhered to. Consultation on None condition
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Condition 4
Performance 3.2.5 The fishery specific management system is subject to regular Indicator internal and occasional external review. Score 70
Rationale It cannot currently be concluded that the fishery specific management system is subject to regular internal or occasional external review (SG80). As indicated in previous conditions, there is currently no harvest control rules or explicit fishery specific objectives legally enshrined within the management system. Once agreed and implemented these 2 Condition key parts of the fishery specific management system should be subject to regular internal and occasional external review. The legally binding form in which the harvest control rule and fishery specific objectives are enshrined in legislation (such as an EC regulation on a Long Term Management Plan) should stipulate the frequency of such reviews. Year 1: No action required – it is expected that the aims of this condition will only be fulfilled once steps in relation to the development of harvest control rules and fishery specific objectives have been progressed to a draft legislative stage which is not reasonably expected in years 1-3. Resulting score: 70 Year 2: On-going work in relation to the harvest control rule and fishery specific objectives should include consideration of the frequency and system of internal and external review. Resulting score: 70 Year 3: Consultation on the proposed fishery specific management measures (in relation to HCR and Milestones fishery specific objectives) should include a recommendation for the process of internal and external review Resulting score: 70 Year 4: The process of incorporating fishery specific review processes into binding management documentation should be underway. Resulting score: 70 Year 5 (by recertification): Binding commitments for the fishery should be in place which detail the frequency of internal and external review. Resulting score: 80 Client accepts this condition and undertakes to continue to work with all Fisheries Administrations and stakeholders with an interest in the fishery, as well as the Pelagic RAC, to develop management rules for the fishery. The NIPSG commits to annual meetings with Client action plan fisheries administrations in the UK, Isle of Man and Ireland, as well as the NSPWG and Pelagic RAC to ensure coherent management of the fishery is maintained and developed. Particular emphasis will be given to the Harvest Control Rules (HCR) applicable to the fishery and designing a management system whereby all parties involved in the fishery agree and conform with the HCR. Consultation on None condition
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Appendix 2. Peer Review Reports
Peer Reviewer 1
Overall Opinion Has the assessment team arrived at an No Certification Body Response appropriate conclusion based on the evidence presented in the assessment report? Justification: General Comments on the Assessment FCI Response: This assessment has not Report used the FAM, which has been superseded for in excess of 2 years by The assessment is generally inclusive, satisfactorily the Certification Requirements. This structured and applies the MSC FAM somewhat strictly. assessment has been carried out However, the application of the scoring guidelines and according to the CR v1.3 and the report justification is not fully comprehensive and I have several makes it clear at several stages that it is queries on the scoring. Especially, it looks like the the CRv1.3 that is the relevant standard. assessors make all efforts to score SG 80 in PI 2 for Reviewing this report in the context of an reasons which are not clear from the text, and most earlier version of the standard will importantly, they did not fully take into account available inevitably give rise to confusion and information. Moreover, and most notably, the lack of a MP review commentary that maybe the result with HCR should have made the fisheries FAIL in P1, while of this misunderstanding. This is the assessors have chosen to put several conditions apparently the case. The CR is a instead. I do not necessarily disagree with this approach standard – either the fishery meets with it but I consider that SG 60 should be conditional to the or it does not. Regarding strict application availability of a draft of the MP and the HCR and it should of the FAM - there is no scope for varying be added to the assessment and summarized under 1.2.2. the degree to which the standard is With regard to the preface to the assessment and applied, a fishery either meets with it or it information provided, the description of the fishery related does not. to each MSC Principle is very informative and adequate for Scores in P2 PI’s were decided after an the purposes of this review. Throughout, I have identified appropriate level of review of information the section(s) of the report at which my comments are available to the team. It is not necessary aimed, and have not commented where I am content with to review every single publication or the information provided or the conclusions reached. report in relation to a fishery, as long as sufficient information is accessed in order to allow the team to arrive at an informed decision. In this case, the team have accessed a very broad range of information and listened to and considered all stakeholder input and commentary received during the assessment. A decision with respect to which scoring guides are achieved and at what level (<6060/80/100) for each scoring issue is then taken and after review and analysis of information received and discussion amongst the team. The scoring justifications will be reviewed in the context of the comment reference P2. However, it is difficult to respond more specifically at this stage as the peer review has been carried out on the basis of an outdated version of the standard and the commentary at this stage is general in nature to P2 Pi’s. Where PI specific commentary is provided later, a further appropriate response will be made. With respect to a
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HCR, the CR does not have a requirement that if there is no MP or formal HCR that a fishery must fail. It is clear that this comment is made with a limited understanding of the current standard and the supporting Guidance document. Conditions have been set where these are appropriate i.e. where the fishery has failed to achieve the minimum unconditional pass mark of 80 for any PI. The PR is referred to the CR and the Guidance to the CR for clarification on what the requirements are in order to score at SG60 for HCR. It is not for the team to decide “that SG 60 should be conditional to the availability of a draft of the MP and the HCR”. The team have followed the CR.
Do you think the condition(s) raised are Yes Certification Body Response appropriately written to achieve the SG80 outcome within the specified timeframe? Justification: FCI Response: no further response required.
If included: Do you think the client action plan is sufficient Yes Certification Body Response to close the conditions raised? Justification: FCI Response: no further response required.
150 version 2.0 (01/06/13) Food Certification International Final Report Northern Ireland Pelagic Sustainability Group (NIPSG) Irish Sea Herring Fishery Performance Indicator Review Please complete the table below for each Performance Indicator which are listed in the Certification Body’s Public Certification Draft Report.
Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
1.1.1 Yes Yes NA FCI Response: no further response required.
1.1.2 Yes Yes NA FCI Response: no further response required.
1.1.3 Yes Yes NA FCI Response: no further response required.
1.2.1 No No NA PI 1.2.1a: I disagree with the scoring FCI Response: We disagree, overcapacity is an here. Overcapacity is not an issue issue for the harvest strategy and is evidence for as long as the TAC is set according a lack of design. The TAC setting is covered to scientific advice and fully under other aspects of the strategy (PI 1.2.2 – enforced, and discards are 1.2.4). “Design” would imply setting the capacity considered to be negligible, which commensurate with the expected productivity of seems to be the case here. Climate the resource. The fishery still meets the SG80. change will affect the stock The score has been arrived at through productivity and generally consideration of all key information and after a recruitment and fish growth. As reasonable degree of discussion amongst the short term forecasts are based on assessment team members. The issue is average recruitment and average whether or not the justification provided supports fish weight of the last 3 years, they the score awarded by the team. The PR
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
do take into account possible short commentary mainly provides justification for term changes in stock productivity. arriving at a different conclusion to that which the Therefore, I think that SG 100 is met team arrived at and which the team did not here and the scoring should be consider the fishery achieved. It is noted that it is changed. not the function of the PR process to recommend or argue for different scores. Scoring can only be carried out by the team who have access to relevant information and all stakeholder input which they can then review in the context of a detailed understanding of the current version of the CR.
1.2.2 No No NA PI 1.2.2: I disagree with the scoring FCI Response: The correct definition of a HCR here, there are no HCR in place for suggests that a generally understood HCR has this fishery, thus SG60 is not meet been in place. It needs to have been to effect and the fisheries should FAIL. recovery of the stock. It is not clear what the However, if a draft of the MP with the reviewer thinks would be the difference between HCR is available, this should be a SG60 and SG80 in this context. added to the assessment and summarized under 1.2.2. Without According to ICES (2013b) the TAC has been having at least an idea of the above ICES advice 3 times, but the catch possible characterization of the MP achieved less than the TAC 6 times. These are and HCR, I think that the fishery small departures, but illustrate why a well-defined does not pass the SG 60 score here. HCR is necessary. Also, it is important to notice that the
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
TAC has been set higher than the advice 4 times between 2007 and
2013, which denotes a scarce compliance of the fisheries with the ICES advice.
