23.12.2012 Views

SGS Product & Process Certification - Marine Stewardship Council

SGS Product & Process Certification - Marine Stewardship Council

SGS Product & Process Certification - Marine Stewardship Council

SHOW MORE
SHOW LESS

Create successful ePaper yourself

Turn your PDF publications into a flip-book with our unique Google optimized e-Paper software.

Public comment draft report<br />

<strong>Marine</strong> <strong>Stewardship</strong> <strong>Council</strong> Initial Assessment<br />

Fishery: Dutch rod and line fishery for Sea Bass<br />

Client: Vereniging Beroepsmatige Handlijnvissers Nederland<br />

<strong>Certification</strong> body:<br />

<strong>SGS</strong> <strong>Product</strong> & <strong>Process</strong><br />

<strong>Certification</strong>Malledijk 18<br />

P.O. Box 200<br />

3200 AE Spijkenisse<br />

The Netherlands<br />

Tel: +31 (0)181 693333<br />

Fax: +31 (0)181 693572<br />

Client:<br />

Vereniging Beroepsmatige<br />

Handlijnvissers Nederland (VBHL)<br />

Strandwal 61<br />

4386 HG Vlissingen<br />

Tel: +31 (0) 646088932


MSC reference standards:<br />

MSC Accreditation Manual Issue 5,<br />

MSC Fisheries <strong>Certification</strong> Methodology (FCM) Version 6,<br />

MSC Chain of Custody <strong>Certification</strong> Methodology (CoC CM) Version 7.<br />

MSC Fisheries Assessment Methodology and Guidance to <strong>Certification</strong> Bodies Version 2,<br />

MSC TAB Directives (all)<br />

Policy Advisories (all)<br />

Assessment Team:<br />

M. Pawson<br />

B.J. Keus<br />

S. Buijs<br />

The client expressed to be thankful to the organisations that made this project possible:<br />

- Dutch Ministry EL&I<br />

- The European Fishery Fund<br />

- Resources Legacy Fund<br />

Page 1 of 151


Glossary of acronyms and terms used in the report<br />

Term Meaning<br />

ACOM ICES Advisory Committee<br />

ACFM Advisory Committee on Fisheries Management – ICES<br />

By catch Non-target species that are caught by fishing operations<br />

CEFAS Centre for Environment, Fisheries & Aquaculture Science (UK)<br />

CFP Common Fishery Policy<br />

CGFS Channel Ground Fish Survey<br />

DEFRA Department for Environment, Food and Rural Affairs (UK)<br />

DCR Data Collection Regulation<br />

DFS Demersal Fish Survey<br />

Discard Species that are caught during fishing operations and returned to<br />

the sea including commercial species that are undersized or not<br />

sold due to lack of quota or lack of markets, and non-commercial<br />

species<br />

ETP Endangered, threatened and protected species<br />

HCR Harvest Control Rule<br />

ICES International <strong>Council</strong> for the Exploration of the Seas.<br />

IFREMER Institut français de recherche pour l‘exploration de la mer<br />

ILVO Instituut voor Landbouw- en Visserijonderzoek<br />

IMARES Institute for <strong>Marine</strong> Resources & Ecosystem Studies<br />

LNV Dutch Ministry of Agriculture, Nature and Food Safety<br />

MLS Minimum Landing Size<br />

MOU Memorandum of Understanding<br />

MPA <strong>Marine</strong> Protected Area<br />

PO Producers Organisation<br />

PSA <strong>Product</strong>ivity and Susceptibility Analysis<br />

RAC Regional Advisory <strong>Council</strong><br />

RBF Risk Based Framework<br />

SICA Scale Intensity Consequence Analysis<br />

SSB Spawning stock biomass<br />

SURBA Survey Based Assessment methodology<br />

TAC Total Allowable Catch<br />

UoC Unit of certification. The fishery that will be subject to MSC<br />

certification<br />

VBHL Vereniging Beroepsmatige Handlijnvissers Nederland (Client)<br />

VMS Vessel Monitoring System<br />

WGNEW Working Group on Assessment of New MoU Species (ICES)<br />

Page 2 of 151


CONTENTS<br />

CONTENTS ........................................................................................................................................................... 3<br />

SUMMARY ........................................................................................................................................................... 5<br />

1.1 THE UNIT OF CERTIFICATION ..................................................................................................................................... 7<br />

1.2 THE CLIENT ....................................................................................................................................................... 7<br />

1.3 REPORT STRUCTURE AND ASSESSMENT PROCESS ....................................................................................................... 8<br />

1.4 REFERENCES ............................................................................................................................................... 10<br />

1. THE ASSESSED FISHERY ............................................................................................................................. 13<br />

2.1 BIOLOGY OF THE TARGET SPECIES ......................................................................................................................... 13<br />

2.2 OVERVIEW OF THE FISHERY .................................................................................................................................... 16<br />

2.2.1 History of the fishery ............................................................................................................................... 16<br />

2.2.2 Fleet and Gear Description ...................................................................................................................... 18<br />

2.2.3 Dutch rod and line fishery ....................................................................................................................... 18<br />

2. TARGET STOCK STATUS AND HARVEST CONTROLS (P1) ............................................................................ 19<br />

3.1 ANALYTICAL ASSESSMENTS ..................................................................................................................................... 20<br />

3.2 STOCK STATUS ..................................................................................................................................................... 22<br />

3.3 HARVEST CONTROLS ............................................................................................................................................. 23<br />

3.3.1 Management unit ................................................................................................................................... 23<br />

3.3.3 Biological reference points ...................................................................................................................... 24<br />

3.3.4 Scientific background to management advice for sea bass .................................................................... 24<br />

4. ENVIRONMENTAL ELEMENTS (P2) ................................................................................................................. 25<br />

4.1 RETAINED SPECIES ................................................................................................................................................ 25<br />

4.2 DISCARDING .................................................................................................................................................... 27<br />

4.3 ENDANGERED, THREATENED AND PROTECTED SPECIES (ETP) .................................................................................... 27<br />

4.4 HABITAT ......................................................................................................................................................... 27<br />

4.5 ECOSYSTEM IMPACTS ........................................................................................................................................ 27<br />

3. FISHERY MANAGEMENT FRAMEWORK (P3) .............................................................................................. 27<br />

5.1 LEGISLATION AND REGULATION ............................................................................................................................... 27<br />

5.2 ROLES & RESPONSIBILITIES .................................................................................................................................... 28<br />

5.4 MONITORING, CONTROL AND SURVEILLANCE ........................................................................................................ 29<br />

5.4 COMPLIANCE ................................................................................................................................................... 30<br />

5.5 DISPUTE RESOLUTION ........................................................................................................................................ 30<br />

