BC Dogfish Fishery - Certified sustainable

There are a couple of interesting aspects to the recent MSC certification of the inside and outside fisheries in the British Columbia hook and line spiny dogfish fisheries.

This is apparently the first shark fishery to get MSC certification.  Sharks tend to be long-living, slow-growing, late-maturing, low-fecundity species.  This combination of life-history traits means that they are vulnerable to overfishing. 

A poorly managed commercial fishery on low productivity species like spiny dogfish typically ends up as a “mining operation” and is seldom sustainable.  This seems to have been the case with the BC spiny dogfish. 

The fishery dates back to 1870.  Catches in the liver oil fishery peaked at over 12,000 t for the inside fishery and over 25,000 t for the offshore fishery in the 1940s. 

Although indices of population abundance are not available over this early period, it can be reasonably assumed that the resource was essentially “mined out” in the 1940s and 1950s.  Catches dropped off sharply in the 1960s and have remained low.

Since the late 1970s, spiny dogfish has been fished as a source of food (including fins for soup) rather than liver oil, using longline and trawl gear, with total annual landings averaging about 1,500 t in the inshore and about the same in the offshore.

Scientific survey and commercial catch rate indices of abundance are all from the 1980s onwards, well after the initial “mining” period had ended, so are uninformative about the big decline from overfishing in the 1940s and 1950s.  In 2010 the Canadian Department of Fisheries and Oceans (DFO) carried out the first attempt at an assessment of stock status since 1987,  This was prompted by the eco-certification bid being made by the fishing industry and a concurrent and pending species-at-risk (of biological extinction) evaluation by COSEWIC under Canada’s Species at Risk Act.  A strange concurrence of events! 

The abundance indices in the DFO assessment showed no clear trends and did not support the fitting of a mathematical population model to the data.  Conclusions were therefore drawn from expert opinion and subjective evaluation.  The assessment did not conclude that the fishery was sustainable, but rather that “There is no immediate conservation concern”.  Given no evidence of a recovery from the decline that must have occurred in the 1940s and 1950s from overfishing, it seems likely that the population remains in a depleted state.

MSC eco-certification begun under contract to the consulting company TAVEL in 2008.  TAVEL was taken over by Moody Marine Ltd part way through the assessment.  Moody initially indicated they would apply the default assessment approach.  This requires quantitative estimates of stock size and the impact of the fishery under Principle 1 of the MSC process.  However, when Moody realized in 2010, based on the new DFO stock assessment, that the data were sparse and uncertain, they switched to the so-called “Risk Based Framework” (RBF) for evaluating Principle 1. 

RBF was introduced by MSC in 2009 to enable scoring of fisheries in data deficient situations, particularly for the “outcome” performance indicators associated with Principles 1 and 2.  

MSC states on its website that “The first years of MSC certification have shown that the strong focus on quantitative data, to prove a fishery is operating sustainably, can make it difficult for smaller and more traditionally operated fisheries to become MSC certified. This is particularly true for, but not limited to, small-scale and Developing World fisheries.”     

The last sentence is particularly pertinent.  Application of an RBF type approach to artisanal fisheries in underdeveloped countries which have a history of supporting small catches (thus proving the fishery to be sustainable) seems justified.  It would be unfair to discriminate in the market place against such fisheries because they are unable to meet the quantitative criteria applied in a standard quantitative MSC assessment of stock status and impact of the fishery. 

Should RBF also be used for industrial scale commercial fisheries in developed countries such as Canada which have access to government research programs and modern methods of data collection and analysis?  Some would argue that data deficiency in such a fishery would be reason enough for it to fail a sustainability assessment. Under “reversal of burden of proof” the fishery is guilty until proven innocent.  At best, RBF, by its nature, can only provide weak evidence that a fishery is sustainable.  It can’t make up for the lack of data and quantitative analysis.   

Two methods are applied in the MSC RBF approach: a system based on expert judgment (Scale Intensity Consequence Analysis- SICA), and a semi-quantitative analysis to assess potential risk (Productivity Susceptibility Analysis - PSA).  SICA is based on the structured collection of qualitative information from a diverse group of stakeholders. 

Similar subjective risk-based approaches have been around for a while but have always remained on the periphery of the scientific evaluation and management of fisheries.  They are generally considered useful in a first-pass or triage approaches to select priority high risk cases for more comprehensive scientific analysis. Generally they are used to identify “near death” cases, not  the“healthy” ones. 

In the case of BC spiny dogfish, RBF was applied to MSC Principle 1: “A fishery must be conducted in a manner that does not lead to over-fishing or depletion of the exploited populations and, for those populations that are deplete the fishery must be conducted in a manner that demonstrably leads to their recovery.”

When RBF is applied to MSC Principle 1, the focus is on the performance indicator PI 1.1.1 which has to do with stock status.  Other PIs under Principle 1 are either automatically given a passing score of 80 or are not applied in the scoring, except one.  This PI, “stock rebuilding”, is only scored if “stock status” is given a score of 80 or more but will be noted under “conditions” in the assessment document if the score for the first PI is less than 80.

Both the inside and outside stocks of spiny dogfish achieved scores of 80 for SICA but only 68 for PSA leading to conditions being place on the sustainability certification.  Under MSC rules, a fishery is only eligible to use the RBF for PI 1.1.1 in subsequent MSC assessments if the MSC scores resulting from both the SICA and PSA analyses are 80 or greater.  This means that RBF may not be used for any subsequent MSC certifications for the BC spiny dogfish fishery.  They have used their "get out of jail free card".  