1.2.3 Yes Yes NA FCI Response: no further response required.
1.2.4 No No NA PI 1.2.4a: I disagree with the scoring FCI Response: We accept the general point here here. The stock assessment that we are perhaps being harsh with the scoring. contains all elements necessary to Can we reasonably ask the fishery to do more to provide a robust estimate of the reach the SG100? Even if theoretically this is stock status. Spatial stock structure possible, is it practically possible or advisable? of the stock is rather irrelevant as We believe that there is scope for a more long as the catches are attributed to accurate structural model, so 1.2.4a SG100 is not the Irish herring stock in a met. We accept that the assessment model has satisfactory manner (which seems been improved through rigorous testing of current to be the case according to the ICES alternatives, so 1.2.4d SG100 is met. report). If not, then the stock The stock assessment is a standard one and is assessment is invalid and therefore the same that is used for a wide number of the fishery would fail to reach SG 60 species such as cod, which is not pelagic. We do in most of the PI 1. Thus, it is either not agree that that differences among stock SG 100 or FAIL here. The real issue assessments are so qualitative. There is always
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
is the splitting of the catches more accuracy that can be achieved if the model between the two stocks, which can structure more closely resembles the real be done with existing technique as processes. We accept the current approach is for example otolith microstructure or sufficient, but do not accept that more couldn’t be others but it is currently not achieved. Assessments on other species performed. However, this has address more issues, such as predation explicit already taken into account in PI spatial distribution, and these assessments 1.2.3, and according to ICES it does should be more accurate and therefore score not affect the general outcome of more highly. the assessment and its capacity to The result cannot be “SG100 or fail”, because the provide a management advice. SG80 defines the MSC standard.
PI 1.2.4d: I disagree with the FCI Response: See above for the general scoring here. The latest benchmark comment. has rigorously evaluated alternative We accept that, particularly with the recent hypotheses and assessment improvement in stock assessment method, The approaches, and thus PI 1.2.4d text has been added and score increased, so the should have scored 100. Also, a SG100 is met. paper is available (Nielsen and Berg 2014, A scientific publication has just become available doi.org/10.1016/j.fishres.2014.01.0 in February 2014, well after when scoring was 14) where the SAM model is completed. However, the lack of a publication did described in details. Finally, the not affect the scoring, but was noted. We agree
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
software is fully documented as the that a lot of information was available, albeit in a code is available in FLR (FLR difficult form for an MSC assessment. SAM). Therefore, I think that SG
100 is met here and the scoring should be changed to SG 100.
2.1.1 Yes Yes NA FCI Response: no further response required.
2.1.2 Yes Yes NA FCI Response: no further response required.
2.1.3 No No NA PI 2.1.3: I disagree with the scoring FCI Response: the word “cannot’ had been here. The text in the justification is omitted and has now been inserted into the inconsistent with the scoring. The sentence. Scoring issues a and b are met with at text says: “Therefore the on-going SG100. Scoring issues c and d are met with at level of mortality of mackerel or SG80. According to CR27.10. the appropriate horse mackerel retained is score is 90, not 100. The score has not been considered to be monitored in changed. absolute detail” but then the scoring is 80. Also, monitoring and information available are adequate and detailed to assess that the mortality imposed on retained species is basically null. Therefore, I think that SG 100 is met here and
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
the scoring should be changed.
2.2.1 Yes Yes NA FCI Response: no further response required.
2.2.2 No No NA PI 2.2.2: I disagree with the scoring FCI Response: the CR requires that a strategy here. You don’t need to test a has specifically been tested in order to score strategy when you know that there is SG100. No evidence of testing of the strategy no substantial by catch of anything was provided to the team. SG 100 not awarded. in the fishery and actually by catch SG100 is not scored as the team evaluated that is close to null. The lack of by catch, scoring issues b and c only achieved SG80 as as verified by the observers, is per justifications provided and following the CR already the most robust test you can and relevant sections of the guidance document achieve. If slippage is not recorded or is a very rare event as stated in the introductory part of PI 2, then
how the fishery does not achieve SG 100 based on slippery? This is largely Inconsistent.
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
2.2.3 No No NA PI 2.2.3: I am confused here and the FCI Response: Confusion is likely to arise as a logic for scoring is flawed. First you consequence of reviewing this report in the say there is an on board observer context of a version of the standard that has not program which cover 5% of the been used in this assessment and which has effort (which I assume it is been superseded for over two years. Again the considered representative of the PR comments do not appear to consider the text fleet catches since it is not stated at SG100, which requires that “Accurate and otherwise), then you say at the end verifiable information is available on the catch of of the justification that “…there is no all bycatch species and the consequences for the independent verification of bycatch status of affected populations”. It is not just main or slippage in the NIPSG fleet bycatch species. The fishery does not record ALL fishery for Irish Sea herring..” and bycatch, even with 5% observer coverage it is not more in the Introduction (page 32) it possible to accurately verify ALL bycatch for all is stated: “…There is sufficient on- vessels for ALL hauls on ALL trips. So SG100 going data collection to identify cannot be met for SIa. The lack of a log onboard increased risks of bycatch in the for reporting rare slippage events means that SIb fishery…” Now, the question is, cannot be met at SG100. The justification is clear there is or there is no a on board in the context of the issues that are being scored observer program for an in the PI’s (CR). There is sufficient ongoing independent verification of bycatch? collection of information to show increased risks If there is and no by catch and through such data sets as VMS and landings slippage is reported, then SG 100 records – risk to bycatch species can be should be awarded or you should monitored to a degree using other indicators. The explain why the on board observer report does not say that there is no slippage – it programme is not representative of mentions it is a rare event. The assessment team the fisheries activity and catches. found that bycatch management amounted to a
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
Again, the rationale for scoring SG partial strategy only on account of incomplete 80 is very confused and inconsistent knowledge in relation to slippage (meaning that with the information reported here SIc can only achieve SG80). It is possible to have and available in the literature. % coverage by observers but still not have independent verification of slippage. Scoring for SId reflects the requirement that “Monitoring of bycatch data is conducted in sufficient detail to assess ongoing mortalities to all bycatch species”. This is not met with for reasons stated in the AT.
2.3.1 No No NA PI 2.3.1: Again here I am puzzled. It FCI Response: It is difficult to address comments looks like the assessors make all confusion when it appears that confusion arises efforts to score SG 80 here and did from unfamiliarity with the CR, what version of the not take into account available standard is used and how scores are arrived at, information. If the observer rather than from the report itself The scoring programme is considered justification is very clearly set out and application representative of the fleet catches of scoring rules (CR 27.10) results in a score of as I would assume since it is not 80. No indication of what information the PR is stated otherwise, the PI 2.3.1 should referring to and which it is claimed the team did have scored 100. Populations of not take into account is made (eg references). It seals are increasing in the area so is not appropriate that assessment teams should they cannot be threatened by the have to address PR comments that are theoretical possibility that single significantly related to unfamiliarity with the individuals might be caught. The
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
same applies to shad, cetaceans standard. and sharks, there is no information available that might even make someone suspecting that pelagic fisheries for herring in Irish sea is threatening shad and basking sharks. Once you are in the sea fishing, there is always the chance that you can catch anything which lives there, theoretically even a blue whale, but from there to affirm that this might constitute a issue for the populations of shad, cetaceans and sharks there is huge step to be made. Again, the rationale for scoring SG 80 is very confused and inconsistent with the information reported here and available in the literature.
2.3.2 No No NA PI 2.3.2: If 0 is reported as by-catch, FCI response: if 0 is reproted as a bycatch, that then a quantitative analysis is means that nothing is reported, it does not mean available. If you mean that they that there is no bycatch. “To score SG 80, the key
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
should report the confidence of issue is to have these estimates and show that intervals of the estimates, this is the upper level of the estimated by catch poses a another matter but it can be easily risk of serious harm to ETP species and does not estimated and it should be stated. ensure that the fishery does not hinder the To score SG 80, the key issue is to recovery of ETP species.”. This is incorrect. To have these estimates and show that score 80, evidence needs to show that the fishery the upper level of the estimated by meets with the PISG for each scoring issue at catch poses a risk of serious harm SG80. to ETP species and does not ensure “Again, the rationale for scoring SG 80 is very that the fishery does not hinder the confused and inconsistent with the information recovery of ETP species. I have a lot reported here and available in the literature.” The of doubts that this is the case, even justificaiton supports fully the score awared at if the coverage is small, being the each scoring issue. It is explicit and direct in its reported by catch 0, the likely upper consideration of the PISG text. There is no estimated level of by catch is too low confusion if the PISG texts are referred to when to have any sort of consequences reading the justification text provided. . It is not for the status of ETP species being appropriate that assessment teams should have the populations of seals and marine to address PR comments that are significantly mammals large. Again, the rationale related to unfamiliarity with the standard. for scoring SG 80 is very confused and inconsistent with the information reported here and available in the literature.