7. STANDARD USED ...................................................................................................................................... 32<br />

PRINCIPLE 1 .............................................................................................................................................................. 32<br />

PRINCIPLE 2 .............................................................................................................................................................. 32<br />

PRINCIPLE 3 .............................................................................................................................................................. 33<br />

8. BACKGROUND TO THE EVALUATION ........................................................................................................ 35<br />

8.1 EVALUATION TEAM ........................................................................................................................................... 35<br />

8.2 PUBLIC CONSULTATION ......................................................................................................................................... 36<br />

8.3 STAKEHOLDER CONSULTATION ................................................................................................................................ 36<br />

8.4 INTERVIEW PROGRAMME ....................................................................................................................................... 37<br />

8.4 OTHER CERTIFICATION EVALUATIONS AND HARMONISATION ......................................................................................... 37<br />

9. OBSERVATIONS AND SCORING ................................................................................................................. 38<br />

9.1 INTRODUCTION TO SCORING METHODOLOGY ......................................................................................................... 38<br />

9.2 RISK BASED FRAMEWORK (RBF) ......................................................................................................................... 38<br />

9.2.1 Introduction to RBF ................................................................................................................................. 38<br />

9.2.2 SICA ......................................................................................................................................................... 40<br />

Page 3 of 151


9.2.3 PSA .......................................................................................................................................................... 43<br />

9.3 SCORING OF PERFORMANCE AGAINST MSC PRINCIPLES ........................................................................................... 47<br />

10. ASSESSMENT RESULTS .............................................................................................................................. 48<br />

10.1 PERFORMANCE ........................................................................................................................................... 48<br />

10.2 CONDITIONS ............................................................................................................................................... 49<br />

13.3 RECOMMENDATIONS ................................................................................................................................... 53<br />

11. LIMIT OF IDENTIFICATION OF LANDINGS FROM THE FISHERY ................................................................... 54<br />

11.1 TRACEABILITY ............................................................................................................................................. 54<br />

11.2 AT-SEA PROCESSING ..................................................................................................................................... 54<br />

11.3 POINTS OF LANDING ..................................................................................................................................... 54<br />

11.4 ELIGIBILITY DATA ......................................................................................................................................... 54<br />

12. PEER REVIEW, PUBLIC COMMENTS, OBJECTIONS...................................................................................... 55<br />

13. MSC LOGO LICENSING RESPONSIBILITIES .................................................................................................. 56<br />

13.1 LOGO USE ......................................................................................................................................................... 56<br />

14. CONCLUSION ............................................................................................................................................ 57<br />

APPENDICES ....................................................................................................................................................... 58<br />

APPENDIX A: SCORING TABLE ............................................................................................................................ 58<br />

APPENDIX B: PEER REVIEW REPORTS ........................................................................................................................... 112<br />

APPENDIX C: CLIENT ACTION PLAN .................................................................................................................. 145<br />

APPENDIX D: STAKEHOLDER COMMENTS ........................................................................................................ 147<br />

APPENDIX E: OBJECTION TO DETERMINATION................................................................................................. 150<br />

Page 4 of 151


SUMMARY<br />

The <strong>Marine</strong> <strong>Stewardship</strong> <strong>Council</strong> (MSC) is an independent, global, non-profit organisation. In a<br />

bid to reverse the continued decline in the world's fisheries, the MSC is seeking to harness<br />

consumer purchasing power to generate change and promote environmentally responsible<br />

stewardship of important renewable food sources.<br />

The MSC has developed an environmental standard for sustainable and well-managed<br />

fisheries. <strong>Product</strong> labels reward environmentally-responsible fishery management and<br />

practices. Consumers, concerned about overfishing and its environmental and social<br />

consequences, will increasingly be able to choose seafood products that have been<br />

independently assessed and certified against the MSC Standard. This will assure them that<br />

production of the product has not contributed to overfishing or environmental harm.<br />

The MSC‘s environmental standard for sustainable fishing, the Principles and Criteria for<br />

Sustainable Fishing, is based on the FAO Code of Conduct for Responsible Fisheries. The<br />

MSC Standard is constantly reviewed by an independent, international group of fisheries<br />

experts. Any fishery around the world can apply to be independently assessed against this<br />

standard.<br />

This report contains the assessment of the Dutch rod and line fishery for Sea Bass in the<br />

southern North Sea against the MSC‘s Principles and Criteria for sustainable Fishing.<br />

The assessment was carried out by a team of three assessors: Dr. Mike Pawson, Mr Bert Keus<br />

and Mr Sander Buijs (Lead assessor).<br />

The evaluation of the fishery against the MSC Principles and Criteria was undertaken following<br />

a site visit to the fishery at Burgh Haamstede, Zeeland, in September 2010, when meetings<br />

were also undertaken with relevant stakeholders.<br />

Information gathered during this site visit was used in conjunction with other available literature<br />

to produce a draft report and score the fishery against the MSC Performance Indicators. The<br />

draft report and scores of the fishery were then supplied to the client for review before being<br />

submitted for peer review.<br />

Peer Review was undertaken by Dr Henk Heessen (Netherlands) and Dr David Bennett (UK).<br />

The report was then available on the MSC website for stakeholder comment for a period of 30<br />

days, prior to being published as a final report on the MSC website in July 2011.<br />

The main strengths of the sea bass fishery with rod and line is that is has very few effects on<br />

the natural environment or ecosystem. There is no impact of the gear on bottom habitats. Sea<br />

bass is the main target species that is caught and landed, together with some cod and pollack.<br />

Other than a few undersized fish of these retained species, there are no discards.<br />

The main present weakness of this fishery is the management system, which lacks explicitly<br />

formulated fishery-specific management objectives or a harvest control rule (HCR), and the<br />

decision making process for the sea bass fishery in the North Sea as a whole is not well<br />

developed.<br />

<strong>SGS</strong> has determined that this fishery should be certified in accordance to the MSC principles<br />

and criteria, subject to four conditions which are summarised as follows:<br />

Page 5 of 151


Condition 1: P1, 1.2.2 Harvest control rule (score 75).<br />

Rationale: Although technical conservation measures are in place (minimum landing size and<br />

mesh size controls) that seek to maximise yield per recruit, the HCRs that are in place do not<br />

ensure that the exploitation rate is reduced as limit reference points are approached (with<br />

respect to maximum sustainable yield, since recruitment is not stock-driven).<br />

Condition: the client should liaise with management and research bodies to determine what<br />

part they can play in the development of a harvest control rule that better ensures that the<br />

exploitation rate on North Sea bass is reduced as limit reference points are approached.<br />

Timescale: By first surveillance audit: written evidence is required of appropriate action by the<br />

client towards management authorities and research institutes, and of their response.<br />

