SCS Global Services Report

Fourth Annual MSC Surveillance Audit Report

Baja California Red Lobster , Mexico

Certificate Number: F-SCS-0005

Prepared for: Federación Regional de Sociedades Cooperativas de la Industria Pesquera de Baja California, F.C.L. (FEDECOOP)

Date of Field Audit: November 17-18, 2015 Report Delivered: January 19th, 2016

2000 Powell Street, Suite 600 Emeryville, CA 94608, USA +1.510.452.8000 main | +1.510-452-8001 fax www.SCSGlobalServices.com

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Table of Contents Preface ...... 3

Glossary of Acronyms ...... 4

1 General Information ...... 6

2 Background...... 8

2 Assessment Process ...... 11

2.1 Methodology ...... 11

2.2 Surveillance Meeting ...... 12

3 Results ...... 13

3.1 Principle 1 - Stock Status and Harvest Strategy ...... 13

3.1.1 Catch and effort ...... 13

3.1.2 ...... 15

3.2 Principle 2 – Ecosystem Impacts from Fishing ...... 22

3.2.1 Retained Species ...... 22

3.2.2 Species ...... 26

3.2.3 Endangered, Threatened or Protected Species (ETP) ...... 29

3.2.4 Habitat...... 29

3.2.5 Ecosystem ...... 30

3.3 Principle 3 – Management and Regulation ...... 31

4 Status of Previously Raised Conditions ...... 32

5 Conclusion ...... 51

6 Use of the MSC blue eco-label ...... 52

References ...... 53

page 1 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

7 Appendix 1. Stakeholder Submissions and Team Response ...... 55

8 Appendix 3. Surveillance Audit Frequency ...... 55

page 2 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Preface

All facts in this report were provided to SCS Global Services, Inc. (SCS) by Federación Regional de Sociedades Cooperativas de la Industria Pesquera Baja California, F.C.L (FEDECOOP), represented by Mr. Edgar Alonso Aguilar Castillo. However, the interpretation, opinions and assertions made in this report as to the compliance of the fishery with MSC requirements are the sole responsibility of SCS.

page 3 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Glossary of Acronyms

AHP Analytical Hierarchy Process ASI Accreditation Services International BAC Biologically Acceptable Catch BCS Baja California Sur Bmin Minimum BMSY biomass at maximum sustainable yield CAB Certification Assessment Body CNP Carta Nacional Pesquera (National Chart) COBI Comunidad y Biodiversidad COFEMER Federal Commission for the Regulations Improvement Comisión Nacional de Áreas Naturales Protegidas (National Commision of Natural Protected CONANP Areas) CONAPESCA Comisión Nacional de Pesca y Acuacultura (National Commission of Fish and Agriculture) CPUE CRIP Centro Regional de Investigación Pesquera (Regional Center for Fisheries Research) CV Coefficients of variation DAT Default Assessment Tree ERA Ecological Risk Assessment ESD Ecologically Sustainable Development ETP Endangered, Threatened, or Protected F Fishing rate/catching rate FAM Fisheries Assessment Methodology v2.1 FAO Food and Agriculture Organization [of the United Nations] FCM Fishery Certification Methodology v6.1 FLIM fishing rate at which catchability will be impaired FMP Fishery Management Plan FMSY fishing rate at which catchability is sustainable and at a maximum g Gram (0.001 kg) HCR Harvest Control rule INAPESCA Instituto Nacional de la Pesca (National Fisheries Institute) IUCN International Union for Conservation of Nature Ley General de Pesca y Acuacultura Sustentables (General Law for Sustainable Fishing and LGPAS Aquaculture)

page 4 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

LRP Limit Reference Point mm Millimeter MSC Marine Stewardship Council MSY Maximum Sustainable Yield MT Metric Ton NGO Non-Governmental Organization nm Nautical mile (1nm = 1.852 km) NOM Norma Oficial Mexicana OY Optimum Yield PI Performance Indicator Secretaría de Agricultura, Ganadería, Desarrollo Rural, Pesca y Alimentación (Secretariat of SAGARPA Agriculture, Livestock, Fisheries and Food) SCS SCS Global Services SEMARNAT Secretaría de Medio Ambiente y Recursos Naturales (Secretariat of Environment and Natural Resources) SG Scoring Guidepost SICA Scale Intensity Consequence Analysis SL Standard Length (from tip of closed mouth to end of fleshy body) SSB and R Spawning Stock Biomass and Recruitment SST Sea Surface Temperature TAB Technical Advisory Board [of the MSC] TAC Total Allowable Catch TL Total length TRP Target reference point TS Target Strength VPA Virtual Population Analysis

page 5 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

1 General Information

Fishery name Baja California Red Rock Lobster Fishery Species: Red Lobster (Panulirus interruptus) Gear: Wire Traps Unit(s) of Location: Central zone in Baja California, Mexico, from Isla Cedros to Punta assessment Abreojos and Isla Guadalupe Fishing operators assessed: 10 Cooperatives in the Federación Regional de Sociedades Cooperativas “Baja California” Date certified 30 June, 2011 Date of expiry 29 June, 2016 Surveillance Normal Surveillance/Level 6 level and type Date of surveillance November 17-18, 2015 audit This surveillance audit is taking place approximately 4 months after the Justification anniversary date in order to accommodate the schedules of the assessment team and client. 1st Surveillance 2nd Surveillance Surveillance 3rd Surveillance stage (tick one) 4th Surveillance x Other (expedited etc) Lead assessor: Dr. Sian Morgan Dr. Sian Morgan, SCS Global Services, Team Leader Dr. Morgan has more than a decade of experience in marine ecology and with particular expertise in markets-based fisheries reform, certification and quantitative methods for decision analysis. She has worked in non- governmental, academic and consulting settings and brings to the team a strong background in cross-sectoral consultation. Her doctoral research at the Fisheries Center, University of British Columbia/McGill examined the population dynamics and management of a small-scale, data poor multi-species fishery in Asia. Dr. Morgan has participated standards setting and revision processes for both Surveillance fisheries and aquaculture, was a past member of the MSC Stakeholder Council team (public chamber) and is a current member of the Technical Advisory Group for the Aquaculture Stewardship Council. Examples of SCS client fisheries that Sian has managed include US Pacific Halibut, Gulf of California Mexico low trophic levels fisheries for sardine and thread herring as well as various pre-assessment and international reform projects in data-deficient developing world fisheries. Past projects managed by Dr. Morgan include developing SeaChoice, a national seafood program for Canada, conceiving pragmatic trade tools for CITES and researching species responses to area-based management for WWF. Sian is trained to audit the MSC standard, various ASC standards, MSC/ASC CoC, ISO 9001 and SA 8000. She has prior experience as a surveillance team member

page 6 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

for this sablefish fishery, is an active team leader and program manager for MSC Americas assessments, and has no conflict of interest in performing the re- assessment.

Dr. Carlos Alvarez-Flores, Consulting Team Member, Principles 1 & 3 Dr. Carlos Alvarez-Flores research interests are focused on the management and conservation of wildlife and fisheries. This includes abundance estimation; assessment of population status; estimation of population parameters; the effect of human intervention; direct harvest; bycatch and associated environmental effects; projections based on biological potential; population viability; risk assessment; design of alternative management strategies. His background comes from work dealing with large, pelagic, data rich fisheries, but his current assignments are related to small-scale, coastal, data poor fisheries. Therefore, his present challenge is to combine ideas, techniques, knowledge and experience to improve the performance of these problematic activities in developing countries. Most of his experience has been centered in practical investigations applied to population assessment and management as a consultant for governments, NGOs and the private sector of different countries. To the present, he has worked for SCS for over two years in pre-assessments, assessments and surveillance audits of different types of fisheries.

Sandra Andraka, Consulting Team Member, Principle 2 Ms. Sandra Andraka has conducted an MSC pre-assessment for SCS as well as undertaken SCS additional training in MSC process and scoring. Her varied background includes , (industrial and small-scale) and policy work and advocacy, both nationally and internationally, for adoption of conservation measures for better practices in fisheries for more than 10 years. She is been working in conservation projects in Latin America for more than 18 years, including Marine Spatial Planning, bycatch mitigation, projects linking marine turtles and cetaceans conservation with communities livelihoods, planning and implementation of conservation result-based management projects. She is currently an international consultant for NGOs, government and private sector and she has commissioned to work on assessment of the capacity needs towards implementation of the FAO Port State Measures Agreement, a proposal writing for developing a public-private sustainable marine commodities platform to mainstream sustainability in the large pelagic value chain in Costa Rica and to build capacity to develop onboard observer programs, among others. She has several publications, which meet the CR requirements for Principle 2 and 3. Ms. Andraka earned her advance degree in Environmental Planning from the International Centre for Mediterranean Studies (CIHEAM), in Spain, and a degree in Biology from the Complutense University of Madrid, Spain.

CAB name SCS Global Services 2000 Powell St. Ste.600 Address CAB contact Emeryville CA 94608, USA details +1.510-452-8000 main Phone/Fax +1.510452-8001 fax

page 7 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Email [email protected] Contact name(s) Dr. Sian Morgan Soto 283, Colonia Obrera. Ensenada Baja Address California, México. Client contact Phone/Fax +52 (646) 176 1591 details Email [email protected] Contact name(s) Edgar Alonso Aguilar Castillo Methodologies MSC Certification Requirements Version 1.3, January 2013

2 Background

SCS finds that the Red Lobster Fishery in Baja California Mexico is still in general compliance with the MSC standard. SCS recommends the continued use of the MSC certificate. Original conditions for the fishery included: 1.2.4, 2.2.1, 2.2.2, 2.2.3 and 2.5.3 (Table 2). Condition 1.2.4 was behind target in Year 1, in Year 2 conditions 2.2.3 and 2.5.3 were closed while condition 1.2.4 was brought back on target. At the third annual surveillance, conditions 2.2.1 and 2.2.2 were closed, while condition 1.2.4 was left as the only remaining open condition and was scored as behind target.

In Year 2 the client was given notice that significant ongoing progress on performance indicator 1.2.4 was expected: “while the major non-conformance against the performance indicators (1.2.4) was closed out and progress against meeting the condition judged to be back on target, further progress will need to be demonstrated throughout the next year and evidence need to be provided at the next surveillance audit”. In particular, the team noted that stock assessment work exploring alternative biologically relevant models was needed, along with use of tagging data to estimate sublegal post-release mortality, and external peer review of the stock assessment models. One component of condition 1.2.4 – to include information from the portion of the fishery taking place at Guadalupe Island demonstrated progress via collection of Catch Per Unit Effort (CPUE) data, which is expected to continue over the 2015-16 fishing season.

The team determined that if by the 4th surveillance no evidence of progress against the original condition 1.2.4 was presented, the certificate would move into suspension and potential withdrawal, as the management agency has been given sufficient time to address these concerns. During the 4th surveillance audit, the fishery submitted a stock assessment report that was considered adequate to meet requirements related to stock status and with appropriate methods. The team also received reports from external peer review of the stock assessment. Condition 1.2.4 was closed for this certification cycle.

Four conditions were raised in the second re-assessment for Principle 2; two of these conditions were closed during the second surveillance audit in 2013 and the other two were closed during the third surveillance audit in 2014. During the 4th surveillance audit, it was confirmed that progress for all

page 8 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015 conditions for Principle 2 is adequate and that they remain on target. In the re-assessment in 2012 the fishery was scored using MSC FAM V2.1 certification requirements, under this version of the certification requirements bait was scored under the Performance Indicator (PI) for bycatch species (2.2.X). In the CR V1.3 bait is scored under PI for retained species (2.1.X). For this surveillance the conditions for bait and bycatch were scored under the PIs that correspond to CR V1.3, however, the numbers associated with the PIs from the original evaluation were kept for consistency.