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
2.3.3 No No NA PI 2.3.3: The text states “All FCI Response: Each scoring issue should be observer programmes operated to considered on its own merit and the text suporting date under 812/2004 reveal little or the score reviewed in order to see that it supoorts no bycatch of protected species in the PISG awarded. In doing this it is essential that the herring fisheries of the Celtic reviewers consult the latest version of the Sea, North Sea and Irish Sea, as standard and the supporitng guidance document. well as western waters”. Then the To score SG100 all SI’s need to be met at scoring is incorrect. Again, the SG100. The PR argues for a change of score to rational for not scoring SG 100 100 on the basis of an argument that applies to should be derived from the upper one scoring issue only (a). However there are level of the estimate of by catch, three socring issues and no evaluaiton is made which is not what reported in the by the PR of where the fishery might be in relation justification text. Anyhow, I have a to SI’s b and c. It is not appropriate to change any lot of doubts that this is the case, scoring on account of the points raised. even if the coverage is small, being the reported by catch 0, the likely upper estimated level of by catch is too low to have any sort of consequences for the status of ETP species. Again, the rationale for scoring SG 80 is very confused and inconsistent with the information reported here and available in the literature.
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
2.4.1 Yes Yes NA FCI Response: no further response required.
2.4.2 No No NA PI 2.4.2: Again, the rationale for FCI Response: the PR comment is insufficient scoring SG 80 is very confused and justification to award a score of SG100. Two inconsistent with the information scoring issues have not achieved SG100, while reported. The pelagic trawls do not two have achieved SG100. Therefore a score of touch the seabed or if it does, it is 90 is appropriate according to CR27.10. Just really a rare event, which I am not because pelagic trawls only touch the seabed on aware of. SG 100 should be very rare occasions does not mean that awarded. management of potential impacts on the seabed related to trawling is well developed and meets with SG100. Clear explanation is provided as to why two SI’s are not awarded SG100.
2.4.3 Yes Yes NA FCI Response: no further response required.
2.5.1 No No NA PI 2.5.1: It was not possible to fully FCI Response: the last part of the extensive review this PI as the text is justification cannot be seen due to a problem with incomplete in its last part. But if the MSC template and which the team have no herring is not a key low trophic level control over, although this problem has been species as stated in PI 1 and the brought to the attention of the CAB. stock is maintained over the SG100 PISG states ”there is evidence that the reference points, I cannot see how fishery is highly unlikely to disrupt the key the fishery can cause serious or
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
irreversible harm to the key elements underlying ecosystem structure and elements of ecosystem structure function to a point where there would be a serious and function. Thus, SG 100 should or irreversible harm”. be awarded. The justification provided notes that “In the context of the relatively major ups and downs that the Irish Sea herring stock has exhibited over the past 30- 40 years, it appears unlikely that fishery related removals have a dominant effect on the underlying ecosystem”. This falls some way short of “highly unlikely”, and partial scoring of the single scoring issue at SG100 is appropriate under the CR.
2.5.2 No No NA PI 2.5.2: Being a fishery that targets FCI Response: the justificaiton acknowledges a low trophic species, the principal the main impact of the fishery being the removal potential impact of the fishery is of the target species which is a forage species. depletion of the herring stock itself, The HCR rationale suggested by the PR has which is an important prey species. already been considered under P1 and it is not Thus, the rationale to score SG 80 appropriate to score the same issue here once should be that HCR are not in place again. and have not been formally tested What is being scored here is the measures and with a MSE, and therefore there is strategies that are in place to manage impacts on no guarantee that they will work to the overall ecosystem, while not rescoring the keep the stock over the biomass HCR issue. Development of a LTMP is part of the
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
reference points. But the assessors strategy and is in progress, as pointed out in the did state before that they consider text. The rationale for scoring 80 is reiterated as the current “under discussion” MP follows: enough to manage the stock. Thus, SIa achieves 80 as per supporting justification. again the rationale for scoring SG80 is inconsistent with what reported Sib achieves SG80 as per supporting before and with available justification. information. Sic achieves SG80 as per supporting justification. Sid achieves SG80 as per supporting justification. As per Cr 27.10, overall score 80. All scores were arrived at after review of informaiton from diverse sources and with team discussion and in consideration of the CR.
2.5.3 No No NA PI 2.5.3: The main consequences FCI Response: the assessment team reviewed for the ecosystem as a result of the available evidence and took into consideration all fisheries are highly likely to be comments from stakeholders in completing the restricted to consequences arising scoring for this PI. No PISG were considered to from a too large removal of the have been met with at SG100. In the main this is herring stocks, but if the ICES relate to the fact that herring is likely to be a advice is followed, this risk is signifcant forage species in the Irish Sea, while it
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
basically null. There is no significant does not appear to be a key LTL species. The bycatch, retained species are well assessment team considered that no PISG were documented and there is no met with at SG100 for reasons outlined or significant habitat interaction. inferred in the justificaiton text. The team scoring Ecosystem consequences can decision was taken on this basis. therefore be expected to be low or negligible. The assessors motivated SG 80 due to slippage and lack of an ecosystem based management of Irish Sea fisheries. But slippage is estimated to be very low and not reported by observers while ecosystem based management is irrelevant here as the fisheries is only having an impact on herring, herring is not a key low trophic level species in the Irish Sea and current ICES HCR will maintain the stock over the reference points. Then, again the rationale for scoring SG80 is inconsistent with what reported before and with available information.
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
3.1.1 Yes Yes NA FCI Response: no further response required.
3.1.2 Yes Yes NA FCI Response: no further response required.
3.1.3 Yes Yes NA FCI Response: no further response required.
3.1.4 No No NA PI 3.1.4: The text given here is not FCI Response: The key difference between the explaining why SG 100 is not SG80 and the SG100 is that the higher score awarded or why SG 80 is awarded. requires explicit and regular consideration of incentives in reviews. The scoring commentary provided states that “However, overall, within the context of the EU CFP it is concluded that explicit consideration of incentives is not yet included in regular review”. This is the reason why SG100 was not met.
3.2.1 Yes Yes NA FCI Response: no further response required.
3.2.2 No No NA PI 3.2.2: The following sentence is FCI Response: Noted. This is rephrased to: “In not supported by fact: “Generally the the 1990s there was a poor record of setting
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
TAC has been set at the level of the fishing opportunities in line with scientific advice. scientific advice since 2002 (with the Since 2002, there has been much improved exception of 2011 when the TAC setting of fishing opportunities in line with was set above the level of the advice scientific advice, although opportunities were set in 2011)” see Table 5.4.14.1. slightly above advice in 4 years from 2008 to Herring in Division VIIa North of 52º 2012”. 30’N (Irish Sea). ICES advice, At the time of assessment, TAC was set as per management, and catch) in the advice, so we conclude that the scoring remains ICES summary sheet for this stock. appropriate. The table shows as the TAC has been set higher than the advice 4 times between 2007 and 2013, which denotes a scarce compliance of the fisheries with the ICES advice.
3.2.3 No No NA PI 3.2.3: The scoring is partially FCI Response: This decision was taken after long inconsistent with the text (or vice discussion among the assessment team, all of versa), the text justification states: whom have considerable experience in MSC “The assessors have not scored the assessments of Northern European pelagic system as comprehensive as the fisheries. The score reflected the fact that level of inspection of landings was although all minimum requirements were met, it lower than in comparable fisheries, did seem that the systems in other Northern although DARD highlight that this is European fisheries were more comprehensive based on an appropriate analysis of and therefore warranted a higher score. A score
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
risk and that the level of inspection of 80 does not reflect badly on a fishery – it is the also meets the EU requirement”. An good practice benchmark for a sustainable analysis of risk is made to avoid fishery. disproportionate costs of inspecting the entire fleet, which is not in the spirit of MSC. If the level of inspections does not report any particular issue, then SG 100 should be awarded.