Condition 2: P3, 3.2.1 Fishery specific objectives (score 70)<br />

Rationale: There are clearly defined management objectives for Dutch North Sea fisheries in<br />

general, but fishery-specific management objectives are not explicitly formulated for the sea<br />

bass fishery (as a whole, in the North Sea). Condition: The client should liaise with the<br />

relevant management authorities and scientists (IMARES and ICES) and encourage them to<br />

develop specific objectives for this fishery, which would preferably also account for other fishing<br />

metiers targeting sea bass, such as trawling and gill net fishing. The Client should also<br />

formulate management objectives for the sea bass fishery within the VBHL management plan.<br />

Timescale: By first surveillance audit, written evidence is required of appropriate action by<br />

client to encourage the relevant management authorities to formulate management objectives<br />

for the sea bass fishery, and to demonstrate that a management objective for the sea bass<br />

fishery is incorporated within the VBHL management<br />

Condition 3. P3, 3.2.2 Decision making process (score 70)<br />

Rationale: Management systems for Dutch North Sea fisheries are well established and<br />

generally effective, decision-making processes are well developed and fishery representatives<br />

are regularly consulted by the relevant authorities. However, the rod and line fishery for bass is<br />

a relatively small sector and is not represented by the National Fishermen‘s organisations.<br />

Condition 3:The client should encourage the relevant management authorities to include the<br />

UoC in formal decision-making processes,<br />

Timescale: By first surveillance audit, written evidence is required of appropriate action by<br />

client to encourage the relevant management authorities to develop a formal decision making<br />

process for this fishery, and of their response.<br />

By the third surveillance visit, evidence is required of the establishment of a more fisheryspecific<br />

decision making-process.<br />

Condition 4. P3, 3.2.5 Information and monitoring (score 75).<br />

Rationale: Because fishery-specific management objectives are not explicitly formulated for<br />

the rod and line sea bass fishery, there is no provision for evaluation of the fishery‘s<br />

performance against objectives.<br />

Page 6 of 151


Condition: Once fishery-specific objectives are identified and set (Condition 2), the client<br />

should liaise with the relevant management authorities and scientists (IMARES and ICES) to<br />

develop a system of evaluating the performance of the management system against these<br />

objectives.<br />

Timescale: By the third surveillance visit, evidence is required that information is being<br />

collected that can be used to evaluate the performance of the fishery against management<br />

objectives.<br />

1. Introduction<br />

1.1 The unit of certification<br />

Prior to providing a description of the fishery, it is important to be clear about the precise extent<br />

of certification. The MSC Guidelines to Certifiers specify that the unit of certification (UoC) is<br />

“The fishery or fish stock (biologically distinct unit) combined with the fishing<br />

method/gear and practice (= vessel(s) pursuing the fish of that stock) and management<br />

framework”.<br />

This definition is useful for both clients and assessors to categorically state what is included<br />

and what is not. This is also crucial for any repeat assessment visits, or if additional vessels are<br />

wishing to join the certificate at a later date. The unit of certification for the fishery under<br />

consideration is set out below:<br />

The fishery assessed for MSC certification, the UoC is defined as:<br />

Species: Sea Bass (Zeebaars, Dicentrarchus labrax)<br />

Geographical Area: Southern North Sea (ICES Division IVc)<br />

Stock: North Sea<br />

Harvest method: Rod and line<br />

Management: EU CFP, National measures (Netherlands)<br />

Client Group: Members of the Dutch Organisation of professional rod and line<br />

fishermen (Vereniging van Beroepsmatige Handlijnvissers Nederland,<br />

VBHL). New members will be included in the UoC.<br />

1.2 The client<br />

This fishery assessment covers the rod and line fishery for sea bass with under-10 m fishing<br />

boats in the southern North Sea by members of the Dutch Organisation of Professional Rod<br />

and Line Fishermen (Vereniging van Beroepsmatige Handlijnvissers Nederland, VBHL). This<br />

organization was founded in 2006 and currently has 19 members. The goal of this organization<br />

is to represent the interests of its members in their widest sense.<br />

Page 7 of 151


Current members of VBHL are the following MFVs, with total length in metres and engine<br />

power in Kilowatts:<br />

1 BRU 22 6,98 m 173 KW<br />

2 BRU 88 5,35 m 55 KW<br />

3 KG 11 6,10 m 73 KW<br />

4 KG 16 8,60 m 184 KW<br />

5 KG 18 7,31 m 220 KW<br />

6 KG 20 9,65 m 376 KW<br />

7 KG 21 8,20 m 225 KW<br />

8 KG 4 7,20 m 184 KW<br />

9 KG7 6,30 m 113 KW<br />

10 SL 35 7,20 m 164 KW<br />

11 TH 20 7,37 m 110 KW<br />

12 WSW 10 6,22 m 167 KW<br />

13 WSW 11 5,05 m 37 KW<br />

14 WSW 12 6,20 m 147 KW<br />

15 WSW 2 9,58 m 234 KW<br />

16 WSW 3 6,50 m 117 KW<br />

17 WSW 5 8,20 m 225 KW<br />

18 WSW6 8,00 m 182 KW<br />

19 WSW9 8,60 m 184 KW<br />

1.3 Report structure and assessment process<br />

The aim of the MSC Fishery assessment is to determine the degree of compliance of the<br />

fishery with the MSC Principles and Criteria for Sustainable Fishing, as set out in Section 7.<br />

This report sets out:<br />

The background of the fishery under assessment and the context within which it operates.<br />

The qualifications and experience of the team undertaking the assessment.<br />

The standard used for MSC Fishery Assessment (MSC Principles and Criteria.)<br />

The stakeholder consultation process as carried out. Stakeholders are all those parties with<br />

an interest in the management of the fishery and include fishers, management bodies,<br />

scientists and Environmental Non-Governmental Organizations (ENGO‘s.)<br />

The methodology used to assess (‗score‘) the fishery against the MSC Standard.<br />

The intention of the first sections of the report is to provide the background information<br />

used to interpret the scoring commentary in the correct context.<br />

A scoring table (Appendix A) with the Scoring Indicators adopted by the assessment team<br />

and Scoring Guidelines, which aid the assessment team to allocate scores to the fishery.<br />

Page 8 of 151


The commentary in this table summarises the performance of the fishery in relation to<br />

these Scoring Indicators.<br />

From the final results of the scoring, the <strong>Certification</strong> Recommendation of the assessment<br />

team is presented, together with any conditions that may be attached to certification.<br />

