February 2, 2015 Alaska Seafood Marketing Institute (ASMI) Conformance Criteria Committee 311 N. Franklin Street Suite 200 Juneau, AK 99801-1147 Submitted via ASMI online portal Re: Alaska RFM Conformance Criteria (Version 1.2) Review Comments Dear Committee members: I am submitting comments regarding the Alaska FAO Based Responsible Fisheries Management Certification Program (RFM) conformance criteria on behalf of Ocean Outcomes (O2). O2 is a new organization that works with local fishing communities and industry leaders to improve the sustainability of globally significant fisheries. Staff members have experience in a variety of areas that involve the development, application and review of sustainability criteria and assessment systems, including the development of FAO Ecolabelling Guidelines, consulting with organizations on their certification and seafood ranking criteria and, recently, serving on the Global Sustainable Seafood Initiative (GSSI) Fisheries Expert Working Group. Our staff has followed the development and progress of the RFM program since its inception and suggest that comments on the RFM system provided for example during previous RFM surveillance audits for Alaska salmon (e.g., State of the Salmon April 30, 2012 comments) still seem relevant and should be considered in this current review. Our past experiences had led us to conclude that the RFM program needed considerable improvement before it could be considered robust, transparent and meaningful. Therefore, we are encouraged to see that ASMI has opened the RFM conformance criteria to public consultation. However, improvements also need to be made to RFM policies regarding stakeholder input during the assignment of assessment team members; review of draft assessment results; and collecting information during surveillance audits. We note that ASMI’s webpage on RFM stakeholder involvement states that changes are coming in 2015. Based on this, we restrict our comments here specifically to the ‘FAO-based Responsible Fisheries Management Certification Program FAO-Based Conformance Criteria” version 1.2 (Criteria) and the companion document “Guidance to Performance Evaluation for the Certification of Wild Capture and Enhanced Fisheries in Alaska” version 1.1 (Guidance). We simply did not have the resources to provide a detailed review and analysis of these documents. Our comments provided below are thus general in nature and focus largely on criteria related to enhanced fisheries. Use of FAO Source Documents Ocean Outcomes Comments RFM Standard Review FeBruary 2, 2015 The RFM conformance criteria appear to be outdated in the context of considering and incorporating most recent guidance from FAO. The Criteria states that the RFM conformance criteria are based on three normative documents developed by the United Nations Food and Agriculture Organization (FAO): • the 1995 Code of Conduct for Responsible Fisheries (FAO Code), • the 2005 Guidelines for Ecolabelling of Fish and Fishery Products from Marine Capture Fisheries & 2009 extensions (Marine Guidelines) and, • the 1996 John Caddy Checklist FAO Fisheries Circular No. 917 (Caddy Checklist) The FAO adopted Guidelines for the Ecolabelling of Fish and Fishery Products from Inland Capture Fisheries (Inland Guidelines) in 2011, that materially revised (i.e., added to) the minimum substantive requirements and criteria for assessing whether a fishery can be certified and an ecolabel applied to a fishery, specified in the Marine Guidelines. In particular the Inland Guidelines specifically defined enhanced fisheries and added a number of minimum substantive requirements and criteria (e.g., Paragraphs 23, 36.8, 36.9, 38, 39, 40, 41 and 43) with respect to enhancement that earlier 2005 and 2009 Marine Guidelines had not addressed. These requirements would certainly be applicable to Alaska’s enhanced salmon fisheries and were adopted into the 2014 consultation draft GSSI framework to benchmark seafood certification programs. We noted that some aspects of the Inland Guidelines were included in the recently posted RFM Guidance (e.g. evaluation parameters for Clause 14.4). However, the articulation of Article 9 of the FAO Code (Aquaculture Development) into the conformance criteria itself as reflected in Sections 14 and 14.1-14.3 of the Criteria is weak and needs careful review with respect to adequacy, particularly in light of additional clarifications now provided in the Inland Guidelines. Enhancement as a Component of Fisheries Management System Enhancement activities should be considered under all the key components of Responsible Fisheries Management. Fishery enhancement activities are an integral part of important fisheries management programs such as that for Alaska salmon. However, the Criteria appear