3.2.4 No No NA PI 3.2.4: The scoring is partially FCI Response: This scoring is consistent with inconsistent with the text (or vice MSC scores on many other well-researched versa). There are only positive ICES fisheries (not just pelagic). The assessment aspects of the fishery research plan, team has experience of asking a wide range of thus I do not see the rationale for member state representatives on ICES working scoring SG 80 here. Moreover, the groups about this specific performance indicator. text given here is not explaining why Although, the national / ICES research in this SG 100 is not awarded or why SG area is exemplary, the MSC methodology 80 is awarded. requires a written fishery specific research plan. The awarded score of 80 reflects that the current situation is ‘good practice’ which does not require either a condition or a recommendation. In short the system works to support management and the teams scoring seems to be a reasonable compromise between the constraints of the
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available been rationale used the fishery’s where possible. Please attach used to score to score this performance to additional pages if necessary. this Indicator? Indicator the SG80 (Yes/No) support the level? given score? (Yes/No/NA) (Yes/No)
methodology and the practicalities of the real world
3.2.5 Yes Yes NA FCI Response: no further response required.
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Peer Reviewer 2 Overall Opinion
Has the assessment team arrived at an Yes Certification Body Response appropriate conclusion based on the evidence presented in the assessment report?
Justification: The conclusion of this assessment, that the NIPSG FCI Response: no response required. Irish Sea herring mid-water trawl fishery be certified, is sound, though there are a number of PIs where the scoring and supporting comments should be reviewed, particularly where there appears to be a “default” 80 score in P2 and P3 that is not explicitly justified by the evidence presented. This is unlikely to reduce the overall scores.
Do you think the condition(s) raised are Yes Certification Body Response appropriately written to achieve the SG80 outcome within the specified timeframe?
Justification: The assessment team have identified the main FCI Response: no response required. weaknesses of this fishery, which center around reference points, fishery-specific objectives, harvest control rule and management plan, but which should be easily overcome within the 5-year certification period.
If included:
Do you think the client action plan is sufficient Yes Certification Body Response to close the conditions raised?
Justification: I say “yes” in the sense that the CAP should FCI Response: no response required. achieve all that is necessary within the remit of the client. The main responsibility falls on ICES (reference points) and the bodies tasked with developing the management plan.
General Comments on the Assessment Report (optional) You should check throughout the report that acronyms in the Glossary are used correctly, and that the whole name is only used once (otherwise why bother with a glossary?). NB ASCOBANS is in the Glossary twice. I suggest a thorough editing of this report before it goes out for public consultation FCI Response: appropriate edits have been carried out and the glossary corrected/updated.
Client strengths: From the assessment report, it does not appear that the Irish Sea herring stock is well managed with a precautionary long term management plan. The latter is still under development and needs agreement up to the European Council level (unless there has been progress since the site visit). FCI Response: Irish Sea herring stock management has been effective in recent times and the stock has rebuilt to a biomass not seen since the 1980’s. While it is the case that management could be more robust, the assessment acknowledges this and also the fact that improvements are under development on the form of a long term management plan as well as a HCR.
What is “the shoaling nature of Irish Sea ecosystem”? FCI Response: a typographical error has been corrected.
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Client weaknesses: It would be useful to briefly describe the weaknesses in P1 and P3 here. FCI Response: a description of main weaknesses has now been included in this section.
Recommendation: The assessment team made one recommendation, which should be outlined briefly here. FCI Response: recommendation has now been described here.
Fishery Ownership and Organisational structure: You state that entitlement to quota for Irish Sea herring is shared between the UK and Ireland. It would be useful here to ensure that readers understand that Northern Ireland (client’s state) is part of the UK and not the Republic of Ireland. FCI Response: amended.
History of the fishery: it would be useful to clearly indicate which of the vessels mentioned here are in the UoC (pair of UK pair trawlers fishing in the 3rd and 4th quarters; a single pelagic trawler; small local fishery on the Mourne herring grounds during the 4th quarter??). Under management history, you state that by the 1990s only the fishery on the Manx fish (meaning the herring stock when it was in IOM Waters?) remained, and only two Northern Irish vessels operated in 2002 and 2003. Today you suggest that three vessels are involved (the UoC). Make this clear early on. FCI Response: the vessels that are included in the UoC are clearly indicated and named in Table 3.2.1. It is not appropriate to repeat this information under the proposed section.
Figure 3.2.2 ICES subareas NE Atlantic is largely redundant and could usefully be replaced by a chart showing the areas in the Irish Sea discussed in this section. FCI Response: the map supports the section “Area under Evaluation” and indicates the location of ICES subarea VIIa (where this stock occurs and the fishery takes place) in the context of Area VII. It is therefore not considered redundant and to remove it would leave the accompanying text unsupported by an ICES marine areas map.
Species: you say “where prey concentrations reach very high levels, ---, herring are able to swim forwards with open mouth and expanded opercula”. Do you mean filter feeding? FCI Response: yes. Clarified.
You describe the characteristics of stock structure in East Atlantic herring, noting that different stocks tend to mix for most of the year but migrate to separate spawning areas. The extract from HAWG 2009 does not clarify this picture particularly well, and a schematic showing the migration paths of the Irish Sea stock and where it is fished by the client fishery (and other fisheries (off SW Scotland? in the Celtic Sea?) would help greatly (i.e. refer to Fig 3.3.1 or introduce it earlier). FCI Response: reference to Figure 3.3.1 has now been included in the section that presents the extract from HAWG 2009.
I fail to understand, given the description provided, why you continue to refer “interested readers” to sources that are really quite general. FCI Response: the term “interested readers” is used all of two times in the report. It is used in instances where summary information is presented and readers can seek more detailed information from sources to which the readers are directed. Some of that source material may be quite general to a person with much knowledge and expertise but is in actual fact presenting a lot more detail than is in the report. The report has not been altered on foot of the comment.
Does ACFM still exist? FCI Response: text amended.
Fishing practices: why is the trawl used by the Icelandic pelagic fleet mentioned? FCI Response: text amended.
Figure 3.2.5 summarise catches for the years 1961-2011 and Fig. 3.2.6 catches compared to TAC 1961-2006 (duplicating catch information). It would be useful to keep only fig. 3.2.5 and show the TAC in recent years in Table 3.2.2, and to update all this to 2012 at least. FCI Response: amendments made as suggested.
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Introducing the Mourne coastal drift net fishery in relation to customary fishing rights confuses the issue (with politics). This is not part of the UoC. The IOM lack of quota may be another matter. FCI Response: reference to the Mourne coastal fishery has been included to capture stakeholder input received during the assessment process. Scoring is independent of the issue but it is appropriate that all stakeholder input is included in the assessment report. Scoring has not been influenced by political circumstances.
In discussing the results of WESTHER, you note the “important conclusion was that there is very little mixing between the Celtic Sea area and the other stock areas”, and then say that ICES (2013) reported that a significant proportion of the catch in the Irish Sea (as much as 30% in some years) are likely to be juveniles originating from the Celtic Sea spawning stock. These statements are contradictory. It would be very useful for the reader if this section was abbreviated to those points that are important to the MSC assessment, whereas the detail given here and previously on stock identity only serves to confuse. FCI response: The text referred to reads “ICES (2013) reported that a significant proportion of the catch in the Irish Sea (as much as 30% in some years) are likely to be juveniles originating from the Celtic Sea spawning stock. This is based on the assumption that all herring that originate from winter spawning are from the Celtic Sea, whereas the Irish Sea is predominantly autumn spawning. There is, however, uncertainty about the migration of adults back to the Celtic Sea and the occurrence of mature fish on the spawning grounds in the Irish Sea suggest that not all fish necessary return to their natal spawning ground. If they did, the population will be genetically distinct and the opposite was found during WESTHER.” The circumstances where ICES (2013) conclude that there is significant mixing is based on the assumption detailed in the paragraph. The text as written explicitly refers to the conflicting statements but provides an explanation of why they conflict. No further response is deemed necessary therefore.
Your argument, that the effect of Irish Sea catches on the Celtic Sea stock, and other aspects, is sufficiently small that the Irish Sea stock should be the only stock addressed in Principle 1 scoring, seems reasonable, but you cannot argue that an increase in the cost of this assessment (if the Celtic Sea stock was included) also justifies this. If it has to be included, then so be it. FCI response: it is not that MSC assessments can be carried out without due consideration of cost versus benefits gleaned. The point is made that carrying out a separate P1 assessment would not add to the robustness of the assessment but would add very significantly to the cost. The point that a separate P1 assessment is not required has already been made. No changes considered necessary in response to this comment. Stock Status and Reference Points: what is “the final assessment”? Presumably that carried out in 2013 giving SSB and F estimates extending to 2012. FCI response: text amended to clarify.