In draft form, this report has been subjected to critical review by independent scientists with<br />

relevant experience (‗peer review‘). The comments of these scientists are appended to this<br />

report, together with the assessment team‘s responses, indicating where amendments are<br />

made to the report on the basis of peer reviewers‘ comments. Following the peer review,<br />

the report is then released for public scrutiny on the MSC website. (www.msc.org)<br />

The report, containing the recommendation of the assessment team, any further<br />

stakeholder comments and peer review comments, is then considered by the <strong>SGS</strong><br />

Governing Board (which is independent of the assessment team). The <strong>SGS</strong> Governing<br />

Board makes the final certification determination on behalf of <strong>SGS</strong>.<br />

It should be noted that, in response to comments by peer reviewers, stakeholders and the<br />

<strong>SGS</strong> Governing Board, some points of clarification may have been added to the final<br />

report.<br />

Finally, the complete report containing the <strong>SGS</strong> determination and all amendments is<br />

released for further stakeholder scrutiny.<br />

Page 9 of 151


1.4 References<br />

Castilho, R., and Mcandrew, B.J., 1998. Population structure of sea bass in Portugal: evidence<br />

from allozymes. Journal of Fish Biology, 53: 1038-1049.<br />

Dunn, M., Potten, S., Radford, A., and Whitmarsh, D., 1989. An economic appraisal of the<br />

fishery for bass in England and Wales. Research Report, R14, CEMARE, University of<br />

Portsmouth, UK, 217 pp.<br />

Dunn, M. R., and Potten, S. D., 1994. National survey of bass angling, A report to the Ministry<br />

of Agriculture Fish and Food. University of Portsmouth, 45 pp. plus 7 Appendices.<br />

Fritsch, M. , Morizur, Y., Lambert, E., Bonhomme, F., and Guinand, B. 2006.Assessment of<br />

sea bass (Dicentrarchus labrax, L.) stock delimitation in the Bay of Biscay and the English<br />

Channel based on mark-recapture and genetic data. Fisheries Research, 83: 123-132<br />

ICES, 2004. Report of the Study Group on Bass, Lowestoft, England 18-22 August 2003,<br />

ICES CM 2004/ACFM:04, 73 pp.<br />

ICES. 2008. Report of the Working Group on the Assessment of New MoU species (WGNEW).<br />

ICES CM 2008/ACOM:25.<br />

ICES, 2010.Report of the ICES Advisory Committee, 2010.ICES Advice, 2010.<br />

Jennings, S., and Pawson, M. G., 1992. The origin and recruitment of bass, Dicentrarchus<br />

labrax, larvae to nursery areas. Journal of the <strong>Marine</strong> Biological Association U. K., 72: 199–<br />

212.<br />

Kelley, D. F., 1986. Bass nurseries on the west coast of the UK. Journal of the <strong>Marine</strong><br />

Biological Association U. K., 66: 439–464.<br />

Kelley, D. F., 1987. Food of bass in U.K. waters. Journal of the <strong>Marine</strong> Biological Association<br />

U. K., 67: 275-286.<br />

Kelley, D. F., 1988.Age determination in bass and assessment of growth and year-class<br />

strength. Journal of the <strong>Marine</strong> Biological Association U. K.., 68: 179-214.<br />

Kelley, D., 2002. Abundance, growth and first-winter survival of young bass in nurseries of<br />

south-west England. Journal of the <strong>Marine</strong> Biological Association U. K., 82: 307 – 319.<br />

Kinne, O.,1995. Ecology of the North Sea. Problems, successes, failures, future needs.<br />

Helgolander Meersesunters. 49: 303-312 (1995).<br />

Kroon, J.W., 2007. Kennisdocument zeebaars, Dicentrarchus labrax, (Linnaeus, 1758).<br />

Kennisdocument 21, Sportvisserij Nederland, November 2007<br />

Kupschus, S. 2010. The UK bass fishery, re-run of FAD-only assessment model. Working<br />

Document, Report of the Working Group on the Assessment of New MoU Species (WGNEW).<br />

ICES CM 2010/ACOM:25, 77 pp.<br />

.<br />

Page 10 of 151


Kupschus, S., Smith, M. T., Walmsley, S. A. 2008. An update of the UK bass assessments<br />

2007.Working Document. Report of the Working Group on the Assessment of New MoU<br />

Species (WGNEW). By Correspondence, ICES CM 2008/ACOM:25, 77 pp.<br />

Lancaster, J. E., 1991. The feeding ecology of juvenile bass Dicentrarchus labrax (L.).PhD<br />

Thesis. University of Wales Swansea, 281 pp.<br />

Masski, H., 1998. Identification de Frayères et Etude des Structures de Population de Turbot<br />

(Psetta maxima L.) et du Bar (Dicentrarchus labrax L.) en Manche Ouest et dans les Zones<br />

Avoisinantes. Thèse présentée a la Faculte des Sciences de Brest. Universite de Bretagne<br />

Occidentale, 136pp + annexes.<br />

MMO, 2010.The Registration of Fish Buyers and Sellers and Designation of Fish Auction Sites<br />

Regulations 2005 (SI 2005 No 1605), viewed at<br />

http://www.marinemanagement.org.uk/fisheries/monitoring/rbs.htm. Aug. 2010.<br />

Naciri, M., Lemaire, C., Borsa, P., and Bonhomme, F., 1999.Genetic study of the<br />

Atlantic/Mediterranean transition in sea bass (Dicentrarchus labrax). Journal of Heredity, 90:<br />

591-596.<br />

Pawson, M. G. 1992. "Climatic influences on the spawning success, growth and recruitment of<br />

bass (Dicentrarchus labrax L.) in British Waters". I.C.E.S. marine Science Symposium. 195:<br />

388-392.<br />

Pawson M. G., 2008. The contribution of science to management of the North Sea cod (Gadus<br />

morhua) and UK sea bass (Dicentrarchus labrax) fisheries: could we do better? pp. 155- 182,<br />

in Advances in Fisheries Science. 50 years on from Beverton and Holt, Blackwell Publishing,<br />

Oxford. xxi + 547 pp.<br />

Pawson, M.G. and Eaton, D.R, 1999. The influence of a power station on the survival of<br />

juvenile sea-bass (Dicentrarchus labrax L.) in an estuarine nursery area. Journal of Fish<br />

Biology, 54: 1143-1160.<br />

Pawson, M. G., and Pickett, G. D., 1996. The annual pattern of condition and maturity in bass<br />

(Dicentrarchus labrax L) in waters around the UK. Journal of the <strong>Marine</strong> Biological Association<br />

U. K., 76: 107–126.<br />

Pawson, M. G., Kupschus, S., and Pickett, G. D. 2007b. The status of sea bass (Dicentrarchus<br />

labrax) stocks around England and Wales, derived using a separable catch-at-age model, and<br />

implications for fisheries management. ICES Journal of <strong>Marine</strong> Science, 64: 346–356.<br />