The conditions placed on the BC spiny dogfish certification require that measures be put in place that will reduce the RBF risk score for PI 1.1.1 within the current certification and that by the time of reassessment in 5 yrs there needs to be a direct measure of stock status that can be compared with biologically based reference points.

To sum up, MSC has certified a fishery on a species with a life history that makes it vulnerable to overfishing, on a population that is probably still depleted from historic overfishing, and in the absence of a quantitative estimate of stock and acceptable harvest levels. 

RBF cannot be used in the next assessment of the stock in 5 yrs time according to MSC's own rules.  Unless new surveys and additional research are initiated by the Department of Fisheries and Oceans or the stakeholders, this certification will have been premature and temporary.  It will not build public confidence in the MSC eco-label for sustainable fisheries.

BC Spiny Dogfish – Sustainable Fishery or Species at Risk?

Will BC Spiny Dogfish be the first shark fishery to be deemed sustainable by the Marine Stewardship Council? Or will it become another species on the growing COSEWIC Species At Risk list? 

MSC accredited certifying body, Moody Marine Ltd, is part way through a sustainability determination and COSEWIC is presently reviewing the extinction risks.

IUCN previously assessed the Spiny Dogfish as near threatened globally.  A proposal by Germany in 2004 to list Spiny Dogfish under CITES Appendix II tabled at a pre-CITES meeting was rejected by European member states.

The MSC assessment process started in 2008 under another private consulting company, TAVEL, which has subsequently been taken over by rival Moody.

Things moved very slowly on the MSC dogfish assessment and on 2 March 2010 Moody announced that it would be using the MSC “default assessment tree”.  In other words, the full-blow sustainability determination with multiple criteria under three Principles as given in “Marine Stewardship Council Fisheries Assessment Methodology and Guidance to Certification Bodies”.

However, once the Moody assessment team started to dig into the available data on this fishery, they found that it was very data-poor.  The last time the federal Department of Fisheries and Oceans (DFO) had attempted to assess the status of the stock was back in 1987, so Moody had very little that was current to work with.  Moody and other MSC accredited consulting companies typically “borrow” extensively from the latest government or RFMO scientific assessment in order to arrive at their sustainability determination.

DFO dutifully commissioned a new stock assessment for BC spiny dogfish held May 17, 2010 in Nanaimo, BC.  The ensuing DFO report, “Science Advisory Report 2010/057 – Assessment  of Spiny Dogfish (Squalus acanthius) in British Columbia in 2010” has yet to see the light of day with regard to the general public.  However, one must assume that Moody got a sneak preview and didn’t like what it saw, because on 8 October 2010 they announced that they had changed their mind and rather than apply the default assessment tree, they are opting for the alternate back-door route to certification by applying the MSC “Risk Based Framework” (RBF).

The RBF was developed by MSC as an alternative assessment approach for data-deficient situations; particularly for Principles 1 and 2 (in other words, the important stuff like stock status, management strategy and ecosystem impacts).  Initially the motivation for such an approach was the idea that the default assessment tree favoured large scale fisheries in developed nations and that smaller fisheries in under-developed countries would be at an economic disadvantage because of a lack of the appropriate information and infrastructure, even though these fisheries might have a track record of being sustainable over a number of years.

This notion of giving a break to under-developed countries seems to have fallen by the way, and RBF is now being applied to fisheries for which there is no excuse for not having a state-of-the-art assessment of the sustainability of a fishery.  Case to point – a British Columbia fishery – one of the wealthiest provinces in one of the wealthiest countries with super-abundant resources to collect the information required to determine whether a fishery is sustainable.

RBF methods are much more subjective than the standard approach under the default assessment tree.  Methods range in complexity and data requirements from a system based on expert judgment (Scale Intensity Consequence Analysis- SICA), to a semi-quantitative analysis to assess potential risk (Productivity Susceptibility Analysis - PSA).  PSA examines attributes of each species that contribute to or reflect its productivity or susceptibility.   Pacific Spiny Dogfish has both a very low productivity and a high susceptibility to fishing gear.  They are long-lived, only maturing at about 35 years of age.  Females typically give birth once every two years and produce around 6 pups after a gestation period of 22-24 months – the longest of any known vertebrate. 

There has been a commercial fishery for Spiny Dogfish in Pacific waters since 1870 with landings peaking landing of over 30,000 tons in the 1940s.  Landings have been much lower, between 5,000 and 7,000 tons, in the Canadian Pacific fishery in recent years presumably because of lower abundance.  The fishery is pursued by both hook-and-line and trawl gear.  Although trawl catches have been relatively stable recently, landings and discards in the hook-and-line fleet have been steadily increasing over the last eight years.  Catch rate and survey trends are either flat or decreasing.  The size of the population relative to virgin levels is not known.  The fishery is managed by quota, currently set at about 15,000 tons.  It is not clear whether this is an adequate measure to ensure a sustainable population in the long-term or whether a more conservative approach is required.

It will be very interesting to see what comes out of the parallel MSC and COSEWIC processes with regard to sustainability vs. extinction risks.  Either way, we need more up-to-date information and a conservation-minded harvesting strategy if the fishery is to be truly sustainably managed such that there is a very low risk of future declines, collapses or even extinction.