You note that the benchmark in 2012 concentrated on F reference points and that, as part of the development of the management plan, we (the assessment team?) are reinvestigating the reference points (including biomass) which will happen within the next year, being an integral part of the management plan. Make it clear that there was no management plan at the time of the MSC assessment. FCI Response: text amended to provide greater clarity. Under Harvest strategy, you mention closed areas which help explain differences in selectivity between the survey and the fishery (though you note that commercial cpue is not used in the stock assessment). Only the 1996 acoustic survey has been mentioned so far. Make it clear that the ongoing acoustic survey includes trawl sampling (which seems to be the main input to the assessment). In fact, there is no explanation of either the acoustic equipment, calibrations etc nor of the survey trawl design that provides insight as to how reliable are the data collected in estimating herring abundance. FCI Response: the suggestion would amount to inclusion of excessive levels of detail. Adequate references are used and trawl sampling is indicated. This is sufficient.
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Data and Stock Assessment. Given the foregoing discussions on IS herring movement into the Celtic Sea and Div. Via, I think that you need to explain why you consider that no significant catches are taken in other fisheries (Celtic Sea, off SW Scotland, Clyde, e.g.). FCI Response: it is considered to be the case because there is no evidence that other fisheries take IS herring.
You state that the estimate of herring SSB for 2012 is 56 759 t, higher than the 2011 estimate, but a significant reduction from the 2010 estimate. In Figure 3.3.2 Herring in Division VIIa North of 52º30’N (Irish Sea) spawning stock status and fishing mortality in relation to current reference points (from ICES 2013b), however, the last three years (2010 -2012) show SSB at ~ 22kt. (confirmed with reference to ICES advice 2013). FCI Response: Information has been corrected.
How is the herring larvae survey (NINEL) used in the stock assessment? FCI Response: additional text has been included to explain in the relevant section. It is rather worrying to find that an assessment for this stock had not been accepted by the working group for more than 20 years prior to 2012. You need to make it clear that two assessments (in 2012, and 2013) have now been performed using the FLSAM model, and that their outcome was consistent. FCI Response: this has been clarified in the text.
ETP species interactions. You say that the Northern Ireland Conservation of Seals Act 1970 makes it an offence to kill or take seals at certain times of the year or by the use of certain prohibited means. When and by what means can seals be legally killed today? FCI Response: the Wildlife (Northern Ireland) Order 1985 makes provisions for the licensing to intentionally kill a range of animals, including both grey and harbor seals. Seals are listed on both schedule 5 and 6. Outside of licensing, the legislation states:
“(3) Notwithstanding anything in Article 10, an authorised person shall not be guilty of an offence by reason of the killing or injuring of a wild animal included in Schedule 5—
(a)if He shows that his action was necessary for the purpose of preventing serious damage to livestock, foodstuffs for livestock, crops, vegetables, fruit, growing timber, pasture or any other form of property or to fisheries; and
(b) He notifies the Department immediately after taking such action. “
Habitats: you state that the fishery is not considered likely to impact on any of the sites to the west of the Isle of Man and outside of Isle of Man territorial waters, since the main fishing area lies to the east of the Isle of Man. However, Figure 3.4.2 indicates the distribution Irish Sea herring fishing effort by NIPSG vessels for 2010-2012 from VMS data, which shows a considerable (in fact the majority) of positions between the IOM and NI. Do these plots show only the UoC (which is important)? FCI Response: yes, plots show only the UoC effort. Main fishing area typo (east/west) has been amended and text now clearly explains the location of the main fishing area.
Ecosystem impacts. Is it really necessary to repeat, for the second time (i.e. 3x in all) the information presented in the second paragraph here? FCI Response: repetition of text is an inevitable consequence of the layout of the reporting template. Nevertheless, the second paragraph has been removed in response to the comment.
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What is the reason for presenting Table 4.2 Scoring elements? FCI Response: the Table appeared in the section above where it was intended to be located and has been moved and renumbered 4.4.1. The Table is similar to a decision tree in that it clearly identifies the status of scoring elements, as is required where the possible use of the RBF has been announced for an assessment.
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available rationale used the fishery’s where possible. Please attach been used to to score this performance to additional pages if necessary. score this Indicator the SG80 Indicator? support the level? (Yes/No) given score? (Yes/No/NA) (Yes/No)
1.1.1 Yes Yes NA FCI Response: no further response required.
1.1.2 Yes No No PI 1.1.2a SG80 asks if reference FCI Response: Text has been added to the points can be estimated, but you scoring table to refelct the concern. provide no evidence of this here. The reference points will be addressed as part of Against 1.1.2b you note that Blim the HCR development. has been set to the lowest observed SSB for the previous ICA A widely accepted BMSY has not been defined. assessment, but then observe that We have accepted FMSY as the target and a the most recent assessment has putative BMSY trigger above Bloss. However, SSB estimates below this level. MSY is now a requirement under CFP, so it will Since Bmsy is based on Blim form part of the HCR and the condition and is (1.1.2c), there is clearly a problem already part of the proposed Management Plan. (which you recognise), although
SSB appears to be around the new estimated Bmsy (17.5kt). A score of 75 is too high. Condition 1, requiring that a limit reference point be adopted by management (set above the level at which there is an appreciable risk of impairing reproductive capacity) should also include a B target (based on MSY).
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available rationale used the fishery’s where possible. Please attach been used to to score this performance to additional pages if necessary. score this Indicator the SG80 Indicator? support the level? (Yes/No) given score? (Yes/No/NA) (Yes/No)
This should be reflected in the Client Action Plan (it is not at present).
1.1.3 NA NA NA
1.2.1 Yes Yes NA FCI Response: no further response required.
1.2.2 Yes Yes Yes FCI Response: no further response required.
1.2.3 Yes No NA You note that the population FCI Response: There is a a judgement to be structure (of herring in the Irish Sea) made in the interpretation of the guideposts as is complex, but it appears that absolute or relative requirements. We agree, it is information is sufficiently not clear that further information on the complex comprehensive to support the stock structure is required or desirable harvest strategy. Would it really be considering the cost of acquiring that information. possible to assess year-to-year Nevertheless, this adds significantly to the stock mixing (though you infer the uncertainty in managing this stock, and MSC assessment is carried out as a P&C are, to some degree, absolute. That is, mixed population fishery, comments fisheries which happen not to have these sorts of against 1.2.4 indicate that this is not uncertainties, score more highly irrespective of the case). A higher score is their management. indicated.
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available rationale used the fishery’s where possible. Please attach been used to to score this performance to additional pages if necessary. score this Indicator the SG80 Indicator? support the level? (Yes/No) given score? (Yes/No/NA) (Yes/No)
1.2.4 Yes Yes NA FCI Response: no further response required.
2.1.1 Yes Yes NA FCI Response: no further response required.
2.1.2 Yes No NA At 2.1.2a, the description of the FCI Response: management is considered to strategy for managing retained meet with a strategy and therefore includes species should deal with the UoC, elements are that are deliberately aim to i.e. how does the fishery’s operation minimise retained catch. Clarificaiton is now effect such a low catch of non-target provided in some amended text. species (as you do in 2.2.1). Is it deliberate, or co-incidental?
2.1.3 Yes No NA At 2.1.3d SG100, I suggest that FCI Response: At SG100, the PISG for Sid states monitoring of retained species is “Monitoring of retained species is conducted in conducted in sufficient detail to sufficient detail to assess ongoing mortalities to assess ongoing mortalities. Given all retained species.”. The fishery was evaluated the size of the fishery and the results in the context of this statement and it was found of observer coverage, mortality of that the fishery does not meet with the SG100 mackerel (for example) is negligible PISG as some fish (individuals of a compared to exploitation of the NE stock/species) may be captured and landed Atlantic stock. without the system fully acounting for them. SG100 is the highest possible score under MSC
and the fishery was found to fall someway short
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of best possible practice.
2.2.1 Yes No NA Against 2.2.1a you argue that there FCI Response: ithe team accept that this may be is a high degree of certainty that counterintuitive, however there are clear logial bycatch species are within reasons for the scoring decisions for each PISG biologically based limits, because at each level. For 2.2.2b, the PISG specifically there is a high degree of certainty refers to “testing” and no clear evidence was that there are no bycatch species in provided to the team that the management the fishery. However, you consider strategy has specifically been tested to the SG100 not to be met for 2.2.2.b&c degree that there is high confidence that it will and all of 2.2.3 (testing, information work. There is always the possibility of slippage and evidence), which is in pelagic fisheries and due to the “observer counterintuitive. Which is correct? effect” slippage is unlikely to be detected even when the ship submits to carrying obsevers from time to time. Also the fishery does not voluntarily keep a log of slippage events which would support an evaluaiotn of the strategies effectiveness. For 2.2.2c, this is also influenced by uncertainty over the level of slippage in the fishery. It is believed to be very ow however there are no firm data to support this and evidene has been considered to fall short of SG100 on account of uncertain level of slippage.