For condition 2.2.1 information was provided on the amount and origin of the bait, mainly locally caught bait, through the use of the monthly bait records and logbooks. In addition, information was provided on the size frequency distribution of locally caught sardines that meet the minimum sizes set in the regulations. Locally caught bait species are considered to be within the biological limits. Conditions 2.2.1 and 2.2.2 were closed based on the fact that sardines used as bait total 3,471 mt1 during the 2014-2015 season, representing approximately 6% of the total estimated catch (60,000 mt) for the whole sardine fishery in the west coast of Baja California (Hill et al. 2011; Enciso and Cotero 2014). Despite a spike in the total catch for sardines in 2011 and a sustained decline until 2014, the catch has remained stable since 2000. The average catch for the period 2000 to 2014 (approximately 1,400 mt) is lower to the latest estimate of Maximum Sustainable Yield (MSY) of near 2,360 mt.

For condition 2.2.2 reports were provided with details of the species or groups of species used as bait by month during the fishing season. The logbooks are used to report on the species or groups of species of bycatch, including bait. Non-target catch in traps appears to be low relative to the likely overall population abundance of the species captured, but more research is needed to obtain estimate of this type of fishery related potential mortality. Sharks are the only bycatch species considered to have vulnerable life history traits, these are released alive as communicated in the audits. In response to condition 2.2.3 a bycatch monitoring system has been established with each fishing team using a logbook and there is a sampling agreement for at least one boat per fishing ground per producer, but more is being sampled in practice (56% of traps in the 14/15 season). For condition 2.5.3 reports have been provided on bycatch during fishing seasons, based on data from the logbook monitoring system.

In the third surveillance audit, three recommendations were made for the conditions in Principle 2. These recommendations requested information on the size distribution of sardines caught locally, information on the contribution of the lobster fishery to the total catch of whitefish and sea bass in the areas where they are extracted and to record on logbook information at species level and whether organisms were retained, discarded or released alive. Evidence was provided on compliance with one of the recommendations (Recommendation 1: size distribution of sardines captured locally for bait). No information was provided on the contribution of to the capture of sea bass and whitefish (Recommendation 2) nor were logbooks provided with data on the destination of the bycatch species

1 Tonnes in this report follow the metric system convention that tonnes=metric ton=1000 kg. Tonnes is a non-SI unit, accepted for use within SI. In this report, tonnes is abbreviated to “mt”.

page 9 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

(Recommendation 3), although data was recorded for whitefish and shark species in some of the fishing fields. The recommendations for PI 2.1.1 and 2.2.3 that were not met could become potential conditions in the re-assessment, unless supporting evidence is provided.

Table 1. TAC and Catch Data

TAC Year 2014-2015 Amount 1,179.162 mt UoA share of TAC Year 2014-2015 Amount 1,179.162 mt UoC share of TAC Year 2014-2015 Amount 1,179.162 mt Total green weight Year (most recent) 2014-2015 Amount 1,179.162 mt catch by UoC Year (second most recent) 2013-2014 Amount 1,446.816 mt

Table 2. Summary of Assessment Conditions

Condition Performance Status PI original score PI revised score number indicator (PI) 1 1.2.4 Closed 4th surveillance 75 80 2 2.2.1* Closed 3rd surveillance 70 80 3 2.2.2** Closed 3rd surveillance 70 80 4 2.2.3 Closed 2nd surveillance 70 80 5 2.5.3 Closed 2nd surveillance 70 80 * Has considerations for bait (PI 2.1.1) and for bycatch (PI 2.2.1) but the action plan focuses on bait (retained species PI 2.1.1). ** Has considerations for bait (PI 2.1.2) y for bycatch (PI 2.2.2) but the action plan focuses on bait (retained species PI 2.1.2).

page 10 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

2 Assessment Process

2.1 Methodology

The surveillance audit was carried out in accordance with the Marine Stewardship Council (MSC) Certification Requirements Version 1.3, January 2013. Should a fishery fail the surveillance audit, and cannot address identified deficiencies in a reasonable period of time, then the use of the certificate and the MSC logo can be revoked by the certifier.

The issues for the certifier are whether the fishery has sufficiently acted on the required conditions set forth in the original certification report, is moving at an appropriate pace toward future conditions and whether a random check on the performance of the fishery verifies continued compliance with the MSC standards and existing scores.

The annual surveillance audit process is comprised of four general parts:

1. The certification body provides questions around areas of inquiry to determine if the fishery is maintaining the level of management observed during the original certification. In addition, the surveillance team requires that the client provide evidence that the fishery management system has taken the necessary actions to meet all conditions placed on the fishery during the initial certification assessment or any previous surveillance audits.

2. The surveillance/assessment team meets with the client fishery to allow the client to present the information gathered in answer to the questions asked by the surveillance team The surveillance team can then ask questions about the information provided to ensure its full understanding of how well the fishery management system is functioning and if the fishery management system is continuing to meet the MSC standards.

3. The surveillance team presents its findings to the client fishery at the end of the site visit. The results outline the assessment team’s understanding of the information presented and its conclusion regarding the fishery management system’s continued compliance with MSC standards.

4. Where appropriate, the client fishery submits final information to the surveillance/assessment team for consideration in the surveillance findings and report. The surveillance team then reviews the final information and submits a final report to the client fishery and the MSC for posting on the MSC website within 30 days. If there are continued compliance concerns, these are presented as non-conformities that require further action: changes in scores require clients to create an action plan against any new conditions.

page 11 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

2.2 Surveillance Meeting

The surveillance audit for 2015 comprised of the following:

1. An Audit Plan was provided to the client, fisheries management and scientists before the meeting. The opening with the client included an exchange of information relevant to the surveillance audit.

2. A meeting took place on the November 17nd and 18th 2015 in Ensenada, Baja California, Mexico. Participants of the onsite meeting, including Mr. Mario Ramade representing the FEDECOOP are listed in Table 3. The discussions focused on the ongoing activities associated with the Conditions placed on the fishery and any changes that occurred since the fishery was first certified.

Table 3. Fourth Annual Surveillance Audit Attendees and Organizations

Name Role Affiliation Aldo Murillo Villavicencio Technical Representative Coop. Leyes de Reforma

Armando Murillo President Administrative Council Coop. La Purisima Armando Vega Velazquez Director, C.R.I.P. INAPESCA Carlos Alvarez Assessment Team Member SCS Carmina Salinas Ivan Technical Representative Coop. Emancipación Celerino Montes Subdirector CONANP Claudia Miranda Technical Representative Coop. San Ignacio Daniel Romero Arce Technical Representative Coop. Pescadores Nacionales de Abulón Donaxi Borjes Flores Representative of RBIG RBIG-CONANP Edgar Camacho Researcher INAPESCA CRIP-La Paz Eduardo Enriquez Gonzalez Technical Representative Coop. Punta Abreojos Coop. Isla Guadalupe Abuloneros y Elviz Estrada Adminstrative Representative Langosteros Secretary of the Administrative Evaristo Hernandez Coop. La Purisima Council President of Surveillance Francisco Camacho FEDECOOP Committee Gabriel Jimenez Researcher INAPESCA CRIP-La Paz Gabriel Arce V. Treasurer Coop. La Purisima Gabriela Anhalzer Observer SCS Treasurer, former President of Geronimo Aguilar FEDECOOP the Surveillance Committee Gustavo Villavicencio Perlata Technical Representative Coop. Leyes de Reforma Coop. Isla Guadalupe Abuloneros y Javier A. Gonzalez Administrative Secretary Langosteros Jose Ramon Franco Santiago Technical Representative Coop. San Ignacio Juan Carlos Bonilla Technical Representative Coop. Emancipación Julián Castro García Jefe de Centro INAPESCA

page 12 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Mario Ramade Client Representative FEDECOOP Mario Ramade Villanueva President FEDECOOP Director, Isla Guadalupe Marisol Torrez Aguilar CONANP Protected Area Oscar Humberto Baylon CONAPESCA Grecco Subdelegado Ramon García Arce Technical Representative Coop. Bahía Tortugas Roldan Maldonado Fisheries Officer CONAPESCA Sandra Andraka Assessment Team Member SCS Sian Morgan Assessment Team Leader SCS Vicente Romero Valenzuela Technical Representative Coop. San Ignacio

3. Necessary documents were presented by the client to SCS prior to and during the meeting. Follow up emails were sent to request additional information after the meeting, including a peer reviewed stock assessment that was sent to the assessment team on January 8th, this document was required to close condition 1.2.3 for this surveillance cycle.

3 Results

3.1 Principle 1 - Stock Status and Harvest Strategy

3.1.1 Catch and effort

The average catch of lobster in the Pacific coast of Baja California from 2009 to 2014 accounts for about 80% of the total catch for lobster in Mexico. The 10 FEDECOOP cooperatives from the unit of assessment operating in the central region of the Peninsula, from season 2010/11 to 2014/15, caught approximately 70% of the total catch in the Peninsula, making it the most important lobster fishery in the country. Table 4 summarizes the catch and effort information for the 10 fishing cooperatives from 2011 to 2015 Total catch has declined from 1,598 mt in the 2012/13 fishing season, to 1,446 mt in 2013/14 and to 1,241 mt in the 2014/15 season2 (Table 4; Figure 1). However, effort (total traps used) has also been declining (Table 4; Figure 1). Members of the fishery stated that effort was deliberately lowered due to diminished prices for spiny lobster in the market.

2 Catch for the 2014/15 season was 1,241 mt according to the INAPESCA stock assessment report. Catch for the same season reported by the FEDECOOP was 1,179 mt.

page 13 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Figure 1. Catch (bars) in metric tonnes and effort (continuous line) in trap/haul for red spinny lobster in the central region of the Pacific coast of Baja California, Mexico. Reproduced from Vega-Velazquez et al. 2015.

page 14 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Table 4. Total Catch (mt) and Total effort (number of trap/hauls) for each of the 10 fishing cooperatives during the 20011/12, 12/13, 13/14, and 14/15 fishing seasons (Ramade, V.M. et al. 2013, 2014, 2015).

COOPERATIVE 2011/12 2012/13 2013/14 2014/15 NAME Total Total Total Total Total Total Total Total catch effort catch effort catch effort catch effort Abuloneros Y 9.355 16,241 7.165 11,092 8.021 13,332 6.999 12,918 Langosteros Pescadores Nacionales De 281.321 242,280 256.901 259,280 200.502 251,350 177.529 250,946 Abulon Buzos Y 145.569 178,888 170.340 180,310 151.778 200,811 151.518 155,392 Pescadores La Purisima 304.208 373,536 259.425 352,351 248.376 378,556 227.451 366,231 Bahia 240.330 272,815 190.553 238,791 163.615 233,737 141.928 232,437 Tortugas Emancipacion 221.564 267,683 172.018 267,650 167.013 223,380 102.195 201,562 California De 118.294 134,874 88.378 124,346 79.387 103,431 56.554 86,196 San Ignacio Leyes De 200.551 150,150 134.104 154,957 105.396 158,477 70.488 77,165 Reforma Progreso 170.271 376,750 140.346 341,626 145.516 346,523 87.280 300,856 Punta 216.545 288,532 186.241 290,326 185.234 282,910 157.219 256,829 Abreojos TOTAL 1,898.654 2,301,749 1,598.307 2,220,729 1,446.816 2,192,507 1.179.162 1,940,532

3.1.2 Stock assessment

An updated stock assessment was presented which repeated the estimation process using a biomass dynamics model and added progress in incorporating evaluation methodology which accounts for the effect of fishing on different size/age classes as affected by the size regulation (Vega-Velazquez et al. 2015). Main features in this assessment are size class analysis, impact of damaged lobsters, biomass dynamics model estimation and analysis using tunned Virtual Population Analysis (VPA).

