Opting out of MSC mackerel recertification because of cost and threats

A group of mackerel handline fishermen from Mevagissey Cornwall (South West Hand Line Fishermen's Association) have decided to opt out of MSC recertification according to a news item from thisisdevon.co.uk  

The primary reason given is the “staggering” cost of £12,000 plus VAT that must be paid to the consulting company Moody Marine Ltd for recertification.  Fishermen also cited MSC’s threat to withdraw accreditation of all north east Atlantic mackerel fisheries in early 2012 unless Iceland and Faroes stop overfishing the mackerel stock.

If MSC follows up with this threat, it seems highly unlikely that the Mevagissey handline fishermen would be refunded their recertification fee by Moody.

Fishermen are considering alternative cheaper ways of promoting their catch as sustainable, such as the grass routes “Responsible Fishing Scheme”.

The large fees charged by consulting companies like Moody for secret pre-assessments (up to $35K?), full assessments (up to $150K?), annual audits and recertifications (up to $20K?) reflect the value placed on the MSC brand by large players in the fishing industry.

It is not clear that smaller low tech fisheries such as the mackerel handline fishery can continue to afford the high prices charged for MSC certification, even though these smaller fisheries are often the most sustainable with least bycatch and impact on the ecosystem.

Alternative grassroots schemes like the Responsible Fishing Scheme or schemes provided by concerned environmental groups such as Seafood Watch and SeaChoice may prove to be increasingly attractive.    

MSC and the mackerel certification dilemma

The Marine Stewardship Council is facing a bit of a dilemma over its sustainability certification of NE Atlantic mackerel fisheries. 

MSC announced April 13 2011 that the independent adjudicator (retained under salary by MSC to hear objections) had decided to uphold an objection to the certification of the Faroese Pelagic Organisation North East Atlantic mackerel fishery to the MSC standard. 

The objection was lodged by Marine Scotland (government agency) against the assessment completed by the consulting company Det Norske Veritas.  The objection was that the Faroese fishery was not abiding by the management framework rules that were in place.

From 2000-2009 the Faroese were part of an international trilateral mackerel agreement with the EU and Norway which respected the scientific advice on sustainable catch levels provided by the International Council for Exploration of the Sea (ICES). 

Recent changes in the distribution of mackerel in the NE Atlantic has made the stock more available and hence more attractive to Faroese and Icelandic fisheries and these two countries have unilaterally increased their catch levels outside ICES advice and the management framework. 

Unless the EU or Norway reduces their own catch, which they are unlikely to do, the total catch in 2011 will exceed ICES recommended sustainable levels and will put the resource at risk.   

Iceland does not seem to care because it is not certified by MSC nor is it applying for certification.  But what of the other mackerel fisheries?  There are 8 separate fisheries already certified by MSC and a 9^th in the assessment process.

fishnewseu.com reported on 13 April that MSC has stated that the decision should have no effect on already MSC certified mackerel fisheries which all fall within Norwegian or EU jurisdiction.

This contradicts an earlier MSC news release of July 16 2010 that “Unless the situation is resolved by the end of 2011, the unilateral quotas and increases in fishing activity will result in suspension of MSC certification of fisheries committed to harvesting the stock sustainably.”

So which is it?  Will all the mackerel fisheries be punished by MSC because two fisheries are being bad?

On the face of it, they should.  ICES considers the NE Atlantic Mackerel fishery to be one stock, albeit composed of three spawning components.  ICES estimates that fishing mortality has exceeded Fmsy (the fishing mortality that gives maximum sustainable yield) since the early 1990s, so technically NE Atlantic Mackerel already has overfishing taking place.  However, the biomass is relatively healthy, above MSY Btrigger, a biomass reference point that triggers a cautious response when stocks fall too far below Bmsy (the biomass associated with maximum sustainable yield). 

ICES estimates that catch in 2010 was 930kt and that this would have to be lowered to below 672kt in 2011 to be consistent with management objectives under the MSY approach.  This is unlikely to happen with Faroese and Icelandic fisheries not abiding by the rules. 

So now the dilemma: can the existing certified fisheries, who are abiding by the rules, still be considered sustainable if two non-certified fisheries are breaking the rules such that the sum of all the fisheries on NE Atlantic mackerel results in overfishing and stock depletion?

MSC is waffling on this issue. 

Turtles and sustainable swordfish

The Marine Stewardship Council deadline for stakeholder comments on the draft sustainability assessment report for the Canadian swordfish longline fishery is just days away. 

Although there are inadequacies in the scientific assessment of the swordfish stock and the management of the fishery by both ICCAT and Canada, swordfish are considered to be at or above the biomass that gives maximum sustainable yield and fishing mortality is below the level that achieves maximum sustainable yield.  In US fishery parlance, the stock is not overfished and neither is overfishing taking place.  On the face of it the primary requirements for consideration as a sustainable fishery under international best practices are met.