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available rationale used the fishery’s where possible. Please attach been used to to score this performance to additional pages if necessary. score this Indicator the SG80 Indicator? support the level? (Yes/No) given score? (Yes/No/NA) (Yes/No)
2.2.2 Yes Yes NA FCI Response: no further response required.
2.2.3 Yes Yes NA FCI Response: no further response required.
2.3.1 Yes No NA Against 2.3.1a SG100, you suggest FCI comment: SG100 for SIa is a very high score that there is not a high degree of in circumstances where there was little specific certainty that the effects of the evidence available in relation to the actual fishery are within limits of national (documentd) level of itneraction between this and international requirements for fishery and ETP species. Information/evidence protection of ETP species. should allow the team determone with a high However, nothing in the scoring degree of certainty (defined as at or above the comments points to this conclusion. 95th percentile evidence provided simply does not From the information provided, it meet with this. The function of justification text is seems that the fishery does not to support the score awarded and less so to pose a risk of serious or irreversible identify why SG100 was not achieved, although harm to ETP species and does not this is done. hinder recovery of ETP species.
2.3.2 Yes No NA It is clear that this fishery and its FCI response: the CR defines what a operation pose a minimal threat to comprehensive strategy is. A comprehensive ETP species, yet you have scored strategy is what is required to score at SG100. only 80 for all SGs. This does not The ETP management strategy in this fishery appear to be due to a lack of was not considered to mee twith the definition of
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information, and I suggest that a comprehensive and therefore coring of issues at higher score might be considered. SG80 was appropriate.
2.3.3 Yes No NA See above. FCI Response: no scoring issues at Sg100 were considered to hae been met with by the team. SIa at SG100 requires that “Information is sufficient to quantitatively estimate outcome status of ETP species with a high degree of certainty.” This was not met with on account of a shortage of evidence – the fishery could elect to mainain a voluntary log of ETP interactions oboard which might produce a greater level of evidence to support SG100, but they do not do so. There is not a high degree of certainty that informaiton is adequate to quantitatively assess the impacts of the fishery on ETP species. Sib at SG100 states “Accurate and verifiable information is available on the magnitude of all impacts, mortalities and injuries and the consequences for the status of ETP species.” There is insufficient evidecne to support
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this statement once again. SIc at SG100 states “Information is adequate to support a comprehensive strategy to manage impacts, minimize mortality and injury of ETP species, and evaluate with a high degree of certainty whether a strategy is achieving its objectives.” There is not a comprehensive strategy as per the CR.
2.4.1 Yes Yes NA It would be useful somewhere to FCI comment: the fishery operates mainly at state whether the fishery operates at night time. Text has been added to explain this. night and/or day, given the vertical movements of herring (which occur near the seabed during the day, especially at spawning time).
2.4.2 Yes Yes NA FCI Response: no further response required.
2.4.3 Yes Yes NA FCI Response: no further response required.
2.5.1 Yes No NA I cannot see where you have shown FCI Response: due to difficulty ith the MSC report that there is insufficient evidence template some text in the justification cannot be that the fishery is highly unlikely to seen. However, explanation is provided that disrupt the key elements underlying there is limited understanding of the irish sea
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available rationale used the fishery’s where possible. Please attach been used to to score this performance to additional pages if necessary. score this Indicator the SG80 Indicator? support the level? (Yes/No) given score? (Yes/No/NA) (Yes/No)
ecosystem structure and function to ecosystem and that fisheries management in the a point where there would be a Celtic seas generally has not moved signifcantly serious or irreversible harm closer to an ecosystem based approach, which (SG100). the team felt would be indicative of less risk of causing serious harm to ecosystem structure and function through cumulative fishery related impacts.
2.5.2 Yes No NA I cannot see why you consider that FCI comment: agreed, the justifications support the measures (to ensure the fishery higher scores. Scoring issue c has been raised to does not pose a risk of serious or the SG100 PISG and scoring issue d has also irreversible harm to ecosystem been raised to SG100PISG. Oerall score for this structure and function) are PI therefore meets 90. Revisions to the report considered unlikely to work (2.5.2c) have been made as appropriate. or that they are not being implemented successfully. There are no habitat impacts, very little non-target species catch and the herring stock is at its highest level since the mid-1970s.
2.5.3 Yes Yes NA FCI Response: no further response required.
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available rationale used the fishery’s where possible. Please attach been used to to score this performance to additional pages if necessary. score this Indicator the SG80 Indicator? support the level? (Yes/No) given score? (Yes/No/NA) (Yes/No)
3.1.1 Yes Yes NA FCI Response: no further response required.
3.1.2 Yes No NA I fail to see why the GAP II funded FCI Response: It is unusual that a project should project, which is involved in play such an active role in what is a key aspect of developing a management plan, the development of the fishery managament including harvest control rules for regime. SG100 requires that all areas are the Irish Sea herring fishery, carries understood. SG80 requires that key areas are such weight as to negate a 100 understood. The assessors concluded that in this score for 3.1.2a. You state under case SG80 was met. A score of 80 does not 3.2.2 that this is not a management reflect badly on a fishery – it is the good practice decision-making body, but has an benchmark for a sustainable fishery. advisory role (via the Pelagic RAC, ICES and STECF) to the European Council.
3.1.3 Yes Yes NA FCI Response: no further response required.
3.1.4 Yes Yes NA FCI Response: no further response required.
3.2.1 No No Yes If “there are clear objectives within FCI Response: Because these are implicit and the fisheries management system not fishery specific – i.e they must be infererred which aim to meet the outcomes from looking at higher level objectives. This
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available rationale used the fishery’s where possible. Please attach been used to to score this performance to additional pages if necessary. score this Indicator the SG80 Indicator? support the level? (Yes/No) given score? (Yes/No/NA) (Yes/No)
expressed by MSC principles 1 & 2”, justification is required to demonstrate why SG60 why is SG80 not met here? There is met. Furthermore this score is required if, as does not have to be a fishery the reviewer suggests, “the condition is specific EU regulation or long-term nevertheless approproiate”. management plan to achieve this.
The question here is whether the explicit objective is MSY, though P2 is not so blessed (as in most EU fisheries). I suggest harmonisation against similar MSC certified fisheries might help here.
The Condition is, nevertheless, appropriate, though I am wary of the CAP’s statement that the Long Term Management Plan (LTMP) for the stock will be reviewed annually and amendmended as necessary to ensure that all MSC principles are adhered to. A true LTP should not need to be revisited every year.
3.2.2 Yes No NA I cannot see any evidence FCI Response: It is not clear which scoring issues presented that SG100 issues have are being referred to here, Several of the scoring not been met here. issues do not have scoring opportunities at
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available rationale used the fishery’s where possible. Please attach been used to to score this performance to additional pages if necessary. score this Indicator the SG80 Indicator? support the level? (Yes/No) given score? (Yes/No/NA) (Yes/No)
SG100. In repsonse to peer review A, the text for the second scoring issue has been changed to: “In the 1990s there was a poor record of setting fishing opportunities in line with scientific advice. Since 2002, there has been much improved setting of fishing opportunities in line with scientific advice, although opportunities were set slightly above advice in 4 years from 2008 to 2012”. Interestingly Peer Review A was here arguing for a lower score. It is not correct to point to a score of SG80 as default scoring. Scoring is carried out from SG60, working up to SG100. In this instance the team concluded the SG100 scoring guideposts were not met.
3.2.3 Yes No NA I cannot see any evidence FCI Response: This scoring is consistent with presented that SG100 issues have MSC scores on many other well researched ICES not been met here. fisheries (not just pelagic). The assessment team have experience of asking a wide range of member state representatives on ICES working groups about this specific performance indicator. Although, the national / ICES research in this area is exemplary, the MSC methodology
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Performanc Has all the Does the Will the Justification Certification Body Response e Indicator relevant information condition(s) Please support your answers by information and/or raised improve referring to specific scoring issues and any relevant documentation available rationale used the fishery’s where possible. Please attach been used to to score this performance to additional pages if necessary. score this Indicator the SG80 Indicator? support the level? (Yes/No) given score? (Yes/No/NA) (Yes/No)
requires a written fishery specific research plan. The awarded score of 80 reflects that the current situation is ‘good practice’ which does not require either a condition or a recommendation. In short the system works to support management and the teams scoring seems to be a reasonable compromise between the constraints of the methodology and the practicalities of the real world.