3.1.2.1 Analysis of length distribution

Data was collected from massive samplings to obtain information on length composition of all sizes and compare it to data from the commercial catch (Figure 2). Pooled data from 1997 to 2015 show that a substantial fraction (88.7%) of the population is under the legal size of 82.5 mm of carapace length and that only the remaining 11.3%, above the legal size, was available to the fishery (Vega-Velazquez et al. 2015). Given that the estimated size at first reproduction is of 72.6 mm of carapace length, there is a proportion of spawning animals that are unavailable to the fishery. However, there are virtually no animals of the largest length classes above 115 mm.

page 15 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

a)

b)

Figure 2. Length distribution of red lobsters: females (a) and males (b), in the central region of the Baja California as recorded from massive sampling (red line) and the commercial catch (grey bars). Reproduced from Vega- Velazquez et al. 2015.

page 16 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

3.1.2.2 Estimating mortality due to handling

During the 2014/15 season out of a total of 48,082 individual lobsters caught during massive samplings, less than 1% (n= 443) were either killed or fatally injured, including lobsters under the minimum legal size that were returned to the sea. The re-certification report of 2011 states that: During the evaluation process we found some information reporting that in one specific fishing area “the bycatch of sublegal lobster is substantially high (86%) which, depending on the post-release mortality, could be a concern” (Shester, 2008). In order to evaluate the degree of concern of this mortality, the assessment of the post- release mortality is highly recommended in incorporated into the stock assessment process. This section in condition 1.2.4 stipulates an evaluation of the potential post-release mortality for all released lobsters, not just those injured. The original request from the re-certification process has not been fully addressed and it is recommended that the issue continues to be monitored in subsequent audits.

3.1.2.3 Biomass dynamics model assessment

Estimates of the status of the stock, from biomass dynamics model, indicate very stable abundance trend since the mid-90s, with a slight decline in the last three years (Figure 3). This Figure also shows that from the mid-90s biomass is approximately 60% over the level producing MSY. The current catch level in 2014- 15 (2,358 mt) is close to 65% of the estimated MSY (9,930 mt) (Figure 4). The estimated current harvest rate is near 0.1 and the harvest rate producing MSY is at 0.24. While the overall methodology is not described in sufficient detail in the report, the results appear consistent with the exception of the fit of the observed catch to the model predictions. This is not a major problem but an indication that implementation details can be improved.

Figure 3. Estimated biomass trend using a biomass dynamics model on red lobster caught in the central region of the Pacific coast of Baja California. Total abundance (B(t)) is compared with the biomass level producing MSY (Bmsy) and the current catch record (CAPTURA(t)). Reproduced from Vega-Velazquez et al. 2015.

page 17 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Figure 4. Probability distribution of MSY of red lobster caught in the central region of the Pacific coast of Baja California. MSY is estimated using a biomass dynamics model. Reproduced from Vega-Velazquez et al. 2015.

3.1.2.4 Virtual population analysis

The estimated biomass trends obtained by means of VPA were quite stable since the mid-90s until 2010 and 2011 when a slight increase followed by a decline that continues until 2014 (Figure 5). This later decline in biomass appears to be the result of a decrease in recruitment, which shows a similar decline in the same years (Figure 6). During the period of stability biomass was estimated to be around 4,000 mt, this figure differs significantly from the approximately 16,000 mt estimated using the biomass dynamics model. The discrepancy in biomass estimates is a direct reflection of the uncertainty in the control parameters for each model (e.g. intrinsic rate of increase, carrying capacity, terminal fishing mortality and natural mortality). Consequently, the harvest rate estimated with the VPA is more than twice the estimated harvest rate from the biomass dynamics model.

Figure 5. Total red lobster biomass estimated through VPA for data from the fishery in the central region of the Pacific coast of Baja California. Reproduced from Vega-Velazquez et al. 2015.

page 18 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Figure 6. Recruitment of red lobster biomass estimated through VPA for data from the fishery in the central region of the Pacific coast of Baja California. Reproduced from Vega-Velazquez et al. 2015.

The age specific fishing mortality rate, as shown in Figure 7, shows variations across different age groups, with lobsters age 11+ subject to a more intense fishing rate. Assuming that across any unit of effort the selectivity and catchability of the traps is constant, the different age classes of lobsters above the minimum legal size are subject to the same fishing pressure. Consequently, rather than an instantaneous fishing mortality rate, the variations across age classes may be reflecting the harvest rate proportional to the biomass for each age class. If so, a higher F value indicates age classes with less abundance rather than age classes subject to higher fishing pressure. This is an interesting aspect that deserves further investigation, particularly if it leads to improvements in the trap to reduce pressure on these older animals that may have a higher reproductive potential.

page 19 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Figure 7. Average age specific estimated fishing mortality rate of red lobster using VPA, females are on the left and males on the right. The estimates cover the period from 1990 to 2014. Reproduced from Vega-Velazquez et al. 2015.

3.1.2.5 Handling uncertainty

The stock assessment includes recognition of the necessity to account for the uncertainties associated to the statistical process of inference. Model uncertainty has been a major concern in the MSC assessment of this fishery and a requirement was added to present an analytical approach to better examine the effect of size-based management actions. The latest version of the stock assessment was improved with the use of the ADAPT platform to run a tuned VPA. This attempt revealed relevant aspects such as the trend in recruitment and some effects of trap selectivity on older age classes. However, it is considered that the potential of the ADAPT platform is yet to be used to its full potential to investigate the original question on size-based management strategies. Although the SCS team accepts the current considerations for model uncertainty in the stock assessment, we are recommending that in future reports the authors include thorough descriptions of any methodology applied If the ADAPT platform continues to be used the assessment should carry out a more in-depth analysis of age structure and trends to identify cohort strength in time and to better understand the effect of gear selectivity and size- based management strategies. We do not advocate the use of any specific platform, and it will be acceptable if the current platform is chosen to continue conducting assessments. The assessment team does recommend considering the use of other approaches that are not only statistically stronger, but also more versatile to allow a broad set of analyses, including incorporation of environmental effects correlated to cohort strength. In particular, the team is concerned about the use of modelling approaches that can’t directly analyse lengths. Direct conversions from lengths to age introduce considerable uncertainty, particularly if no other analyses are made to understand the effect of length on age variability. Differences in length to age conversions may affect estimates of the contribution of maturing animals that are not vulnerable to the fishery, to the spawning stock. If other approaches are considered it may be possible to include formal statistical comparisons of model performance and to further investigate potential effects.

In terms of observation error, the stock assessment includes probability distributions of parameters associated to the logistic model parameters and for MSY. However, no indications are made as to how

page 20 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015 these distributions were computed. When using the ADAPT platform a series of indices are included to represent uncertainty. Most of those indices are only shown in tables but little to none description or discussion is included. In addition, some statements are incorrect or inaccurate, for example, in the report states that low coefficients of variation (CVs), associated to the bootstrapping results indicate that “biomass was well estimated” (Vega-Velazquez et al. 2015, p. 47). A low CV indicates that the resulting estimate has a high level of accuracy, but tells nothing about the level of bias of the estimator. This estimator may be very accurate but could be highly biased, resulting in a poorly estimated biomass. Similarly, a low CV may partly be due to low variability in the data, but it does not address goodness of fit as stated in Section 4.6.3 “Uncertainty” of the report. The audit team suggests greater caution in the interpretation of these results.

The uncertainty associated to the reconstructed trends in ADAPT is also unusual (Figures 28 and 29, Vega-Velazquez et al. 2015, p. 48-49). For the re-assessment the team recommends a more detailed discussion explaining the narrowing of confidence intervals as they go back in time, this should also include input from the external peer reviewers.

3.1.2.6 General considerations from the stock assessment

The results of the stock assessment indicate that the stock of red lobster subject to the fishery in the central region of Baja California is well above the level producing MSY and that fishing takes place at a rate that is much lower than that producing MSY. Despite differences in the absolute abundance estimated with both methods, the trends are similar and it is likely that the decline in abundance and recruitment is a process unrelated to the fishing activities which is not captured in the biomass dynamics model. The apparent health of the stock is reinforced by the data on the length distribution of the catch compared to that of the population. This data shows that every year an important proportion of lobsters are left to grow and reproduce which assures continuous supply of animals of legal size. These analytical approaches need to be further improved by using more versatile assessment methodologies or at least investigating the sensitivity of the results in critical assumptions including variability in growth, terminal F and natural mortality. It is also necessary to compute confidence intervals for the trend in the biomass dynamics model and to revise the intervals in the ADAPT platform. These improvements are included as recommendations to monitor in future audits.

An analysis of the genetic structure of the Red Lobster in Baja California (García-Rodríguez and Pérez- Enriquez 2006) reported little mtDNA differentiation in lobsters along the Peninsula. The authors however discussed the relevance of apparently contradicting results of previous analyses using allozyme differentiation. They concluded that homogeneity of mtDNA is related to the presence of intense genetic flow in a stable population where the forces driving genetic differentiation are more related to drift and mutation, whereas protein variability is more influenced by selection and the effect of local environmental conditions. This suggests the possible existence of a meta-population with moderately discrete units interconnected by larval flow. The analytical approach to evaluate such a population is then simple to share a set of biological characteristics and keep some other exclusive to specific locations. This can be

page 21 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015 extremely helpful to better understand the effects of differential approaches to management and harvest in a population that shares common biological driver parameters.

3.2 Principle 2 – Ecosystem Impacts from Fishing

3.2.1 Retained Species

At the time the full assessment was conducted (2010), bait was considered as bycatch Accordingly to the FAM V2.1 certification requirements Under MSC CR Requirements V1.3, bait is considered a retained species, which is dealt with in that section of PI 2.1.X. Based on the original assessment, we have clearly separated both issues, but retained the numbers associated with the scoring system used for the original assessment.

Since the 2011/12 season, the fishery is using fishing logbooks to record retained and bycatch species captured in the observations column (Table 5). Evidence provided indicates that the logbooks are used to collect information on non-target species, including species that are used as bait, but the end use (retained, discarded alive/dead) is not specified. Through personal communications with the FEDECOOP technicians and the client representative, the assessment team was able to verify that the “finfish” category (Table 5. Total number of individual organisms from bycatch and non-target species caught in lobster traps operated during the 2014/15 fishing season, extrapolated from 56% (1,089,127 traps) observed traps to the total number of the traps operated by the 10 COOPs covered under the unit of certification.Table 6) includes several fish species that are used for bait, mainly vieja (Semicossyphus pulcher), lopon (Ophiodon elongates) and cabrilla or verdillo (barred sand bass - Paralabrax nebulifer and P. clathratus). The landing ticket (permiso de arribo) reports the species used for bait, for example sea bass and blanco (ocean whitefish - Caulolatilus princeps). There is a low percentage that is captured and consumed but not recorded at the landing, for example, sea bass. Depending on the availability of sardines for bait, the retained bycatch is used for bait.

In the third surveillance audit a recommendation was made to present information on the contribution of the lobster fishery to the total catch of whitefish and sea bass in the zones where they are extracted. Limited progress has been made on this recommendation. Captures of species in the “finfish” category are recorded as numbers of organisms only, consequently the contribution of “finfish” to the total catch volume for the fishery cannot be accurately estimated, nor can the proportion of species used as bait be calculated. By using the number of individual lobsters captured the assessment team roughly estimated that the contribution of the “finfish” category is less than 5% of the total lobster catch landed, therefore, none of the species listed in Table 5 are considered a “main” retained species.

page 22 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Table 5. Total number of individual organisms from bycatch and non-target species caught in lobster traps operated during the 2014/15 fishing season, extrapolated from 56% (1,089,127 traps) observed traps to the total number of the traps operated by the 10 COOPs covered under the unit of certification. Reproduced from Ramade- Villanueva et al. 2015.