Pawson, M. G., Kelley, D. F., and Pickett, G. D. 1987. The distribution and migrations of bass<br />

Dicentrarchus labrax L. in waters around England and Wales as shown by tagging. Journal of<br />

the <strong>Marine</strong> Biological Association U. K., 67: 183–217.<br />

Pawson, M. G., Pickett, G. D., Lebalour, J, Brown, M., and Fritsch, M. 2007a. Migrations,<br />

fishery interactions, and management units of sea bass (Dicentrarchus labrax), in Northwest<br />

Europe. ICES Journal of <strong>Marine</strong> Science, 64: 332–345.<br />

Pawson, M. G., Pickett, G. D., and Smith, M. T., 2005.The role of technical measures in the<br />

recovery of the UK sea bass (Dicentrarchus labrax) fishery 1980 - 2002. Fisheries Research,<br />

76: 91 - 105.<br />

Page 11 of 151


Pawson, M.G., G. D. Pickett and P. R. Witthames, 2000. The influence of temperature on the<br />

onset of first maturity in sea-bass (Dicentrarchus labrax L). Journal of Fish Biology, 56: 319 –<br />

327.<br />

Pickett, G.D., 1990. Assessment of the UK bass fishery using a log-book-based catch<br />

recording system. Fish. Res. Tech. Rep., MAFF Direct. Fish.Res. Lowestoft 90, 33 pp.<br />

Pickett, G. D., Pawson, M. G., 1994. Sea Bass, Biology, exploitation and<br />

management.Chapman and Hall, London, Fish and Fisheries Ser. 12: 358 pp.<br />

Pickett, G. D., Brown, M., Harley, B., and Dunn, M. R., 2002.Surveying fish populations in the<br />

Solent and adjacent harbours using the CEFAS bass trawl. CEFAS Science Series Technical<br />

Report, 118:16 pp.<br />

Pickett, G. D., Eaton, D. R., Cunningham, S., Dunn, M. R., Potten, S. D., and Whitmarsh, D.<br />

1995. An appraisal of the UK bass fishery and its management. Laboratory Leaflet MAFF<br />

Directorate of Fisheries Research, Lowestoft, 75: 47pp.<br />

Pickett, G. D., Kelley D. F. and Pawson, M. G. 2004. The patterns of recruitment of sea bass,<br />

Dicentrarchus labrax L. from nursery areas in England and Wales and implications for fisheries<br />

management. Fisheries Research, 68: 329-342.<br />

Reynolds, W. J., Lancaster, J. E., and Pawson, M. G. 2003. Patterns of spawning and<br />

recruitment of sea bass to Bristol Channel nurseries in relation to the 1996 "Sea Empress" oil<br />

spill. Journal of the <strong>Marine</strong> Biological Association U. K., 83: 1163 - 1170.<br />

Roblin, C. and Bruslé, J., 1984. Le régime alimentaire des alevins et juvéniles de loup<br />

(Dicentrarchus labrax L.) des lagunes littorales du Golfe du Lion (étangs Roussillonnais,<br />

France). Vie et Milieu : 34: 195-207.<br />

Thompson, B. M., Harrop, R. T. 1987. The distribution and abundance of bass (Dicentrarchus<br />

labrax) eggs and larvae in the English Channel and Southern North Sea. Journal of the <strong>Marine</strong><br />

Biological Association U. K., 67, 263–274.<br />

Walmsley, S.A and Pawson, M. G., 2007. The coastal fisheries of England and Wales, Part V:<br />

A review of their status 2005-6. CEFAS Science Series Tech. Rep. No. 140: 83 pp.<br />

Page 12 of 151


1. THE ASSESSED FISHERY<br />

2.1 Biology of the target species<br />

Distribution<br />

Sea bass are distributed in Northeast Atlantic shelf waters from southern Norway, through the<br />

North Sea, Irish Sea, Celtic Sea, Bay of Biscay and Mediterranean, to Northwest Africa.<br />

Tagging studies around England, Wales and Ireland (Pawson, Kelly and Pickett, 1987; Pawson<br />

et al., 2007a), together with studies on geographical and seasonal patterns of feeding,<br />

condition and gonad development (Pawson and Pickett, 1996), have demonstrated that adult<br />

sea bass migrate between well-defined feeding areas and pre-spawning and spawning areas<br />

which tend to be offshore to the south and west. First-year sea bass are found in estuaries and<br />

harbours, and along the adjacent coastline, where the juveniles may remain for up to 5 years<br />

before recruiting to the adult population.<br />

Figure 1.Sea bass<br />

Stock identity<br />

Tagging and genetic studies indicate considerable mixing throughout the North-west European<br />

bass population (Castilho & McAndrew, 1998; Naciri et al., 1999; Frisch et al., 2006; Pawson et<br />

al, 2007a), and assessments of the dynamics of sea bass populations around the coasts of<br />

England and Wales show common features regarding year-class strength over large parts of<br />

the species‘ range (Pawson et al., 2007b). This suggests that the abundance of sea bass may<br />

be controlled by large-scale environmental patterns. However, the assessment areas proposed<br />

by ICES (2005), within which fishery and biological data could be used in assessments and for<br />

which management advice may be given, are based on a consideration of both the current<br />

patterns of seasonal movements of sea bass in the exploited populations (i.e., fish larger than<br />

the 36 cm minimum landing size – MLS, total length used throughout), as indicated by tag<br />

recaptures, and the characteristics of the fisheries taking them (Figure 2, Pawson et al.,<br />

2007a). The bass population in the North Sea (ICES Divisions IVa,b,c) is considered to be a<br />

single management unit, although there is some movement of both juvenile and adult sea bass<br />

between the North Sea and the English Channel (see below). The main area of exploitation of<br />

this ―stock‖ is in ICES Divisions IVc (southern North Sea) and VIId (eastern English Channel).<br />

Page 13 of 151


Figure 2.Main migration routes of adult sea bass and proposed ‗stock‘ areas within which<br />

fishery and biological data could be used in assessments of bass populations and for which<br />

management advice may be given (ICES 2005). The North Sea stock is designated by the<br />

hatched area ―A‖, the distribution of which now extends into Norwegian and Scottish waters.<br />

Spawning<br />

Tagging studies around England and Wales in the late 1970s and early 1980s demonstrated<br />

that adult bass migrated between feeding areas in the North Sea and pre-spawning and<br />

spawning areas which tended to be offshore in western English Channel (Pawson et al., 1987).<br />

Movement between the respective areas appeared to be relatively rapid and took place as the<br />

water cools in October-December. Spawning in the western English Channel started during<br />