3.2.4 Yes Yes NA FCI Response: no further response required.
3.2.5 Yes Yes Yes FCI Response: no further response required.
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Any Other Comments
Comments Certification Body Response
Scoring: there is a general tendency in this assessment to shy away from FCI Response: scoring decisions are the responsibility of the team and are awarding SG100 scores for Principle 2 issues for by catch, ETP species and taken once sufficient information has been accessed and reviewed by the team habitat, even though the evidence presented suggests that the criteria are often and after in-depth discussion and review by the team. The CR serves as a met. Similarly, much of the marking at P3 appears to use a default 80 score constant reference in taking scoring decisions and is supported by the GCR. rather than address SG100 issues. The team has only awarded scoring issues at the level they are fully satisfied that the fishery has met with. SG100 is a very high score and evidence needs
to be comprehensive, recent and offer a high degree of certainty. The team found this degree of evidential support lacking where the team was required to make scoring decisions in many instances for P2 and P3 in this fishery. Hence SG100 has not been achieved in many Performance Indicators or specific scoring issues and this is reflected in PI scores and overall scores at Principle level.
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Appendix 3. Stakeholder submissions a. Written submissions from stakeholders received during consultation opportunities on the announcement of full assessment, proposed assessment team membership, proposed peer reviewers, proposal on the use or modification of the default assessment tree and use of the RBF. No written submissions received. b. All written and a detailed summary of verbal submissions received during site visits pertaining to issues of concern material to the outcome of the assessment3 regarding the specific assessment. i) Meeting with Mr C. Milligan of C&O Milligan (fish Processors) 21/8/2013 Summary of discussion held: History of C&O Milligan business Relationship with the fishery How catch is split between the 3 main processors Bi-Catch issues – how it is dealt with and volume of other species Where the fish processed by the firm comes from – Query about Clyde herring was this ever and issue Difficulty selling non MSC certified fish – restricted market - doors closed to him as no MSC stock to sell The anticipated timeline was discussed ii) Meeting with Mr Greg Griffiths and Mr Paddy Campbell, Dept Agriculture and Rural Development 20/8/2013 Discussion took place relating to:
Landings – Recording of Data
How data was recorded and collected – (Confirmed list of Data DART will supply) If discarded catches were recorded Introduction of electronic log books Recording of any slippage Query relating to possible landings in Isle of Man - couldn’t handle such big boats Clyde – To far for boats and stringent checks - Tank dipping
Compliance enforcement
Details of the ports used to land catches, what port authority’s checks are in place. The number of checks made in 2012 - what percentage were Irish Sea fisheries/ Celtic Sea Fisheries Appeals process- Introduction of fines system CCTV – Scottish pelagic trial taking place at present Royal navy have right to board any sea vessels Query if the DART fisheries department was every auditing to check resources were sufficient – this took place 18th/19th January this year. Audit was fair – generally good
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Management
Management plan is in place – confirmation - stage of planning required from PJS Process of re-evaluating the management plan was discussed NGO involvement in management process – Meetings take place in October with invited Stakeholders Quota
The history of Skiff fishery quota and reduction DARD do not get involved with quota swaps, donations or purchases, this is done between the fisheries Quota decision is made in December annually iii) Meeting with Mr Brian Cunningham, 21st Aug 2013
Discussion took place on:
History of the Mourne Inshore fisheries Reasons behind the reduction in quota from 100 tonnes to 30 tonnes Question if Inshore fisheries should be MSC certified – fact finding mission for other fishermen iv) Meeting with Mr Andrew Orr, Skipper MFV Havilah and Mr Stephen McCullock, Skipper MFV Stephanie M 23/8/2013
Discussion took place about the abundance of Spratt in the Irish sea at present, eating the cod roe Skippers were asked how they make the decision to land at a particular port – Weather, catch size, processing all factors in this decision. Enforcement & monitoring was discussed – how often they were boarded, by whom and inspection type Level of Bycatch if any Discussed ETP interactions - Any instances of catching Basking Sharks or Minke Whales interaction – none in 30 years of fishing haven’t seen any in the nets Tolerance levels of estimated catches and landings were discussed what percentage of tolerance they have to work to. Suggestion of CCTV on board to cut out paperwork as has been trialed in Scotland – Skippers both feel it would be difficult to implement Sea bed interaction – Discussion took place regarding clump weights on nets, damage to sea bed not an issue as they have sensors on the nets and years of experience v) Teleconference with Karen McHarg, Peter Duncan and Colin Eastwood, Department of Environment, food and Agriculture, isle of Man Government. 6/9/2013 Discussion took place on:
1. Impending legislation in the Isle of Man may affect commercial fisheries operation in Manx waters 2. Establishment of access rights may cause difficulty for IoM authority in their quest to develop offshore renewable energy in Manx waters. 3. IoM authority is not sufficiently recognized/involved in the management of the stock that spawns in its waters. They only receive notice and/or invitation to meetings concerning the stock at the last minute and are frequently overlooked.
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4. No longer have a direct interest in the fishery – the size of fish generally not suitable for Manx smokeries and the fishing season is too short causing a glut of fish and raw material shortage for the smoking sector on IoM. 5. IoM have implemented the herring closure in its waters since 1973 and this has proved instrumental on the current apparent recovery of the stock. However the closed are was once much greater but has now shrunk back to an area within IoM territorial sea. 6. NIPSG vessels in the main respect the closure. 7. The IoM receives no rent from the fishery that operates largely within its waters – this does not reflect the fact that they are custodians of the resource. 8. Main concerns are lack of involvement in the decision making process for the fishery. 9. There is good compliance now for the vessels in the fishery – vessels do not come within 3nm closed area either. Vessel location is verified by 2 hr poll pattern on the VMS. 10. Vessels need Manx fishing license to fish in their waters out to 12nm, this is not a permit however so they cannot introduce conditions – such as might enable the authority to prevent vessels from going into certain areas (other than the closed areas). 11. IoM authority would like to be more involved in the decision making process c. Explicit responses from the assessment team to submissions described in a. and b. above. 1. Comments received from C&O Milligan are noted by the assessment team. These are not considered to materially affect the outcome of the assessment. Therefore no further response is made.
2. Comments received from Mr Greg Griffiths and Mr Paddy Campbell, Dept Agriculture and Rural Development are noted by the assessment team. The comments received have contributed to the assessment and have provided significant evidence that has contributed to the assessment of the fishery. As the stakeholders raised no issues of concern, no further response is required.
3. Response to issues raised by Mr Brian Cunningham, Cloughmore Shellfish The only issue of concern raised by Mr Cunningham related to the loss of entitlement by smaller vessels operating in the Mourne coastal drift net fleet. These vessels operated in the coastal seasonal fishery until such time as changed economics meant that it was favoured larger vessel fishing operations. Since the decline of the fishery, quota has been reallocated to larger vessels. While the loss of entitlement (quota) by the sentinel fleet is regrettable and it is noted that efforts are being made to try and secure extra entitlement for the Mourne fleet currently, no evidence was presented to the assessment that indicated that the fishery under assessment was impacting on the rights of the Mourne vessel operators. The assessment team note that there has been no forcible removal of quota from coastal communities, and the Mourne fishermen are eligible to buy or lease quota as any other fisherman in an open market. The coastal communities are not indigenous populations dependent on fishing for food.
4. Response to issues of concern raised by Mr Andrew Orr and Mr. Stephen McCulloch. No issues of concern were raised by either stakeholder during the discussions other than to state that the fishery has an effective zero rate of bycatch/ discarding through slippage. This has contributed to the level of understanding of the bycatch issue in the fishery and is reflected in the scoring awarded under PI 2.2 in this assessment.