Species # Organisms Org/Traps Organisms /Season 2014/15

Crabs 19,171 0.018 34,158 Finfishes 12,318 0.011 21,947 Octopus 5,092 0.005 9,073 Sharks 3,293 0.003 5,867 Eels 1,206 0.001 2,245 Sea snail 1,204 0.001 2,145 Sea birds (cormorant) 32 0.000 57 Sea cucumber 17 0.000 30 Starfish 5 0.000 9 Abalone 1 0.000 2 Sea urchins - - - Total 42,339 75,533

Table 6. Total number of individual species in the “finfish” category caught in lobster traps operated during the 2014/15 fishing season, extrapolated from 56% (1,089,127 traps) observed traps to the total number of the traps operated by the 10 COOPs covered under the unit of certification. Reproduced from personal communication with Ramade, 2016.

Spanish Common Scientific Name Number of Name organisms Vieja Semicossyphus pulcher 7,423

Lopon Ophiodon elongatus 5,175

Cabrilla Paralabrax clathratus and P. nebulifer 4,969

Blanco Caulolatilus princeps 2,478

Naranjo Hypspops rubicundus 923

Jurel Seriola lalandi 332

Roncador Anisotremus davidsoni 159

Lenguado Paralichthys spp 123

Rocot Sebastes mystinus, S. miniatus and S. caurinus 86

Mojarra Embiotoca jacksoni 77

page 23 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Chololo Kelletia kelletii 77

Barbito Umbrina roncador 77

Curvina Argyrosomus regius 75

Total 21,974

Since the 2010/2011 season, a “Monthly Bait Production Record – Lobster Fishery” is used to report the details of the bait used each month of the fishing season (September-February). In the last surveillance audit the client submitted unpublished data that indicates that information is being collected at the species level for the “fish” category ((Table 7).

The “Report of the 2014/15 Lobster Season” provided during this surveillance audit, shows that the 10 COOPERATIVES used a total of 3,577,575 kg of bait (Table 7Table 6). This amount is very similar to the amount used in the 2012/13 season and 18% less than the amount used in the 2013/14 season. The main bait species used in fishing are sardines, which are bought from the commercial fishery in Ensenada and captured locally by the artisanal fishers of the cooperatives. Local sardines are caught using gear for purse seining tuna.

In the 2014/15 season, 96% of the bait was Pacific sardine (Sardinops sagax), of which 55% corresponds to purchases made in the city of Ensenada, B.C., whose origin could be the fleet that is operating just off Sinaloa and Sonora, or out of Ensenada, but is the audit team was not able to determine this. The remaining 45% of sardines used for bait corresponds to captures made within the area of the unit of evaluation by the cooperatives. The latter is recorded on the landing ticket requested by CONAPESCA. Pacific sardines account for more than 5% of the total catch by weight, and therefore are considered a “main” species.

The total catch volume of sardine used as bait is 6% of the total catch estimated for the total sardine fishery on the west coast of Baja California (Enciso and Cotero 2014). The mean of the estimated distribution for this sardine stock maximum sustainable yield is near 60,000 mt with an approximated 95% CI of 47,000 to 76,000 mt (Enciso and Cotero 2014b). This implies that an increment of 6% in the catch puts the exploitation level slightly above the estimated mean and nowhere near the upper CI limit. Under these conditions, it was considered unlikely that the sardine catch for bait could have a critical effect on the sardine stock.

page 24 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Table 7. Volume of bait used by all 10 COOPs in the 2012/13, 2013/14 and 2014/15 lobster fishing seasons by species or species groups. Reproduced from Ramade-Villanueva et al. 2015.

2012/13 2013/14 2014/15 Category Volume (kg) % of TC Volume (kg) % of TC Volume (kg) % of TC Sardine Ensenada 2,109,006 132% 2,513,435 174% 1,898,139 161% Sardine Local 1,399,976 88% 1,210,376 84% 1,553,023 132% Whitefish/Fish 30,496 2% 39,596 3% 59,294 5% Mackerel 22,778 1% 39,460 3% 57,805 5% Sheephead 3,050 0% 3,869 0% 0% Bonito 5,549 0% 15,825 1% 5,078 0% Sea Bass 5,750 0% 43,298 3% 0% Skipjack 0% 2,000 0% 295 0% Others 0% 17,319 1% 0% Squid 0% 0% 633 0% Carcajes (Waste) 0% 0% 3,308 0% Total Volume Bait 3,576,605 224% 3,885,178 269% 3,577,575 303% TC Lobster 1,598,307,00 1,446,816,00 1,179,162,000

In addition to sardines, the volume all other species reported as bait (Table 7) is lower than 5% of the total catch for the 2012/13 and 2013/14 seasons. In the last fishing season mackerel increased to represent 5% of Total Catch for the fishery, since on average Mackerel is under 5% it is not considered a “Main” retained species. Under the “Whitefish/Fish” category most species are groupers and sea basses, other fish species used as bait include sheepheads (Archosargus probatocephalus). These species might be non-target retained species from the lobster fishery or may be coming for fish traps used by the cooperatives to target fish. Without a clear understanding of the origin of bait species in the “Whitefish/Fish” category the audit team was unable to compile a list of all retained and bycatch species and their respective contribution to the total catch of the lobster fishery.

During the third surveillance audit, a recommendation was issued to present information on the size distribution of sardines captured locally to ensure that these conform to existing minimum size limits in national regulations. During this audit, information was provided on the sizes recorded for Pacific sardines. The data correspond to Punta Abreojos and Bahía Asunción, where most of the captures are made. All sizes are above the 150 mm in length, as required by NOM-003-PESC-1993 (Figure 8). This recommendation is considered to have been met.

page 25 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Figure 8. Size frequency distribution of sardines (Sardinops sagax) used as bait in the 2014/15 season (Source: 2014-2015 lobster season report). Title: Pacific Sardine Size Distribution. X axis: Standard length (mm). Y axis: Frequency (%). Source

During the fourth audit the team identified the capture of two tropical lobster species, the blue lobster (P. inflatus) and the green lobster (P. gracilis), which are also captured in traps for the red lobster and are retained. No information is available on catch volume in the certification unit, but for Baja California Sur, the average is 128 tons for both species. For all the fisheries of the Baja California Peninsula, it is estimated that 95% of the catch is red lobster and the remaining 5% contains the two other species (Vega et al. 2014). The tropical lobster catch is more abundant for the central area of the west coast of BC to the south of the Peninsula.

Recommendations:

 Provide data (volume) at the species level for the “Whitefish/fish” bait category and other species used as bait and indicate what proportion is sourced from retained species within the unit of assessment.  Provide catch data (volume) for blue and green lobsters as retained species in the evaluation unit.

3.2.2 Bycatch Species

The bycatch in this fishery is considered moderately low (Shester 2008). The studies conducted by Dr. Fiorenza Michelli which include the results of Shester (2008) provide estimates on the quantity and composition of the bycatch species retained and discarded, and the bait used in the fishery. The total bycatch represented approximately 13% weight of the lobster catch. In of the lobster fishery approximately 3.6% of the organisms landed in the 2012/13 season were non-targeted catch and 2.4% in the 2013/14 season. Therefore, none of the species fall under the category of “main bycatch species”, however, there are two groups that play important roles in the ecosystem as top predators or are vulnerable species, sharks and cormorants, respectively.

page 26 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

In the second surveillance audit (2013), it was agreed that at least one boat per fishing ground/cooperative within the unit of assessment would be monitored with the use of a logbook. The logbook system, designed by INAPESCA and FEDECOOP, records data on bycatch species in an “observations” column. From the second audit to date, the client has provided evidence of the use of the logbooks to report bycatch. According to the analysis of the data from the logbooks there are 11 species or groups of species that are caught incidentally (Table 5). During the 2014/15 season the logbook monitoring covered 56% of the traps deployed during the season. The data is extrapolated to estimate the total organisms caught in the total number of traps according to a coefficient of org/trap. The total number of traps checked in the 201/15 season increased form past 2013/14 and 2012/13 seasons, not only in percentage but also in absolute number (Table 8. Number of traps observed for bycatch data in the fishing logbooks for three seasons. .

Table 8. Number of traps observed for bycatch data in the fishing logbooks for three seasons. Reproduced from Ramade-Villanueva et al. 2015.

Number of traps observed Season Number of traps % of total traps for bycatch

2012/13 2,220,729 599,597 27%

2013/14 2,192,507 909,091 41.5%

2014/15 1,940,532 1,089,127 56%

Compared with the results of the analysis of past seasons including data from Shester (2008), we can see that the dominant species are crabs and fish (estimated to comprise only 1.11% and 0.7% of the total lobster catch by weight) (Table 9). In the fish category Shester (2008) recorded 40 species, while data collected on the FEDECOOP logbook records lists 13 finshish species and 2 shark species (Table 6; Table 9). The shark group includes horn sharks (Heterodontus francisci) and swell sharks (Cephaloscyllium ventriosum), with records of 4,156 and 1,711 individuals captured respectively during the 2014/15 season (M. Ramade, personal communication, January 8, 2016). Horn sharks are considered Data Deficient by the IUCN and swell sharks are categorized as Least Concern (Carlisle, A.B. 2015; Villavicencio-Garayzar et al. 2015). Neither species have any commercial value and are not retained. Also neither of these two shark species are included in NOM-059-SEMARNAT-2010 for protected species or in NOM-029-PESC- 2006 for the responsible fishing of sharks and rays.

In the “Crab” group the genus Cancer dominates, there is a license for the commercial exploitation of these species. In the “Caracol (Snail)” group we have the caracol tornillo (Astrae spp.). For “Octopus”, “Eel”, “Cormorant”, “Sea cucumber” and Starfish, only one species is recorded for each group. In general, the species or groups of species are similar throughout the seasons, although there are several species, with varying abundance, that did not appear in the records of Shester (2008), (eels, sea cucumbers, starfish, abalone and sea urchins). Noteworthy are the differences in individual octopus captures in the

page 27 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

2012/13 season, and that in general the numbers recorded by Shester (2008) are higher than those in the logbooks, especially for cormorant captures (Phalacrocorax spp). Shester’s numbers are extrapolations from the samples, however, the audit team did not find a written explanation accounting for these differences.

In the case of cormorants, during the third as well as the fourth audits, it has been suggested that Shester’s sample was smaller and focused only on two fishing zones, while the logbook data encompass a larger sampling effort in all the fishing zones of the 10 cooperatives. Cormorants are caught when they dive into traps on the bottom. One of the technicians from a cooperative asked a researcher from the University of Ensenada who monitors birds in Guerrero Negro and Laguna San Ignacio about Shester’s numbers (2008) for the cormorant bycatch. According to the expert, the high figures could be that the result of an atypical year for the migration of that species. It is also assumed that the larger catches in some years could mainly consist of less experienced juveniles that are looking for food when it is not available and they tend to resort to taking bait from the traps.

Table 9. Estimates of by species group and number of individuals for season. Reproduced from Ramade-Villanueva et al. 2015 and Shester 2008.