March, when the temperature range associated with bass egg distributions was 8.5-11 °C, and<br />

appeared to spread east and into the North Sea in May and June as the surface water<br />

temperature exceeded 9 °C (Thompson and Harrop, 1987). Studies on geographical and<br />

seasonal patterns of feeding, condition and gonad development of bass (Pawson and Pickett,<br />

1996; Masski, 1998), and a repeat tagging exercise in 2000-2004 (Pawson et al., 2007a)<br />

confirmed that the spent fish move north and east onto feeding grounds at the end of spawning<br />

in April/May. The most recent tagging study, however, suggests that proportionately fewer<br />

adult sea bass were leaving the North Sea to spawn in the English Channel than in the 1970s<br />

and 1980s (i.e. more are now spawning in the North Sea), though plankton surveys to confirm<br />

this are lacking.<br />

Page 14 of 151


Recruitment<br />

Bass post-larvae resulting from offshore spawning recruit from June onwards into coastal and<br />

estuarine nursery habitats (Jennings and Pawson, 1992; Reynolds, Lancaster and Pawson,<br />

2003). The survival of sea bass through the first winter is reduced at temperatures below 5–<br />

6°C (Kelley, 2002; Lancaster, 1991), which may well explain the attraction of warm water for 0group<br />

(first year) sea bass, especially in cold winters in the North Sea, where they may<br />

otherwise not survive(Kelley, 1986; Pawson and Eaton, 1999). Incidental catches of juvenile<br />

bass taken during demersal fish surveys (DFS) suggest that the estuaries in the south of the<br />

Netherlands (Easter Scheldt and Wester Scheldt) have become increasingly important as<br />

nursery areas for sea bass (ICES, 2008).<br />

Juvenile bass emigrate from these nursery areas at around 36 cm, aged 3-5 years depending<br />

on growth, which is strongly related to summer temperatures (Reynolds et al., 2003). In<br />

contrast to the regular migrations shown by adult bass, a substantial proportion of pre-adult sea<br />

bass emigrate from their respective ―stock‖ areas and disperse widely, and do not necessarily<br />

recruit to their specific parent spawning stock (Pawson et al., 1987; Pickett, Kelley and<br />

Pawson, 2004). It appears that there is considerable mixing of sea bass at this stage<br />

throughout large parts of the populations' range, and pre-adult fish have been observed to<br />

emigrate from the Thames Estuary (southern North Sea) along the English Channel coast and<br />

even into the eastern Irish Sea. After 4-7 years, or at approximately 35 cm for males and 42 cm<br />

for females, sea bass attain maturity (Pawson and Pickett, 1996).<br />

Feeding<br />

Bass are opportunistic predators throughout life, feeding on the species of crustaceans and<br />

fish which are the most readily available in any particular environment (Pickett and Pawson,<br />

1994). Bass larvae feed on small zooplankton whilst 0-group bass take larger, epibenthic<br />

organisms that are abundant in the near-shore environment, particularly small crustaceans<br />

(Roblin and Brusle, 1984).Whilst small fish such as gobies and juvenile herring and sprat are<br />

found more regularly in the diet as the bass grow, crabs are the most common food of juvenile<br />

bass in UK waters, followed by brown shrimp Crangon crangon. Pickett and Pawson (1994)<br />

found shore crab (Carcinus meanas) and brown shrimp occurring at a similar frequency<br />

(around 40% of stomachs) in the southern North Sea, with relatively few fish, though they did<br />

note a predominance of fish (particularly mackerel Scomber scombrus) in the diet of adult bass<br />

taken 10-30 miles offshore in the western English Channel. Low temperatures inhibit feeding in<br />

juvenile bass (Lancaster, 1991), whilst adults continue to feed throughout the year, except<br />

possibly when spawning (Pawson and Pickett, 1996).<br />

Climate effects on sea bass production in the North Sea<br />

Studies on the migration of sea bass in the late 1970s and early 1980s around the coasts of<br />

England and Wales, and on the species‘ reproductive physiology (Devauchelle, 1984) and the<br />

distribution of bass eggs in relation to water temperature (Thompson and Harrop, 1987), were<br />

used by Pawson et al. (1987) to suggest that the southerly/westerly migrations between<br />

summer feeding areas (in the North Sea and the offshore spawning areas in the English<br />

Channel were related to the necessity for adult female bass to seek out water above<br />

approximately 9 C, both for final gonad maturation and spawning. Pawson, Pickett and<br />

Witthames (2000) showed that ambient water temperatures in winter strongly influence the<br />

onset of maturity in female bass, so that females that stayed in the North Sea are unlikely to<br />

mature until they either adopt the autumn migrations to the south west, or if warmer winters<br />

occur.<br />

Page 15 of 151


This hypothesis was tested in 2000 and 2001 by Pawson et al. (2007a), who tagged over 4000<br />

adult bass inshore around the coasts of England and Wales during summer and autumn and<br />

on the offshore spawning grounds in winter. Whereas all winter recaptures of adult bass<br />

tagged in the North Sea during the late 1970s and early 1980s were reported from the offshore<br />

fishery in the western Channel (Pawson et al., 1987), no ―North Sea‖ fish were reported there<br />

in the more recent study. In addition, the proportion of adult bass tagged inshore reported from<br />

within the UK 3-mile zone between November and April in 2000 – 2005 (30%) was much<br />

higher than in the 1980s (10%), with some fish being recaptured in these areas as late as<br />

February. This suggests that the duration of residence of adult bass in summer feeding areas<br />

may have lengthened, and has allowed bass to spawn much further to the east and north (i.e.<br />

in the North Sea) rather than in the main spawning areas in the English Channel.<br />

The bass is towards the northern limit of its distribution in waters around England and Wales,<br />

and its growth is also affected by temperature. The main growing season is between June and<br />

October, and there is good evidence for a close correlation between the growth of juvenile bass<br />

and temperature (Kelley, 1988; Pawson, 1992). This suggests that growth in summer is faster<br />

in shallow sea areas (e.g. the southern North Sea) than on western, oceanic coasts, and that<br />

warmer winters towards the northwards edge of their distribution range might be expected to<br />

enhance survival of first-year bass (Kelley 1986; Pawson and Eaton 1999, Pawson and Pickett,<br />

1996). This fits well with the hypothesis (Pawson, 2008) that climate warming has resulted in<br />

an expansion of the distribution range of bass stocks around the English and Welsh coasts,<br />

through a combination of a northerly and eastwards shift of spawning areas (where water of<br />

>8-9 C is available through January – April) and enhanced growth and survival of juveniles.<br />

This, in turn, has contributed to an increased in the population‘s abundance since the early<br />