5. Response to issues raised by Karen McHarg, Colin Eastwood and Peter Duncan, Isle of Man Fisheries Directorate. Given that so much of the fishery takes place in the waters of the Isle of Man (who are not EU members) the assessment team note that there are some decisions which may impact on the management of the fishery that are taken by the Isle of Man government. Notable amongst these would be decisions over closed areas in the Isle of Man’s own waters. The Isle of Man Government have expressed an interest
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Ref Type of Page Requireme Reference Details PI . Finding nt Guidance 53 CR- 1 27.12.2 If the CAB determines the It would be beneficial to include 27.12.2.1 systems are sufficient, fish and fish within this section a link or v.1.3 products from the fishery may enter reference to the vessel list (in into further certified chains of addition to the link on page 17) custody and be eligible to carry the MSC ecolabel. The CAB shall determine:27.12.2.1 The scope of the fishery certificate, including the parties and categories of parties eligible to use the certificate and the point (s) at which chain of custody is needed. a. Chain of custody certification shall always be required following a change of ownership of the product to any party not covered by the fishery certificate. b. Chain of custody certification may be required at an earlier stage than change of ownership if the team determines that the systems within the fishery are not sufficient to make sure all fish and fish products identified as such by the fishery originate from the certified fishery. c. If the point where chain of custody certification is required is covered by the fishery certificate, the team shall determine the parties or category of parties covered by the fishery certificate that require chain of custody certification.
FCI Response: Details of vessels, landings from which are included on the certificate and from which catches can enter further Chains of Custody have been included in section 5.3
Guidance 121 2 SI a – typo in first paragraph, 3.1.1 sentence starting ‘For example, the regulation states….’ does not continue
SI a – The text indicates that the ‘fishery takes place entirely in EU waters’, however in other places in the document (including P3 background section) it is indicated that the fishery also takes place in the territorial waters of the Isle of Man, which is not an EU member state. This discrepancy causes confusion.
FCI Response: SIa: Missing text added. Also we have removed the statement about the fishery taking place entirely in EU waters and added further clarification detailing the agreement between the IoM and the UK.
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Major 121, CR- Rationale shall be presented to PI 3.1.1, SI b – no rationale 3.1.1, 3 125, 27.10.6.1 support the team’s provided on how measures are 3.1.2, 129, v.1.3 conclusion tested & proven to be effective to 3.1.3, 131, justify meeting the SG100 3.1.4, 134 3.2.2 SI d– not clear how the rights of the IoM fishers are “observed” (SG80 – see also CB4.2.5.2 on taking people’s long-term interests into account) if they are not able to access herring quota because they are not members of EU Pos?
PI 3.1.2, SI c – does consultation process provide “encouragement” of participation of ALL interested and affected parties – i.e. do they encourage IoM participation?
PI 3.1.3, SI a – the rationale here refers mainly to UK objectives, also making reference to EU. However the IoM long-term objectives, consistent with MSC P1& P2 and precautionary approach, are not described.
PI 3.1.4, IoM incentives (positive/negative) not described
PI 3.2.2, SI d – not clear why it doesn’t meet SG100
FCI Response: 3.1.1 SIb: Further text added – pointing to the lack of requirement for a coastal states agreement, the effective role of the RACs and the effectiveness of the Northern Ireland Judicial process. 3.1.1 SId: The fishers of the IoM would not be described as those with customary rights, dependent on fishing for food or livelihoods, therefore arguably this issue does not belong under this PI. However it is included for the sake of clarity and because it was an issue highlighted by a stakeholder. When quotas are introduced into fisheries there is a long history of fishers pointing to unjust allocations, or alternatively changing operations in an attempt to qualify for an increased allocation. It is notoriously difficult to get right, and even more difficult, through the fogs of time, for an MSC assessment team to make a judgement on the fairness of any allocation process. The issue is further complicated by factors such as past stock declines which influenced fortunes of the respective fleets, the decline of the IoM kipper smoking industry etc. Nor is it clear how the MSC assessment process should treat historical issues – whether they be like this in respect of management or in respect of past impacts on the environment. Further text added for clarity. Also included the fact that “The Manx Fish Producers Organisation was established in 2003, for the management of quota”. 3.1.2 SIc: It is not clear the extent to which the IoM are Encouraged – therefore this scoring issue is amended to highlight this point and score decreased.
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PI3.1.3 & PI3.1.4: these refer to the Objectives and the Incentives that guide overall management policy (i.e fleets, exploitation, market and environmental sustainability etc.). In this context it is the policies that apply at an EU level (applied at the member state level by UK and at a devolved level by Northern Ireland) that are relevant to the management of the fishery. The system as described is therefore the one, which influences the management of the fishery under assessment. Describing the objectives and incentives in place for the IoM is not relevant. PI 3.2.2 SId: Further text added to explain why d is not met – essentially there is no formal reporting of the actual decision-making process. Guidance 54 In the scoring table, the below 80 4 scores in P3 are not highlighted in red. FCI Response: Amended
Minor 144,, CR- The CAB should draft conditions The conditions placed for 3.2.1 and 5 145 27.11.1.2 to follow the narrative or metric 3.2.5 do not follow the narrative of v.1.3 form of the PISGs used in the the PISGs. Suggest rewrite and final tree. have the more explicit text on how to meet the conditions be included as rationale or as a recommendation. FCI Response: Amended
Major 25 CR 27.4.9 The CAB shall identify if there 6 v.1.3 are catches of non- target Section 3.3.2 and the teams stock(s) that are inseparable or description on IPI stocks and the practically inseparable (IPI) from overall treatment of the Celtic target stock(s). Sea herring stock in this assessment is not in line with the MSC requirements for IPI stocks. The CAB seems to have provided rationale in this section that herring from the Celtic sea stock is in fact an IPI stock and likely fulfils most of the criteria in 27.4.9.1. However, already certified stocks cannot be treated as IPI catches (27.4.9.1e) If the proportion of catches from the Celtic Sea stock are to be able to receive the logo, possible options for moving forward could include: 1) The team provides a full P1 scoring for the Celtic Sea herring. This would essentially be a duplication of the P1 assessment already done for this stock, harmonised as appropriate. The separate scoring could be done by defining Celtic Sea herring as a whole new UoC, or as a separate scoring element.
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2) The team provides further clarification as to how the treatment of these two separate stocks can be regarded as a meta population/stock complex without being scored as separate scoring elements (as required by CB2.2.5, noting also CB2.3.6 and CB 2.3.8). This seems to be what the rationales provided throughout the report already suggest, given the uncertainties of mixing during spawning and questions about the genetic separation of these stocks. Although the rationale for 1.2.1 addresses this to some degree, PIs 1.2.2, 1.2.3 and 1.2.4 could also be expanded upon and how the treatment of uncertainty in dealing with this meta population is also considered and how the management responses from this fishery are not negatively impacting the health of the Celtic sea stock. MSC suggests that any further rationale provided on the impact of this fishery on the Celtic sea stock should also clarify whether catches are indeed negligible and indicating the overall stock status of the Celtic sea stock in the scoring rationales where appropriate.
FCI Response: We have not treated the catch as IPI because the Celtic stock is not eligible. We note that including Celtic Sea as additional Principle 1 was possible. However, this would not be consistent with how this stock was managed or with the treatment applied to other fisheries within the MSC programme. The problem with CB2.2.5 is that, unlike multi-species catches or salmon, for most stocks it is not possible to separate fish that have come from different spawning areas. This makes the assessment of risks very general, so CB2.2.5 can only be applied strictly when significant information is available, and the stock components are expressly managed as a complex. This is not really the case here. Significant research has been carried out (WESTHER), resulting in the general conclusion that the current divisions and management, while imperfect, are as good as they currently can be. The type of stock mixing described between the Irish and Celtic seas is very common and certainly not limited to this case. Most stocks are defined on the basis of administrative boundaries. ICES makes some attempt to divide areas up based on ecology and stock differentiation (e.g. areas of high density), but in most cases catches are allocated to stocks based on the area caught. In all these cases, there will most likely be some mixing at the administrative boundaries, but the amount of mixing is unknown. Where it is unknown, it has not been addressed within MSC assessments, but would have been considered as a general risk under the harvest strategy.
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We have addressed the stock mixing issue primarily in the harvest strategy because it is not explicitly addressed by the HCR or stock assessment. The area division (North of 52º30’N) forms part of this strategy. However, in response to MSC comments, we have added text justifying the scores to extent possible meeting CB2.2.5, 2.3.6 and 2.3.8. Specifically, we have included text where appropriate on “Adjacent Stock Considerations” for PI 1.2.1-1.2.4. This clarifies comments already made in the justification text on stock and spatial structure of populations and should make it clearer why we believe all components of the harvest are robust to this uncertainty.
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