Species 2006/07* 2012/13** 2013/14** 2014/15**

Crabs 143,418 38,306 38,434 34,158 Finfishes 35,624 34,559 24,499 21,947 Octopus 1,851 28,821 6,828 9,073 Sharks 31,922 7,262 4,901 5,867 Eels - 2,072 2,159 2,245 Sea snails 32,487 2,262 4,520 2,145 Sea birds (cormorant) 16,655 241 65 57 Sea cucumber - - 12 30 Starfish - - - 9 Abalone - 8 2 2 Sea urchins - - 12 - Total 261,957 42,339 81,432 75,533 *Data from Shester (2008). ** Data from FEDECOOP logbooks

The FEDECOOP technicians believe continuous work with the fishers will improve bycatch data recorded in the logbook. Currently data collection on bycatch species is not seen as a priority and the quality of the data depends on the fisher. Some records contain species level details, others records only go down to groups. The technicians assert that due to the fishing conditions it is difficult to record more detailed data,

page 28 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015 including size or destination of the bycatch and that the fishers have commitment to record data to the species or group level. However, there does not appear to be standardized detail level between cooperatives. A recommendation was made in the 2014 audit pertaining to recording information in the logbook on the capture of non-target species by individual species and recording whether each was retained, discarded dead or alive. As was communicated in the audits, but not recorded in the logbooks, some bycatch species are retained (e.g. sea bass, green lobster, blue lobster), others are discarded (such as birds that tend to be dead because they were caught on the bottom) and others are released alive (e.g. sharks, crabs, and others). There are no formal written procedures or best practices for bycatch but the fishers customarily release animals that are not lobsters or other species of commercial interest.

Recommendations:

 Provide some sampling system to verify the accuracy of the data collected in logbooks and to collect information at species level and destination for bycatch.

 Demonstrate improvements in monitoring plan to standardize effort and quality of data collected across the different fishing fields/cooperatives.

3.2.3 Endangered, Threatened or Protected Species (ETP)

No interactions with ETP species have been reported in the red lobster fishery of Baja California. During the audit the information was confirmed with representatives of CONANP who participated in the meetings. One cooperative operates in the Isla de Guadalupe Biosphere Reserve and eight others operate within the Vizcaino Biosphere Reserve, both of these reserves are habitat for species with special protection status; gray whales (Eschrichtius robustus), pinnipeds including the northern elephant seals (Mirounga angustirostris), sea lions (California sea lion - Zalophus californianus), the Guadalupe fur seal - Arctocephalus townsendi), and white sharks (Carcharodon carcharias). The client group confirmed that there are no reports of interactions between the fishery and these species. In the Vizcaino Reserve, fishing is not allowed in the bays and special zones from December 15 of each year to April 30 of the next year due to the start of the gray whale breeding season, according to Rule 104, paragraph XX of the area’s management plan.

It is likely that the effects of the fishery are within the limits of national and international requirements for the protection of ETP species, and it is unlikely that direct or indirect effects are causing any unacceptable impact to ETP species.

3.2.4 Habitat

There is empirical evidence that suggests it is highly unlike the fishery is reducing habitat structure and function to a point where serious or irreversible damage could occur. The studies of Shester (2008) and Eno et al. (2001) describe very few direct impacts to benthic habitat associated with trap fisheries. There is no direct impact on the rocky substrate, most of which is covered by coralline red algae. The traps are

page 29 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015 sunk with weights to prevent them from being dragged along the bottom, so they rarely cause more direct impact to the substrate. In hauling the trap, some algae can be uprooted but they recover quickly.

It is estimated that there is no mortality due to ghost fishing because the traps have “locks” or clips that are biodegradable.

There are several management measures whose purposes can also be considered to provide direct habitat protection and impact management. These measures include limits on the number of traps, controlled access, and prohibitions on the use of other fishing gear. The audit team recommends providing strategy that considers information on the distribution of the different habitat types and informs the management of the fishery’s impact on different habitat types.

3.2.5 Ecosystem

The west coast of Baja California, Mexico is a highly variable ecosystem that transitions from cold areas in the north to a subtropical ecosystem in the south. The area is characterized by high productivity compared to areas in southern California. Two of the main are in Punta Eugenia and Punta Abreojos, in the central area of the Peninsula, where lobster abundance and captures are higher.

The seabed in this region is sandy and cobbled, most of the rocky substrate is covered by coralline red algae, and there are gorgonian corals. Kelp is very common which is characteristic of cold water upwellings. Sea urchins and abalone feed on kelp. Other species associated with kelp forests are kelp bass (Paralabrax clathratus), mackerel (Trachurus symetricus), and yellowtail (Seriola lalandii).

Most of the cooperatives operate in two Biosphere Reserves that conserve particular terrestrial and marine ecosystems: Vizcaino and Isla Guadalupe, the latter has particular geographic conditions as it is an offshore island.

Lobster habitats are rocky areas from the lower intertidal zone to approximately 100 m depth. The adults move from deeper to shallower areas (less than 20 m) for reproduction and “hatching” from March to May. In this complex ecosystem, lobsters are members of assemblages that are rich in coastal pelagic species (sardine, northern anchovy and mackerel); demersal-reef fish (cabrilla, grouper, tilefish, whitefish, sheephead, triggerfish, dogfish shark, nurse shark, etc.) and benthic communities of flora and fauna associated with macro-algae forests and seagrass beds (Vega et al. 2014). The fauna also includes crustaceans (crabs, etc.) and mollusks (limpets, chitons, snails, abalone and clams).

Adult lobsters are omnivorous and consume algae, snails, mussels, sea urchins, clams and fish. Cannibalism has been reported on injured or newly molted lobsters (Barsky 2001). Lobsters are prey for sheephead, sculpin, kelp bass, octopuses, California moray eels, horn sharks, leopard sharks, rockfishes and giant sea bass (Barsky 2001).

page 30 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Some analyses of the food web and biomass flows (Morales-Zarate and Lluch Cota 2011) suggest that the red lobster is a ‘key’ species in the rocky ecosystems of the central Pacific area of the BCP because it interacts with many species, has a generalist diet and preys on a wide variety of invertebrates, and many predator species feed on lobsters.

The team believes that direct extraction of the target resource is the only significant effect the fishery has on the ecosystem. The impact of lobster extraction on ecosystem structure and function, as well as the composition of the community and the biodiversity, is considered low, based on the known catch rate. The total red lobster catch for the 2014-2015 season was 1,179,162 tons, as mentioned in the background for Principle 1 (Section 3.1), since the 2012/13 season total catch and effort show a decline. Estimates for the status of the stock indicate a stable abundance trend and that the current catch rate roughly 45% of estimated biomass at MSY is left unharvested by the fishery. The conclusion from the second re- assessment is maintained, that this fishery is unlikely to affect the status of the retained, bycatch or ETP species, habitat or functioning and structure of the ecosystem.

Condition 2.5.3 was imposed in relation to the establishment of a bycatch monitoring system in condition 2.2.3. The condition was closed in the second audit because information was being provided through the logbook system. In the re-assessment the contribution of additional information to identify the impact of the fishery on bycatch species, such as cormorants and sharks, and an understanding of their function in the ecosystem is recommended by the audit team.

3.3 Principle 3 – Management and Regulation

There are currently no open conditions associated to Principle 3. During the onsite audit the audit team was informed that the Fisheries Management Plan (FMP) continues at the draft stage and has not been published. The lack of a formal and available FMP may affect several Scoring Issues, probably in all three Principles, but main problems may be encountered in fishery-specific aspects of Principle 3 including long term objectives (PI 3.2.1), decision making process (PI 3.2.2), research plans (PI 3.2.4). There needs to be in place a decision-making process that results in measures and strategies to achieve the fishery specific objectives. In particular PI 3.2.1 (b) requires at the SG80 level that the “Decision-making process must respond to serious and other important issues identified in relevant research, monitoring, evaluation and consultation […]” (MSC CR V 1.3). During previous certification cycles elements that constitute the decision-making process were identified across different documents; the , the NOM and the CNP and also mechanisms for inter-institutional coordination and consultation including the Comité Técnico Consultivo de la Pesquería de Langosta del Pacífico (Technical consulting committee for the Pacific lobster fishery) and the Subcomité Estatal de Langosta de Baja California Sur (Baja California Sur state lobster subcommittee. These elements provide management tools that can be used to implement control rules (limited entry policy and the minimum legal size ruling). However, there is limited evidence of how these tools respond to fishery-specific issues (research, monitoring, evaluation and consultation).

If the Baja California Red Lobster fishery has selected a target reference point that is MSY related an explicit control rule is required to regulate the fishery. Failure to meet target indicators established by the

page 31 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015 fisheries management, such as a reference points, require responsive mechanisms that would translate a decision to reduce fishing mortality to an actual reduction in effort such as how many traps need to be removed from operation and how that will be accomplished. It is expected that the Fisheries Management Plan would be the instrument to aggregate tools and mechanisms to determine how and when the decision making process will operate. It is also expected that this decision making process will be part of a harvest strategy that includes explicit target and limit reference points as defined in Performance Indicator 1.1.2 and harvest control rules as defined in PI 1.2.2. We are recommending for future audits to observe if the FMP has been made public and evaluate if it meets the requirements of PI 3.2.2 as stated above. If the FMP continues to be unpublished this could affect scoring of several PIs (1.1.2, 1.2.1, 1.2.2 and 3.2.2).

4 Status of Previously Raised Conditions

PI 1.2.4 There is an adequate assessment of the stock status Scoring Issue SG 60 SG 80 SG 100 a The assessment is The assessment is appropriate for the stock appropriate for the stock and for the harvest and for the harvest control rule. control rule and takes into account the major features relevant to the biology of the species and the nature of the fishery. Met? (Y/N) (Y/N) (Y/N) b The assessment estimates

stock status relative to reference points.

Guidepost Met? (Y/N)

c The assessment identifies The assessment takes The assessment takes into account major sources of uncertainty into account. uncertainty and is evaluating stock uncertainty. status relative to reference points in a probabilistic way.

Guidepost Met? Y Y N d The assessment has been tested

and shown to be robust. Alternative hypotheses and assessment approaches have been

Guidepost rigorously explored. Met? N

page 32 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

PI 1.2.4 There is an adequate assessment of the stock status

e The assessment of stock The assessment has been status is subject to peer internally and externally peer review. reviewed.

Guidepost Met? Y Y

page 33 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

PI 1.2.4 There is an adequate assessment of the stock status During the last ten years, the fishery has been assessed using several models (Vega et al. 2000; Vega 2003; Vega 2006) in order to obtain stronger recommendations in line with suggestions in the literature (eg. Hilborn and Walters 1992; Hilborn and Mangel 1997). However, during the last stock assessment, Vega et al. (2010) only used a Biomass Dynamic Model that allowed them to evaluate the present status of the stock (as B current biomass, F current fishing mortality, or f current exploitation rate) relative to the reference points (BMSY, FMSY, and fMSY). Although this approach has had a long history in fisheries stock assessment, and is fairly straight forward to apply, it generally ignores the impact of stochasticity in the population dynamics (eg. recruitment fluctuations) (Punt 2010). During the past assessments of this fishery, efforts to understand the effects of recruitment dynamics were undertaken by applying the modified Leslie-DeLury model (Vega 2006) or the delayed impact of the recruitment in the biomass using the LRSG model (Hilborn and Mangel, 1997; Vega et al. 2000; Vega 2006) and their lack of use in the latest assessment are considered here for the scoring. It is highly recommended that a model or models that better explain the biology of the resource be systematically used and updated. Also, methods that represent uncertainty and that allow the estimation of confidence intervals of the estimated parameters is highly recommended to be developed and applied. It is highly recommended that in order to quantify uncertainties, an effort to include information from other fishing areas or fisheries such as the one in California, USA be considered. Finally, during the reviewing process for this certification, the CB did not find any information that allowed the assessment team to verify whether stock assessments are peer reviewed, either internally or externally. Peer review of the assessment is highly also recommended. Until now, INAPESCA has carried out the stock assessment based on the information of the Cooperatives located in the central part of the peninsula (Vega et al. 2000, Vega 2003, Vega 2006, Vega et al. 2010), however, the FEDECOOP intends to include for this certification the Abuloneros y Langosteros (AyL) cooperative, based in Isla Guadalupe. The fishing effort (number of traps) of this cooperative represents only 2% (n=320) of the total effort from the cooperatives that constitute the Unit of Certification (Table 2), with a mean catch of 7.2 t in the last five seasons, representing the 0.5% of the mean total catch (n=1,378 t) of all cooperatives of the Unit of Certification. Even the catch and effort of AyL cooperative are low, they should be included in future stock assessments. We recognize that almost no sublegal size lobster is landed (based on Vega et al. 2010), however, post-release mortality has not been evaluated and assumed to be low. During the evaluation process we found some information reporting that in one specific fishing area “the bycatch of sublegal lobster is substantially high (86%) which, depending on the post-release mortality, could be a concern” (Shester Justification 2008). In order to evaluate the degree of concern of this mortality, the assessment of the post-release mortality is highly recommended in incorporated into the stock