The big issue is bycatch of other species such as turtles and sharks. 

Concern is greatest for the loggerhead sea turtle.  Estimated bycatch in the Canadian pelagic longline fishery is about 1,200 turtles annually out of a population of 17,000.  This species was determined by COSEWIC to be endangered in Canada in April 2010 because it is “declining globally and there are well documented, ongoing declines in the Northwest Atlantic population from which juveniles routinely enter and forage in Atlantic Canadian waters. The Canadian population is threatened directly by commercial fishing, particularly bycatch in the pelagic longline fleet, and by loss and degradation of nesting beaches in the southeastern USA and the Caribbean.”

A decision by the Canadian Government on whether or not to list loggerheads under the Species at Risk Act has yet to be made.  In its initial response on December 2010, Government stated that “A voluntary Code of Conduct for Responsible Sea Turtle Handling and Mitigative Measures has been developed by the Canadian swordfish and tuna pelagic longline fleet.  This Code of Conduct includes measures such as avoiding areas of high sea turtle capture rates, gear hauling protocols to minimise harm to turtles, sea turtle handling guidelines, and usage instructions for de-hooking gear.”

A Canadian Department of Fisheries and Oceans recovery potential assessment published in 2010 found that “Reduction or elimination of mortality in Canadian waters alone is highly unlikely to be sufficient to achieve recovery.” 

Although not the sole culprit, and despite efforts being made in Canada to reduce bycatch and increase survival of released loggerheads, the Canadian longline swordfish fishery is contributing significantly to the potential extinction of loggerheads.

The Canadian harpoon fishery for swordfish has zero bycatch mortality and provides a certified sustainable alternative source for consumers to consider.

Marine Stewardship Council - Acceptable time frames for rebuilding depleted fish stocks

In the fall of 2010 MSC consulted with partners and stakeholders on acceptable rebuilding timeframes for certification of depleted stocks.  MSC defines a depleted stock as one which has a biomass below BMSY (the biomass that gives maximum sustainable yield) or equivalent target level, but is still above a precautionary limit level. Fisheries on stocks which are depleted can become MSC certified, however certification of such fisheries requires that there be a rebuilding plan in place which leads to the recovery of the stock within a specified timeframe.

The MSC Fisheries Assessment Methodology addresses rebuilding under Performance Indicator PI 1.1.3.  Currently, a conditional pass score of SG60 merely requires “reasonable expectation of success” with regard to rebuilding to the target biomass of BMSY within a specified timeframe.  

An unconditional pass of SG80 requires evidence that rebuilding strategies “are rebuilding stocks, or it is highly likely based on simulation modelling or previous performance that they will be able to rebuild the stock within a specified timeframe”.

A perfect score of SG100 requires that “strategies are demonstrated to be rebuilding stocks continuously and there is strong evidence that rebuilding will be complete within the shortest practicable timeframe”.

It is good that MSC is considering revising its methodology with regard to depleted stocks; however the consultation document only addresses a clearer definition of the timeframes for rebuilding to be associated with each of the three scores.

MSC certification of fisheries on depleted stocks as “sustainable” is highly controversial.  See for example the ongoing saga of the conditional certification of the fishery on the collapsed offshore South African hake stock. 

It can be argued that the current SG100 requirement should be the minimum required in order for a fishery to be considered for a conditional pass score (SG60) and that an unconditional pass score (SG80 or 100) should only be given to a fishery on stock that has already rebuilt and is fluctuating around BMSY or above under a fishing mortality of FMSY or lower (the fishing mortality rate consistent with maintaining the stock at BMSY or above).

A fishery on a depleted stock should never be considered sustainable.   

MSC Surveillance audit – South African hake trawl fishery

It is one year into the recertification of the South African hake trawl fishery.  Moody Marine Ltd has sent a team to South Africa to undertake the first surveillance audit of the fishery as required under the MSC eco-certification procedure.

The recertification the South African hake trawl fishery was not plain sailing for Moody.  The unit of certification includes an inshore and an offshore fishery component on different species.  The offshore hake, Merluccius paradoxus, is the main contributor to the fishery.  It is in a collapsed state and did not improve during the previous certification period.

One of the independent reviewers of the Moody recertification strongly argued against calling a fishery “sustainable” when one of the components remains in a severely depleted state.  This was overruled by Moody in their assessment, but did lead to “Condition 1” in the certification – a requirement that a recovery trend be demonstrated in M. paradoxus within the certification period.