1990s, mediated through temperature influences on the reproductive biology of bass and the<br />

species‘ propensity for a dispersive pre-adult stage and migratory behaviour that capitalises on<br />

favourable environment change. The combined effect would enable self-sustaining bass<br />

populations to become established in areas not previously occupied by the whole of the<br />

species‘ life cycle, in the North Sea, for example, and enhance production generally.<br />

2.2 Overview of the fishery<br />

2.2.1 History of the fishery<br />

In North-west Europe, sea bass have traditionally been caught in a directed fishery between April<br />

and November, from small boats using a variety of fishing methods close to the shore and by<br />

anglers operating from boats and the shore. Since the early 1980s, French mid-water pairtrawlers<br />

and (more recently) British vessels have targeted pre-spawning and spawning<br />

aggregations of adult bass in winter offshore in the western English Channel, eastern Celtic Sea<br />

and Bay of Biscay (Pawson et al., 2007b).<br />

The landings of sea bass by French vessels in North West European waters were around 2000 t<br />

during the period 1986–1995 and have increased to around 4000–5000 tonnes (t) in the most<br />

recent years, due mainly to the increased catch in the southern North Sea (ICES Divisions IVc)<br />

and eastern English Channel (VIId). Commercial landings of bass into the Netherlands from the<br />

North Sea were below 10 t until1997, but they rose rapidly to above 300 t by 2005.<br />

The international commercial landings of sea bass from ICES Divisions IVb,c and VIId are<br />

shown in Table 1.<br />

Table 1. Nominal landings ( t) of bass by country in ICES Divisions IVb, c, and VIId, and<br />

additional UK catch 1 according to the CEFAS logbook scheme, 1984– 2008 (Source: ICES<br />

Bulletin Statistique).<br />

Page 16 of 151


Year Belgium Denmark France Netherlands Scotland UK (Engl.<br />

& Wales)<br />

1984<br />

1985<br />

1986<br />

1987<br />

1988<br />

1989<br />

1990<br />

1991<br />

1992<br />

1993<br />

1994<br />

1995<br />

1996<br />

1997<br />

1998<br />

1999<br />

2000<br />

2001<br />

2002<br />

2003 133<br />

2004 119<br />

21<br />

175<br />

151<br />

85<br />

104 8<br />

1 147 2<br />


also comprised a substantial part of the overall landings in the UK, and estimates for 1986/7<br />

(Dunn et al., 1989) and 1992/3 (Dunn and Potten, 1994) from English and Welsh waters show<br />

similar values (around 415 t). Dutch recreational landings of sea bass from the North Sea in<br />

2006 were estimated at 195 t (Kroon, 2007).<br />

2.2.2 Fleet and Gear Description<br />

Along the western shores of the North Sea, commercial rod and line fishing takes place near<br />

warm water discharges from power stations on the Scottish east coast and in north-east<br />

England, where landings of trawl-caught bass have increased significantly since 2003. Bass<br />

are also taken in set nets and as a by-catch along with cod Gadus morhua and sea trout Salmo<br />

trutta. Along the English coast in Division IVc, from Norfolk southwards, bass are often caught<br />

as part of a mixed fishery in drift nets, fixed nets, trawls, longlines and rod and lines (Walmsley<br />

& Pawson 2007). Bass may be specifically targeted in the local estuaries and around wrecks<br />

and offshore banks. The fishing season in this area normally lasts from April until November.<br />

French and Belgian trawlers may also take bass as a valuable by catch in the southern North<br />

Sea.<br />

Until recently, sea bass was not a target species for professional fishermen along the eastern<br />

coast of the North Sea, and was mainly taken as a by catch in the beam-trawl fishery.<br />

However, with the reduction of quotas for target species like sole and plaice, and increasing<br />

prices for sea bass, the fishery now attracts some directed effort from Dutch beam-trawl, flyseine<br />

and twin-rig trawl fishermen. Landings reported in the official catch statistics increased<br />

from virtually zero in the 1990s to 375t in 2008 (see Table 1.)<br />

2.2.3 Dutch rod and line fishery<br />

The UoC is part of a professional rod and line fishery for sea bass (and cod) in the Netherlands<br />

that has developed from a practice where ―recreational‖ fishermen where selling (part) of their<br />

catches. In 2005, the Dutch government prohibited the selling of fish caught with unregistered<br />

fishing vessels, in response to complaints by professional fishermen and their organizations<br />

that the substantial unofficial landings of cod by ―recreational‖ fishermen was considered as<br />

unfair competition. The measure compelled any fisherman that was earning a living from this<br />

practice to register his boat and to acquire quota for cod, at the same time legitimizing the<br />

practice of selling sea bass.<br />

The UoC fishery is operated by the members of the VBHL and is mainly carried out from the<br />

fishing port of the so called ―working island NeeltjeJans‖, though a few boats are based in other<br />

ports in the Provinces of Zeeland and Zuid-Holland.<br />

Page 18 of 151


Map: Southern North Sea, ‗A‘ = Neeltje Jans<br />

The UoC fishing fleet consists of 19 under-10 m boats propelled by high-powered inboard or<br />

outboard motors (5 vessels have an engine power of more than 200 KW). The fishery takes<br />

place up to 70 miles from the home port, and uses high speed boats that normally make oneday<br />

trips and fish mainly during daytime. The fishery is carried out between March and<br />

December from an anchored boat near shipwrecks and other obstacles on the sea floor that<br />

attract concentrations of bass and cod, and which are located using GPS. The boats normally<br />

carry two or three crew, occasionally four, each using a single rod and line fishing with artificial<br />

bait (lures and pirks), but occasionally with natural baits, such as ragworm (Nereis spp),<br />

lugworm (Arenicola spp) or razor shells (Ensis spp). From VIRIS sales data, the client<br />

estimates that the members of the VBHL have been catching around 60 t of sea bass each<br />

year, as shown below.<br />

2006 2007 2008 2009<br />

Sea bass 33.4 56.4 62.3 56.7<br />

Cod 6.1 8.5 13.6 16.1<br />

2. TARGET STOCK STATUS AND HARVEST CONTROLS (P1)<br />

Page 19 of 151


3.1 Analytical assessments<br />

The first analytical examination of any sea bass fishery was a yield per recruit (Y/R) analysis<br />

carried out using catch-at-age data in three métiers (gear groups, within which the species<br />

composition in the catch is relatively consistent) - trawls, nets and lines (including recreational<br />

rod-and-line) - in the UK sea bass fishery in ICES Division VIId (Pawson et al., 2005). The<br />

results showed that increasing length at first capture above 36 cm (the current EU minimum<br />

landing size, MLS) would produce small gains in Y/R up to about 46 cm, above which potential<br />

yields increase only if the level of fishing mortality (F) is also increased.<br />