Original assessment process. References Vega et al. (2000), Vega (2003), Vega (2006), Vega et al. (2010), Hilborn and Walters (1992), Hilborn and Mangel (1997), Shester (2008), Punt (2010)

page 34 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

PI 1.2.4 There is an adequate assessment of the stock status

ORIGINAL OVERALL PERFORMANCE INDICATOR SCORE: 75

PERFORMANCE INDICATOR SCORE AFTER SURVEILLANCE AUDIT 80

CONDITION NUMBER (if relevant):

page 35 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

PI 1.2.4 There is an adequate assessment of the stock status CONDITION 1.2.4 By the first annual surveillance audit the client shall provide evidence that the stock assessment has been modified to be more appropriate for the stock. The client shall consider using a model that accurately represents the biology of the resources and which better represents the uncertainties in the parameters estimations and includes the Guadalupe Island fishery information. In addition provide some evidence to the CB that the stock assessment has been peer reviewed either internally or externally. By the second surveillance audit, provide some evidences that the post- release mortality of the sublegal size California spiny lobster has been assessed and incorporated in the assessment process. Recommendations 2015 (5)

1) To either account for the variability in growth, or use a more versatile platform that integrates the error associated to growth or model lengths directly.

2) Use the analytical platform of choice to investigate: i) sensitivity of the model to alternative assumptions about parameters or specific model components (alternative forms of recruitment, different types of selectivity, etc.); ii) the dynamic structure of age/size in time and its implications, particularly to determine the extent of impact of fishing on the population compared to environmental forcing; iii) the potential effect of modifying gear selectivity to reduce fishing pressure on older animals.

3) Develop a research program to investigate the magnitude of post-release mortality of all lobsters caught and released in fishing operations, not only those that were injured.

4) Request peer reviewers to conduct and produce a more thorough discussions about the stock assessment analytical structure, results and areas of improvement.

5) Describe all methods used in the stock assessment with as much detail possible, including justification of assumptions, data weighting, penalties, priors, etc. Include data tables with all information included in reported analyses. All work must be able to be replicated from methodological descriptions and data provided.

Status of Condition 1.2.4: Closed

CLIENT ACTION PLAN Client will request from INAPESCA to perform stock assessment using a size-structured model including uncertainty estimations for its parameters. Information from the Guadalupe Island fishery will also be requested from INAPESCA to be incorporated in the stock assessment process. Information of the sublegal lobster caught and released during the fishing operations will be recorded in the fishing logbooks by the Client including any mortality, and the Client will request to INAPESCA that post-release moralities are evaluated and incorporated in the stock assessment process.

page 36 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

PROGRESS AND STATUS AFTER THE SURVEILLANCE AUDIT: Progress on Condition: During the 4th Surveillance the client submitted a report of stock assessment that included the usual biomass dynamics model which incorporated probability distributions around the parameters, including MSY. The assessment also included analysis using the age based ADAPT platform which is an implementation of a tuned VPA that allows for computation of confidence intervals around the estimated biomass. All these inclusions in the stock assessment respond to the requirements for an improved structured model and incorporate uncertainty, this previous requirement applies to a length based model and there is still a necessity to address this in future assessments. Therefore, a recommendation is made to either account for the variability in growth or to use a more versatile platform that integrates the error associated with growth or model lengths directly.

Regardless if the ADAPT platform continues to be used or other approaches are considered, several aspects need to be improved to make the results of the assessment more reliable. Assumptions such as, but not restricted to, natural mortality, terminal F or selectivity need to be tested for sensitivity of the model in use against alternative assumptions. When priors are used these need to be justified, even if only informal accounts are considered. Platforms such as ADAPT and Stock Synthesis have the ability to produce graphic descriptions of the dynamic structure of age/length which can be important to understand age/size class strength and correlate it with environmental variability. Some of these platforms also allow investigating the effect of controls on size such as minimum length regulations or gear selectivity. It is recommended to consider the full potential of the analytical platform selected to investigate all effects described in this paragraph.

Information was presented on the population size structure in Isla Guadalupe vs size in the catch for the overall unit of assessment, showing that the commercial fishery is removing large animals and that a large proportion of spawners are not being removed. based on the following Requirement for Isla Guadalupe were satisfactorily meet when considering the following: i) The fraction of the population around Isla Guadalupe is associated to a different management unit than that of the central region of the Baja California Peninsula; ii) The catch level is very small; iii) Details about the biological source of the recruits are still being investigated; iv) Appropriate analysis of the catch from Isla Guadalupe requires using a platform that allows for modeling of meta-populations were some parameters are stock specific and others are shared, This is a level of complexity that the research program cannot reach in the short term and is considered to impractical for such a small catch. The client will be removing Isla Guadalupe from the Unit of Assessment in the next Certification cycle. This situation may be reverted if in the future meta-population analysis is conducted to integrate the northern and southern lobster fisheries, which are currently considered part of separate stocks and are not currently included in the unit of assessment..

During massive samplings information was collected on injured or dead lobsters to estimate the impact of this mortality source on the population. The main concern in the original condition inquiries on the potential effect of the catch of sub-legal sized lobster on all post-release mortality, not only of those that are released injured. This requires a different approach and is still a pending concern that needs to be addressed. A recommendation is added to expand the investigations on this subject.

The SCS team received two reports of external reviews of the stock assessment. Overall, the reviewers agree that the stock assessment has sufficient elements to demonstrate that the fishery

page 37 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

PI 1.2.4 There is an adequate assessment of the stock status operates sustainably and that the output of the analysis is useful to make management decisions. Although there are some comments regarding the methods and general content, we recommend the client to request reviewers to conduct and produce more detailed and extended reports with discussions about model shortcomings, issues related to assumptions, larger scope of improvements and so forth.

Another recommendation is made to improve report writing to include complete and detailed description of all methods used. If a method considered to be well known whenever possiblereference and equations should be included. When there is a amount of equations these should be included as part of an appendix. For population and fishery dynamics models equations describing the observational and statistical models must be clearly inserted and described. Other non-evident processes and equations need to be also presented and clearly described, this includes penalties, analytic solutions to parameters, etc. Details of model structure and implementation can be included in an appendix at the end of the report.

Component Retained Species

The fishery does not pose a risk of serious or irreversible harm to the retained species PI 2.1.1 and does not hinder recovery of depleted retained species. Scoring SG 60 SG 80 SG 100 Issue a. Main retained species are Main retained species There is a high degree of likely to be within are highly likely to be certainty that retained species biologically based limits within biologically are within biologically based or if outside the limits based limits, or if limits. there are measures in outside the limits there place that are expected is a partial strategy of to ensure that the fishery demonstrably effective does not hinder recovery management measures and rebuilding of the in place such that the depleted species. fishery does not hinder If the status is poorly recovery and known there are rebuilding. measures or practices in place that are expected to result in the fishery not

causing the retained species to be outside biologically based limits

Guidepost or hindering recovery. Met? Y Y Not Scored

page 38 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

The fishery does not pose a risk of serious or irreversible harm to the retained species PI 2.1.1 and does not hinder recovery of depleted retained species. b. Target reference points are

defined and retained species are at or fluctuating around their target reference points.

Guidepost Met? Not Scored This justifications was placed under PI 2.2.1 in the original assessment (2010). Text has been extracted related to “retained species” and bait. Consideration of bait species was highly weighted in assessment of this fishery. Lobster traps are baited each time they are checked and the daily biomass of bait exceeds the lobster catch throughout the fishery. Approximately 2.3 to 3.5 kg of bait is used per kg of landed lobster catch, which equates to total use of approximately 4,500 to 5,000 t of bait in the whole area of assessment per season (M. Ramade pers. com). Oily fishes such as sardines, mackerel and bonito are mostly used for bait and purchased in Ensenada, Mexico, and therefore derive from commercial and managed fishery (see invoice sample Appendix 1). Stock assessments are conducted for these species (Nevárez-Martínez et al. 1993a, b, 1999). Therefore it is highly likely that these species are within the biologically based limits based on reference points.

However, according to Shester (2008), in Bahia Tortugas for example, 1/3 of the bait that is used is mixed finfish species that are caught locally. This is likely to vary between areas and month in the fishing season. The main species that are caught

locally for bait including barred sand bass (Paralabrax nebulifer) and ocean whitefish (Caulolatilus princeps). None of these species are currently managed or assessed since there is no commercial fishery for these species. Therefore it is difficult to determine the stock status of these species with certainty. Further studies are needed to monitor and record the amount and species composition of locally caught bait species for the whole fishing area. Considering that the status of 1/3 of the bait species is poorly known this Performance Indicator was scored below 80 overall.

Original Justification Original Nevárez-Martínez et al. (1993a, b), 1999, Shester (2008) References

ORIGINAL OVERALL PERFORMANCE INDICATOR SCORE (for 2.2.1): 70

PERFORMANCE INDICATOR SCORE AFTER SURVEILLANCE AUDIT (2014) 80

CONDITION NUMBER (if relevant): 2.2.1 CONDITION 2.2.1: By the second surveillance audit, provide some details to the CB about the amount and origin of bait species used in the fishery. By the third annual surveillance provide some evidence to the CB that the bait species that are caught locally are highly likely to be within biologically based limits.

Recommendations 2014 (2): To present information on the size distribution of sardines caught locally to assure that these

page 39 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

The fishery does not pose a risk of serious or irreversible harm to the retained species PI 2.1.1 and does not hinder recovery of depleted retained species. conform with existing minimum size limits in national regulations.

To present information on the contribution of the lobster fishery to the total catch of Whitefish and Sea Bass in the areas where they are extracted.

Recommendations 2015 (2):  Provide volume data at the species level for the “Whitefish/fish” bait category and other species used as bait and indicate what proportion is sourced from retained species within the unit of assessment.  Provide catch data (volume) for blue and green lobsters as retained species in the evaluation unit

page 40 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

The fishery does not pose a risk of serious or irreversible harm to the retained species PI 2.1.1 and does not hinder recovery of depleted retained species. CLIENT ACTION PLAN The client will introduce fishing logbooks, the source and quantity of bait used during the fishing operations will be recorded, and summarized in a monthly and seasonal manner. – FEDECOOP – March 2012

The client will continue to follow the fishing specifications in the Carta Nacional Pesquera for the species used as bait and adopt and respect the official measures provided by the CONAPESCA. – FEDECOOP – March 2013

page 41 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

The fishery does not pose a risk of serious or irreversible harm to the retained species PI 2.1.1 and does not hinder recovery of depleted retained species. PROGRESS AND STATUS AFTER THE SURVEILLANCE AUDIT Closed – 2014 third Surveillance.

Prior to the start of the 2012/13 season, a specific reporting form (Registro de Producción Mensual de Carnada- Pesquería de Langosta) was developed to capture details of bait used during each month of the fishing season (September –February). The assessment team received a report that provided details on species groups (e.g. sardine) and amounts of bait used by each COOP during the fishing seasons 2013/14 and 2014/15.