So is there evidence that M. paradoxus is recovering?  It is hard to tell.  The last public-domain stock assessment document is a 2008 paper by Rademeyer and colleagues at the MARAM consulting company based in the Mathematics Department of the University of Cape Town.  This assessment showed the spawning biomass trajectory up to 1999 and there is no evidence of rebuilding. 

The Moody 2010 certification report provides the public with a rare look at the assessment process and the state of the stock. According to the report “models developed and implemented by MCM and its contractors are subjected to various reviews and debates through MCM’s Demersal Working Group. Industry, through their consultants, participate in the debates of the Working Group and have been influential in guiding the research.”

MCM is the South African federal government department of Marine and Coastal Management.  MCM is a bit of a black hole.  Nothing in the way of useful information is released to the public.  The “contractor” to MCM is MARAM.  MARAM developed the assessment model and also carry out the assessments using the model, apparently because of a lack of quantitative expertise at MCM.  MARAM is also responsible for the development of the Operational Management Procedure which is used by MCM to manage the stock.  MARAM does not produce public documents related to its contracts with MCM.

The assessment in the Moody certification report extends the spawner biomass series to 2007.  Spawning Stock Biomass continues to decline, reaching the lowest estimated level ever.  Projections under the MARAM management procedure predict that recovery will take place following 2007, however such projected recoveries are notoriously optimistic and routinely get postponed in subsequent assessments.  There needs to be actual realized evidence of recovery to satisfy Condition 1, not merely a projection.

One assumes that the Moody team for the current hake surveillance audit will have MARAM and MCM documents at their disposal in order to evaluate whether or not Condition 1 is being met.  

There should be full public disclosure by Moody of all relevant MCM and MARAM documents on M. paradoxus used in the audit, otherwise the public are being kept in the dark and have a right to be suspicious.

A comment on the NE Atlantic mackerel objection

From the comment section - the following anonymous comment on the NE Atlantic mackerel certification raises some interesting issues and is repeated here.


Two things strike me regarding this. 


Firstly, MSC has always said that it is not directly involved in decisions regarding who gets certified and who does not. It argues that it merely sets the standard for the assessment criteria and then it is up to an independent consulting company to determine if a fishery meets the standard. The proclamation on the MSC website regarding removal of certification by 2012 unless the whole NE Atlantic mackerel fishery meets the standard sounds like direct interference in the process to me.


Secondly, the concept that not only the enterprises seeking certification need to be abiding by the criteria, but also those outside the certification, will pose problems for other fisheries currently seeking certification, such as the offshore northern shrimp fishery of Newfoundland/Labrador. In this fishery Faroe Islands have unilaterally increased their own shrimp quota outside the overall quota set by the responsible RFMO, NAFO.

NE Atlantic mackerel – MSC policies and international governance

The NE Atlantic mackerel fishery is presenting some interesting insights into the evolving policies of the Marine Stewardship Council and its relationship with existing governance structures.

It can be argued that Marine Stewardship Council  eco-certification program only has added value in situations where national and international fisheries governance structures are not doing their job of conserving fisheries and ecosystems through sustainable management in the interests of long-term public good.

Given the poor practices of many governments in both developed and developing nations, and regional fisheries management organizations, there has been much for MSC to get their teeth into over the last 10 years.  Some of the cases they have taken on have been controversial – best known of all being the recent Ross Sea Antarctic Toothfish fishery certification.  This fishery is in international waters and is being pursued by a number of fleets from around the world.  A subset of these fleets applied for certification and achieved it despite strong objections from conservation groups (but not the responsible RFMO, CCAMLR).  Other fleets outside of the certification engaged in the same fishery have reputations as pirates and rogues responsible for serial collapses of the conspecific Patagonian Toothfish fisheries in various parts of the world.  This did not seem to matter to MSC then.

But it matters now.  MSC has announced that unilateral quotas and increases in fishing activity by Faroese and Icelandic fisheries on NE Atlantic mackerel will result in suspension of MSC-certification for those seven fisheries already certified.  Ongoing certification and any new certifications of fisheries on this stock will require establishment of a mechanism for monitoring and managing the combined catch of all the nations before the end of 2011. If not, all seven certificates will be suspended in January 2012.

The mackerel bubble was burst, not by an environmental organization but by the tweed jackets at Marine Scotland, part of the core Scottish Government set up in 2009 to manage Scotland's waters.  They recently ponied up the £5,000 required to object to the assessment by the for-profit consulting company Det Norske Veritas that the Faroese mackerel fishery smelt like roses.

So two three things of note (1) MSC threatens removal of certification unless the whole fishery including those not in the program are behaving; (2) A government challenges the outcome of the MSC process; and (3) An objection is actually sustained by the MSC appointed Independent Adjudicator.

Too bad about the Ross Sea Antarctic Toothfish though.