to consider all enhancement aspects solely under Clause 14 of key component F. “Serious Impacts of the Fishery on the Ecosystem”. Segregating the enhancement criteria in this way prevents a critical assessment of enhancement as it applies to the Fishery Management System; Science and Stock Assessment Activities; Precautionary Approach; Management Measures; and Implementation, Monitoring and Control. We strongly recommend that you consider enhancement as an integral part of the Fisheries Management System and incorporate enhancement criteria into all key components of the Criteria. SuBjective Scoring Guidance We were pleased to finally see the public posting of the Guidance on the ASMI website in November 2014. However, we found that guidance for many criteria were subjective and lacked specificity for objective evidence. Take for example the guidance for Clause 14.3 “Effective procedures specific to aquaculture of fisheries enhancement shall be established to undertake appropriate environmental assessment and monitoring, with the aim of minimizing adverse ecological changes (such as those caused by inputs from enhancement activities and related economic and social consequences.” The evaluation parameters are: Page 2 Ocean Outcomes Comments RFM Standard Review FeBruary 2, 2015 Process: There are management measures and regulations to ensure appropriate environmental assessment and monitoring is undertaken. Current Status/Appropriateness/Effectiveness: These procedures are effective in minimizing adverse ecological changes (such as those caused by inputs from enhancement activities) and related economic and social consequences. Evidence Basis: Availability, quality, and adequacy of the evidence. Examples may include various regulations, data and assessment reports. The process guidance seems to imply that management measures and regulations are in place to ensure assessment and monitoring takes place. In reality the management measures and regulations should be in place to minimize the adverse ecological, economic and social impacts of enhancement. Monitoring and assessment should be in place to evaluate whether the management measures and regulations are effective at doing so. While the current status appropriately addresses the outcome for minimizing the adverse impacts of enhancement, the evidence basis does not provide sufficient guidance for evaluating whether adverse impacts are occurring. Extensive research in Alaska and the Pacific Northwest on potential impacts from salmon enhancement activities on natural production has resulted in Congress forming Hatchery Scientific Review Groups (HSRGs) to evaluate and recommend improvements to hatchery programs in the Pacific Northwest and California. These have led to progressive recommendations on ways to evaluate and minimize the impacts of enhancement programs (e.g. Paquet et al. 2011). Alaska’s enhancement programs were designed to avoid many of the mistakes made by hatchery programs in the Pacific Northwest (e.g. requiring siting of hatcheries away from natural production areas). However, enhancement programs in Alaska still pose potential ecological and genetic risks to wild salmon populations (Grant 2012, Jasper et al. 2013). To credibly assess these risks, the guidance needs to include specific objective evidence to reduce subjectivity. Examples can be found of such objective evidence can be found in the Marine Stewardship Council document (MSC 2014) completed after their recent standard review, and Seafood Watch’s Standard for Salmon Fisheries Consultation document (SFW 2014). Summary We appreciate the opportunity to review and comment on the RFM Criteria and Guidelines. O2 staff would be available to provide technical services with subsequent criteria drafting, revision, or guidance in subsequent steps. We look forward to constructive improvements in these documents and stakeholder engagement policies. Sincerely, Randy Ericksen Fisheries Science Director Ocean Outcomes [email protected], +1-503-333-0502 Page 3 Ocean Outcomes Comments RFM Standard Review FeBruary 2, 2015 References Caddy, J. F. 1996. A checklist for fisheries resource management issues seen from the perspective of the FAO Code of Conduct for Responsible Fisheries. FAO Fisheries Circular No. 917. Rome, FAO. 22 pp. FAO. 2011. Report of the twenty-ninth session of the Committee on Fisheries. Rome, 31 January– 4 February 2011. FAO Fisheries and Aquaculture Report. No. 973. Rome, FAO. 59 pp. FAO. 2010. Report of the expert consultation on the development of guidelines for the ecolabelling of fish and fishery products from inland capture fisheries. Rome, 25−27 May 2010. FAO Fisheries and Aquaculture Report. No. 943. Rome, FAO. 37 pp. FAO. 2009. Guidelines for the ecolabelling of fish and fishery