Starting on 2012/13 season the amount of bait used by species or group of species was reported. The main species used in the fishery are Sardine (S. sagax) accounting for 96% of all bait used during 2014/15 season. The origin of 45% of the volume of Sardine is local and the rest 55% is purchased in Ensenada from different sources.Overall this catch represents 6% of the total estimated catch (60,000 mt) for the whole sardine fishery in the west coast of Baja California (Hill et al. 2011; Enciso and Cotero 2014). The mean of an estimated distribution for this sardine stock maximum sustainable yield is near 60,000 mt with an approximated 95% CI of 47,000 to 76,000 mt (Enciso and Cotero 2014b). This implies that an increment of 6% in the catch puts the exploitation level slightly above the estimated mean and nowhere near the upper CI bound. Under these conditions, it was considered unlikely that the sardine catch for bait could have an effect on the overall sardine stock. During the onsite visit for the third surveillance, it was noted that the sardine obtained locally may be composed of small fish below the legal size limit for Pacific sardines. This was identified as a potential area of concern. The size frequency of Sardine caught locally was analyzed in the report of the season 2014/15 and is above 150 mm in length as required by NOM-003-PESC-1993 as minimum size limits. The team concluded that information on sardine catch for bait is reliable and catch of other species for bait are considered to be low enough to represent a risk to their populations and Sardine caught locally are highly likely to be within biologically based limits.

The recommendation to present information on the contribution of the lobster fishery to the total catch of Whitefish and Sea Bass in the areas where they are extracted was not fully addressed. During the fourth surveillance the audit team was presented in unpublished data for the 2014/15 season on organisms at the species level for the “Whitefish/Finfish” category, however, information is recorded on number of organisms rather than weight, difficulting estimating the contribution of the lobster fishery to the catch of finfish in the area.

The condition was closed in the 3rd Surveillance and monitoring of bait species has continued during the 2014/15 fishing season. The PI scores at 80

page 42 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

There is a strategy in place for managing retained species that is designed to ensure the fishery does not pose a PI 2.1.2 risk of serious or irreversible harm to retained species.

Scoring SG 60 SG 80 SG 100 Issue a. There are measures in There is a partial There is a strategy in place for place, if necessary, that strategy in place, if managing retained species. are expected to maintain necessary that is the main retained species expected to maintain at levels which are highly the main retained likely to be within species at levels which biologically based limits, are highly likely to be or to ensure the fishery within biologically does not hinder their based limits, or to

recovery and rebuilding. ensure the fishery does not hinder their recovery and

Guidepost rebuilding. Met? Y Y Not Scored b. The measures are There is some Testing supports high considered likely to work, objective basis for confidence that the strategy based on plausible confidence that the will work, based on argument (eg, general partial strategy will information directly about the experience, theory or work, based on some fishery and/or species comparison with similar information directly involved.

fisheries/species). about the fishery and/or species involved.

Guidepost Met? Y Y Not Scored c. There is some evidence There is clear evidence that the that the partial strategy is being implemented

strategy is being successfully, and intended implemented changes are occurring. successfully.

Guidepost Met? Y Not Scored

d. There is some evidence that the strategy is achieving its overall objective.

Guidepost

page 43 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

There is a strategy in place for managing retained species that is designed to ensure the fishery does not pose a PI 2.1.2 risk of serious or irreversible harm to retained species.

Met? Not Scored This justifications is extracted from PI 2.2.2 in the original full assessment (2010). There is also a partial strategy in place to ensure that the majority of bait used (2/3) is restricted to fish species such as sardines, mackerel and bonito that are sourced from

managed fisheries and purchased in Ensenada, Mexico. There is evidence that this partial strategy is working (see copy of invoices Appendix 1). However up to 1/3 of all bait used may be caught locally and is taken from unmanaged .

Justification References Shester (2008) ORIGINAL OVERALL PERFORMANCE INDICATOR SCORE: 70

PERFORMANCE INDICATOR SCORE AFTER SURVEILLANCE AUDIT (2014) 80

ORIGINAL CONDITION NUMBER (if relevant): 2.2.2

page 44 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

There is a strategy in place for managing retained species that is designed to ensure the fishery does not pose a PI 2.1.2 risk of serious or irreversible harm to retained species.

CONDITION 2.2.2*: By the third surveillance audit, the client shall provide evidence that main bycatch species including bait species used in the fishery are highly likely to be within biologically based limits, or if outside such limits there develop a partial strategy of demonstrably effective mitigation measures and provide some evidence to the CB that the strategy has been implemented successfully.

* *Note that at the time of assessment, bait was scored under the bycatch section of the FAM V2.1 certification requirements (performance indicators 2.2.X). Under more current versions of the standard, bait is scored under PIs for retained species (2.1.X). Based on the original assessment, we have clearly separated both issues, but retained the numbers associated with the scoring system used for the original assessment. CLIENT ACTION PLAN Client will adopt and respect the official measures provided for the administration and management of the species that are used as bait in the lobster fishery. – FEDECOOP – March 2013

Client will work closely with INAPESCA and follow the trend of the population of the bait species. A comparison will be made between the amount of bait used by species (data from new logbooks – see 2.2.3 and 2.2.1) with the total catch of the species in the region - with INAPESCA – March 2014

page 45 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

There is a strategy in place for managing retained species that is designed to ensure the fishery does not pose a PI 2.1.2 risk of serious or irreversible harm to retained species.

PROGRESS AND STATUS AFTER THE SURVEILLANCE AUDIT Closed – 2014 third Surveillance The assessment team received a report that provided details on species groups and amounts of bait used by each Co-­­op during the fishing season. As discussed in closing Condition 2.2.1, catches of both Monterrey sardine and all other species taken for bait is not considered to represent a risk to their populations. The Sardine used as bait respect the official measures (see 2.1.1) and a comparison has been made between the amount of Sardine uses as bait with the total catch in the west coast of BC. No specific strategy is therefore required if bait species are considered to be fished within biologically based limits.

Progress on Condition (bycatch-retained): Current logbook forms are used to report bycatch and other interactions in the fishery (Bitácora de la Pesquería de Langosta INAPESCA 2006). Considering the scale, intensity and nature of the fishery (pot fishery) this action is considered appropriate to collect information on bycatch species. Data from 2012/2013, 2013/2014, 2014/13 with strong overall sampling of total trap hauls (<50% in the most recent season) indicates that approximately 2.4% (in numbers) of total landings is comprised of non-­­target catch. Finfish (composite of species) and crabs are the largest groups of non-­­target catch by number, comprising <2% of total landings apiece. Therefore it is unlikely that any individual species is being taken as non-­­target catch at a level that poses a threat of serious or irreversible harm at the population level, and none are considered main retained species for the purposes of MSC assessment. The two sharks species identified could be considered as main retained based on the vulnerability of their life history, but are reported to be released alive, and are also captured in relatively small numbers (n=5867 in the 2014/15 season). Data presented during the fourth surveillance was at the species level for bycatch. The audit team recommends that data continues to be collected at the species level for bycatch species in order to identify changes in trends that might increase risk for bycatch species.

The PI scored 80 and the condition was closed in 2014.

Component Bycatch Species

Information on the nature and amount of bycatch is adequate to determine the risk posed by the fishery and the PI 2.2.3 effectiveness of the strategy to manage bycatch.

Scoring Issue SG 60 SG 80 SG 100

page 46 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015 a. Qualitative information Qualitative information Accurate and verifiable is available on the and some quantitative information is available on the amount of main information are amount of all bycatch and the bycatch species available on the consequences for the status of

affected by the fishery. amount of main affected populations. bycatch species affected by the fishery.

Guidepost Met? Y Y Not Scored b. Information is adequate Information is Information is sufficient to to broadly understand sufficient to estimate quantitatively estimate outcome status with outcome status with outcome status with respect to respect to biologically respect to biologically biologically based limits with a based limits. based limits. high degree of certainty.

Guidepost Met? c. Information is adequate Information is Information is adequate to to support measures to adequate to support a support a comprehensive manage bycatch. partial strategy to strategy to manage bycatch, manage main bycatch and evaluate with a high species. degree of certainty whether a strategy is achieving its objective.

Guidepost Met? Y Not Scored d. Sufficient data Monitoring of bycatch data is continue to be conducted in sufficient detail collected to detect any to assess ongoing mortalities increase in risk to main to all bycatch species. bycatch species (e.g. due to changes in the outcome indicator scores or the operation

of the fishery or the effectiveness of the strategy).

Guidepost

page 47 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

Met? Y Y Not Scored

The amount of the main bycatch species affected by the fishery are known and stated under PI 2.2.1 (Shester 2008). There is also qualitative and some quantitative information available on the amount and origin of bait used in the fishery. Overall the information is adequate to broadly understand the status of these species and is adequate to support a partial strategy to manage the main bycatch species. However data is not continuously collected on main bycatch and quantitative

information on bait species is only available for a certain area of the fishery (Shester 2008). Therefore the fishery meets 2 of 4 elements of the guidepost 80 resulting in a score of 70.

Justification References Shester (2008)

ORIGINAL OVERALL PERFORMANCE INDICATOR SCORE: 70

PERFORMANCE INDICATOR SCORE AFTER SURVEILLANCE AUDIT (2014) 80

CONDITION NUMBER (if relevant):

CONDITION 2.2.3:

By the second surveillance audit, the client shall establish a scientifically defensible monitoring and reporting system for bycatch, including the amount and species that are used for bait, in the Baja California Spiny Lobster Fishery.

Recommendation (2014):

Logbook information record non-­­target catch by individual species and record whether such take is retained, discarded (returned to the water), or released alive.

Recommendation (2015):

 Provide some sampling system to verify the accuracy of the data collected in logbooks and to collect information at species level and destination for bycatch.

 Demonstrate improvements in monitoring plan to standardize effort and quality of data collected across the different fishing fields/cooperatives.

page 48 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

CLIENT ACTION PLAN The client will record the source and quantity of bait used in the lobster fishery in logbooks specifically designed for this purpose and summarizes the results make monthly and by fishing season PROGRESS AND STATUS AFTER THE SURVEILLANCE AUDIT Closed – 2013 Second Surveillance After the client fulfilled the action plan set in 2011 to record source and quantity of bait the condition was closed at the Second Surveillance. During the Third Surveillance the Team noted that reporting format was weak and recommended that logbook information record non-­­target catch by individual species and record whether such take is retained, discarded (returned to the water), or released alive. The team cautioned the client that for species that are caught in large numbers, and for reassessment under Version 2.0, it is likely to be necessary to present estimates of overall catches by species relative to population estimates of non-­­target catch in order for the team to appropriately score species under Principle 2. It is also in the fishery’s interest to demonstrate where species are released alive, such that non-­­ target catch is not overestimated, as may be the case under the current recording system. During the fourth surveillance the team was able to verify that the monitoring and reporting system for bycatch established for the fishery continues to work. Logbook forms are used to report bycatch and other interactions in the fishery (Bitácora de la Pesquería de Langosta INAPESCA 2006). A report analyzing the bycatch caught with strong overall sampling of observed traps (56% in the most recent season) has been provided to the assessment team during 2013/14 and 2014/15 season with information of non-target species. Records are by species and group of species and by number of individuals. The client presented date for all fish species, providing data at the species level for all bycatch. However, the recommendation was not fully addressed as the fate of catch is not recorded and the audit team was unable to determine the amount of retained species that are used as baitClient and technician of the Coops reported verbally that some species are retained (i.e. Sand bass), discarded (i.e cormorants that expired before reaching the boat) or released alive (i.e. two species of sharks).

The PI scored 80. For a higher scoring in a potential re-assessment monitoring of bycatch data should be conducted in sufficient detail to assess ongoing mortalities to all bycatch species, and particularly to species considered vulnerable such that sharks or top predators (cormorants). It is also in the fishery’s interest to demonstrate where species are released alive, such that non- target catch is not overestimated, as may be the case under the current recording system, thus the Information is adequate to support a comprehensive strategy to manage bycatch.

Ecosystem component

page 49 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

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

Scoring SG 60 SG 80 SG 100 Issue a. Information is adequate to Information is adequate identify the key elements to broadly understand the of the ecosystem (e.g. functions of the key trophic structure and elements of the function, community ecosystem. composition, productivity pattern and biodiversity). Main impacts of the fishery on these key ecosystem elements can

be inferred from existing information, but may not have been investigated in

Guidepost detail. Met? Y Y 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 can ecosystem elements can ecosystem elements can be be inferred from existing be inferred from existing inferred from existing information, but have not information, and some information, and have been

been investigated in detail. have not been investigated in detail. investigated in detail are known.

Guidepost Met? Y Y Not Scored c. The impacts of the fishery The main functions of the on target, Bycatch, Retained Components (i.e. target, and ETP species and Bycatch, Retained and Habitats are identified and ETP species and Habitats) the main functions of these

in the ecosystem are Components in the known. ecosystem are understood.

Guidepost Met? Y Not Scored

page 50 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015 d. Sufficient information is Sufficient information is available on the impacts available on the impacts of of the fishery on these the fishery on the Components to allow Components and elements

some of the main to allow the main consequences for the consequences for the ecosystem to be inferred. ecosystem to be inferred.

Guidepost Met? Y Not Scored e. Sufficient data continue Information is sufficient to to be collected to detect support the development of any increase in risk level strategies to manage (e.g. due to changes in ecosystem impacts. the outcome indicator scores or the operation of

the fishery or the effectiveness of the measures).

Guidepost Met? Y Not Scored

There are appropriate studies in the UK (Eno et al. 2001) and in the local area of the fishery, that show that trap fisheries have minor impacts on the ecosystem (Shester 2008). Traps are among the least impacting gear on both the habitat and other species. As stated previously, the modelling of the rocky coastal ecosystem, suggests that even for exploited lobster populations, predation and competition are stronger stresses than current fishing effort (Morales-Zarate et al. submitted). Without sufficient

understanding of the total mortality of Cormorants taken as bycatch across the fishery, and information about the status of the population, (see PI 2.2.1) the overall severity cannot be determined.

Justification Reference Eno et al. (2001), Shester (2008). s ORIGINAL OVERALL PERFORMANCE INDICATOR SCORE: 70

PERFORMANCE INDICATOR SCORE AFTER SURVEILLANCE AUDIT (2014) 80

CONDITION NUMBER (if relevant):

CONDITION 2.5.3

page 51 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

By the second surveillance audit, provide information on the impact of the fishery on ecosystem components like the Cormorants taken as bycatch in the Baja California Spiny Lobster Fishery. This could include data from the reporting system for bycatch (see condition 2.2.3).

Recommendation 2015 (1):

Present additional information to identify the impact of the fishery on bycatch species, such as cormorants and sharks, to help understand their function in the ecosystem.

CLIENT ACTION PLAN

Client will record the bycatch in the fishing logbook including cormorants, and produce monthly and seasonal reports

PROGRESS AND STATUS AFTER THE SURVEILLANCE AUDIT Closed – 2013 Second Surveillance As detailed under 2.1.1 and 2.1.2 above a specific form has been introduced for bait species. Information about bycatch species is collected on the existing logbook form and recorded in the “observation” column. Reports were provided for both summarizing the findings for the 2012/13, 2013/14 and 2014/15 fishing seasons. The monitoring and reporting have continued. This condition was closed at the Second Surveillances and the PI re-scored at 80.

Client and technician of the Coops reported verbally that some species are retained (i.e. Sand bass), discarded (i.e cormorants that expired before reaching the boat) or released alive (i.e. two species of sharks). A Recommendation was issued that logbook information record non-­­target catch by individual species and record whether such take is retained, discarded (returned to the water), or released alive. This recommendation has not been fulfilled and it might turn into a potential condition in a future re-assessment.

5 Conclusion

This is the 4th Annual Surveillance Report prepared by SCS Global Services to meet the requirements of the MSC for annual audits of certified fisheries.

It is SCS’s view that the Baja California Lobster fishery continues to meet the standards of the MSC and complies with the ‘Requirements for Continued Certification’. SCS recommends the continued use of the MSC certificate through to the end of the current Certification cycle. All conditions presented in the

page 52 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

2011 Certification Report are closed at the end of the 4th Surveillance Audit. Several recommendations have been added to be considered in the next Re-Assessment process. Some of these recommendations relate to PI 1.2.4; however, a recommendation related to PI 3.2.2 may result in revision of several other PIs in Principle 1 (1.1.2, 1.2.1, 1.2.2). Recommendations related to Principle 2 will continue to be observed for at least two more surveillance audits in the next Certification cycle.

An outcome of the 3rd surveillance audit indicated that emphasis should be made on corrective actions from the original assessment related to 1.2.4 which is considered, for a second time during the certificate, to be behind target. The two main actions to be observed were to improve on the stock assessment methodology and to have the report of the stock assessment subject to peer review. The client presented a stock assessment report that satisfied the requirements of all SIs at SG80 and two reports of independent reviewers that satisfy the requirement of the SIe at SG80 of PI 1.2.4. The last outstanding condition can therefore be closed and the fishery can complete the current Certification cycle in compliance of the requirements for Continued Certification

6 Use of the MSC blue eco-label

Fisheries that meet the standards of the MSC for a sustainable and well managed fishery are eligible to use the MSC blue eco-label on products originating from the fishery. The fishery does not use the eco- label. A logo licensing agreement with the logo licensing branch of the MSC, the MSCI is not required.

page 53 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

References

Barsky, K.C. (2001) California spiny lobster. In: Leet, W.S., Dewees, W.S., Klingbeil, R. & Larson E.J. (eds.) California‘s Living Marine Resources: a status report. California Department of Fish and Games, CA, USA. 98-100.

Carlisle, A.B. 2015. Heterodontus francisci. The IUCN Red List of Threatened Species 2015: e.T39333A80671300. http://dx.doi.org/10.2305/IUCN.UK.2015-4.RLTS.T39333A80671300.en. Downloaded on 21 January 2016

DOF, Diario Oficial de la Federación. 2007. Norma Oficial Mexicana NOM-029-PESC-2006, Pesca responsable de tiburónes y rayas. Especificaciones para su aprovechamiento. Secretaría de Agricultura, Ganaderia, Desarrollo Rural, Pesca y Alimentación (SAGARPA, México), 14 de febrero de 2007. Primera sección, pp. 60–102.

DOF, Diario Oficial de la Federación. 2010. NORMA Oficial Mexicana NOM-059-SEMARNAT-2010, Protección ambiental-Especies nativas de México de flora y fauna silvestres-Categorías de riesgo y especificaciones para su inclusión, exclusión o cambio-Lista de especies en riesgo. Secretaría de Medio Ambiente y Recursos Naturales (SEMARNAT, México), 30 de diciembre de 2010. Segunda sección. Enciso, C. and C.E. Cotero. 2014. Análisis de las capturas y longitudes de la pesquería de sardina Monterrey (Sardinops caeruleus) en la costa occidental de Baja California durante la temporada 2013. XXI Taller de Pelágicos Menores. INAPESCA. Ensenada, BC. Junio 2014.

Enciso, C. and C.E. Cotero. 2014b. Evaluación de la pesquería de sardina Monterrey (Sardinops caeruleus) en la costa occidental de Baja California a partir de datos de captura. XXI Taller de Pelágicos Menores. INAPESCA. Ensenada, BC. Junio 2014.

Eno, N.C., MacDonald, D.S., Kinnear, J.A.M., Amos, S.C., Chapman, C.J., Robin A.C., Bunker, F. St P.D. & Munro C. (2001) Effects of crustacean traps on benthic fauna. ICES Journal of Marine Science 58:11-20.

Hill K. T., Crone P.R., Lo N.C.H., Beverly J., Macewicz J., Dorval E., Mac Daniel J.D., and Gu Y. 2011. Assessment of the Pacific sardine resource in 2011 for U.S. management in 2012. NOAA-TM- NMF-SWFSC-487. 212 PP.

Morales-Zarate, M.V., Lluch-Cota, S.E., Serviere-Zaragoza, E. (submitted). Modeling an exploited rocky costal ecosystem: Bahia Tortugas, Mexico.

Ramade-Villanueva, M., D. Romero-Arce, A. Espinoza-Montes, J.C. Bonilla-Gutierrez, R. Garcia-Arce, C. Salinas-Ivan, R. Luna-Villalobos, A. Murillo-Cruz, D. Aguilar-Osuna and E. Enriquez-Gonzalez.

page 54 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

2014. Reporte de la Temporada Langostera 2013/14. Federacion Regional de Sociedades Cooperativas de la Industria Pesquera “Baja California” F.C.L. 7 pp.

Ramade-Villanueva, M., D. Romero-Arce, A. Espinoza-Montes, J.C. Bonilla-Gutierrez, R. Garcia-Arce, C. Salinas-Ivan, R. Luna-Villalobos, A. Murillo-Cruz, D. Aguilar-Osuna and E. Enriquez-Gonzalez. 2015. Reporte de la Temporada Langostera 2014/15. Federacion Regional de Sociedades Cooperativas de la Industria Pesquera “Baja California” F.C.L. 11 pp.

Shester, G.G. (2008) Sustainability in small-scale fisheries: an analysis of the ecosystem impacts, fishing behavior and spatial management using participatory research methods. Doctor of Philosophy Degree Thesis. Stanford University, Stanford, CA, USA. September, 2008. 225 pp.

Vega, A., J. Castro, A. Vega y R. Sánchez. 2014. Plan de manejo pesquero para las langostas espinosas (Panulirus sp) de la Penísula de Baja California. Insituto Nacional de Pesca. Direccion General adjunta de investigación pesquera en el Pacífico. Centro Regional de Investigación pesquera La Paz. Centro Regional de Investigación pesquera Ensenada. La Paz. Baja California Sur. Abril de 2014. Vega-Velazquez, A., G.A. Jimenez-Llanos, A. Vega-Bolaños, E. Camacho-Bareño and J.C. Monroy. 2015. Evaluacion de la pesqueria de langosta roja (Panulirus interruptus), en la region centro occidental de la península de Baja California: Estado actual temporada 2014-2015. Informe de investigacion (preliminar). SAGARPA-INAPESCA/CRIP La Paz. 61 pp.

Villavicencio-Garayzar, C.J., White, C.F. & Lowe, C.G. 2015. Cephaloscyllium ventriosum. The IUCN Red List of Threatened Species 2015: e.T60227A80671800. http://dx.doi.org/10.2305/IUCN.UK.2015- 4.RLTS.T60227A80671800.en. Downloaded on 21 January 2016.

page 55 Version 1-3 (October 2013) | © SCS Global Services

SCS Baja California Lobster Fishery 4th Annual Surveillance Audit 2015

7 Appendix 1. Stakeholder Submissions and Team Response

No stakeholder comments were submitted for this surveillance.

8 Appendix 3. Surveillance Audit Frequency

The surveillance audit frequency is “normal” for this fishery, meaning annual. This is in accordance with Tables C3 and C4 in the MSC Certification Requirements. The fishery scores >2 in table C3 and therefore does not qualify for reduced or remote surveillance audits.

--End Report--

page 56 Version 1-3 (October 2013) | © SCS Global Services