In 2003, the ICES Bass Study Group (SGBASS) used the SURBA program with data on UK<br />

and French bass catch-at-age and fishing effort by métier groups (trawls, nets and lines) for<br />

four stock areas (Divisions IVb,c; VIId; VIIe,h; VIIa,f,g) for which sufficient biological sampling<br />

information was available over the period 1985–2002 (ICES, 2004). A separable model was<br />

used to provide independent assessments of the status of each stock, which indicated trends in<br />

spawning-stock biomass (SSB) within stocks, and similar recruitment patterns between stocks.<br />

Estimates of F using SURBA were considered to be less informative, largely because of a lack<br />

of independence between the selectivities estimated for the fishery and the indices of catch per<br />

unit of effort (cpue: actually based on landings, but discards of sea bass are usually negligible)<br />

used. No biological reference points were proposed at this time.<br />

No update on these assessments has been carried out using international data, but Cefas<br />

developed a multi-métier, fully statistical, separable model using UK fishing effort and catch<br />

numbers-at-age data for three métiers (i.e. trawls, nets, and lines) in four areas (ICES Divisions<br />

IVb,c; VIId; VIIe; VIIa,f,g;) over the period 1985-2004 (Pawson et al. 2007b). Although there is<br />

little information on bass discards, they are thought to be either insignificant (in nets) or to<br />

survive on being returned to the water (from lines).<br />

Catch and fishing effort data<br />

Prior to implementation of the Buyers and Sellers regulation in 2005 (MMO, 2010), the official<br />

statistics grossly underestimated the quantities of bass landed in England and Wales (Pawson<br />

et al., 2007b). A considerable proportion of the UK bass catch taken by commercial small-boat<br />

fisheries and by the recreational sector is sold directly to restaurants or small merchants, and<br />

the official statistics may record as little as 20% of actual landings. The best estimates of<br />

annual catch and effort have been obtained by integrating official statistics, derived from<br />

landings declarations and local market sales at the 60-70 major ports, with estimates of total<br />

landings by inshore fishing vessels, including charter and casual angling boats, obtained from<br />

a voluntary logbook scheme administered by CEFAS for the England and Wales


Size and Age data<br />

Analytical assessment methods usually rely on data on the length and/or age distributions of fish<br />

in the landed catch. In the UK, a biological sampling programme for sea bass has been run in<br />

conjunction with the CEFAS logbook scheme, in which length data are collected either from the<br />

whole landing from small vessels, often at fish merchants, or from markets by size category,<br />

against targets set by gear group (i.e. demersal trawls, gillnets, lines, and pelagic trawls). Sea<br />

bass are easily aged using scales (Kelley, 1988), and length-stratified ―all gears‖ scale samples<br />

of at least 150 fish are used to provide corresponding half-yearly age-length keys for each stock<br />

area. Sex ratio, maturity, and length-weight conversion factors are derived from biological<br />

sampling carried out between 1982 and 1990 (Pawson and Pickett, 1996).<br />

Recruitment<br />

A robust time-series of data on year-class strength of pre-recruit bass has been provided by a<br />

trawl survey in the Solent nursery areas (central English Channel), where a standard grid of 35<br />

stations has been fished over a 4-day period at the same part of the tidal cycle (falling Springs)<br />

in May and September each year since 1984 (Pickett et al., 2002). Numbers of each year<br />

class caught at ages 2, 3, and 4 in up to 6 successive surveys are used to derive abundance<br />

indices (Pawson, 1992), which have been shown to correlate well with model-derived<br />

recruitment patterns to the bass fishery in Division VIId (Pawson et al., 2007b).<br />

A similar fishery-independent trawl survey of bass has taken place across a standard grid of 35<br />

stations in the Thames Estuary in November each year since 1995, from which indices of yearclass<br />

strength of the bass population in the southern North Sea are available, Figure 3 (source<br />

CEFAS). This index of recruitment is not used in the stock assessment, but acts as a fisheryindependent<br />

validation. It becomes more robust as each year class is caught at ages 0,1,2,3<br />

and 4, hence the provisional estimates for 2006 onwards. Both these surveys were<br />

discontinued in 2010, due to cost cutting.<br />

Page 21 of 151


Figure 3.Indices of the abundance of juvenile bass year-classes in the Thames Estuary (IVc),<br />

1994-2008 (source CEFAS).<br />

Fishery-independent estimates of relative abundance of juvenile bass year classes are also<br />

available from a trawl survey (actually using a 3-m beam trawl to sample pre-recruit flatfish)<br />

conducted in the Westscheldt Estuary (IVc) by IMARES each year, Figure 4 (source Henk<br />

Heessen, WGNEW). These also show an increasing trend in year class strength since the<br />

early 1990s, though the pattern is not the same as that in the Thames Estuary survey, probably<br />

because different age groups are used in calculating the indices (0-groups especially can suffer<br />

high mortality in cold winters).<br />

N per hour<br />

120<br />

100<br />

80<br />

60<br />

40<br />

20<br />

Figure 4. Indices of the abundance of juvenile bass year classes in the Westscheldt Estuary<br />

from the IMARES DFS (source Henk Heessen, WGNEW).<br />

3.2 Stock status<br />

Sea bass Westerscheldt<br />

0<br />

1970 1975 1980 1985 1990 1995 2000 2005 2010<br />

The results of the fleet-based separable model for the sea bass stock unit (Divisions IVb,c) that<br />

includes the southern North Sea indicate levels of F around 0.2–0.4 between 1995 and 2004<br />

(Pawson et al., 2007b). The gear selectivity patterns derived from the model confirm the results<br />

of Pawson et al. (2005).The abundance of adult bass (SSB) in the North Sea appears to have<br />

remained stable between 1985 and 2004, whilst there has been an increased level of recruitment<br />

from 1989 onwards.<br />

The patterns in F and recruitment derived from this model are consistent with the evidence<br />

provided by the CEFAS logbook scheme and the fishery-independent pre-recruit survey (which<br />

has not been used in the model), but there are inevitable problems with the scaling of F and<br />

estimating biomass. In particular, the absence of data for the recreational rod-and-line fishery,<br />

a substantial contributor to mortality on the younger sea bass, would affect estimates of<br />

recruitment to the commercial fishery. However, these are consistent between areas over the<br />

period 1984–2002, and that for VIId closely matches the fishery-independent abundance<br />

indices for pre-recruit bass provided by the Solent trawl survey that covers the main nursery<br />

areas for sea bass in Division VIId. Thus, whilst the model reflects reasonably the dynamics of<br />

the bass stock (around the UK) both in stock numbers, SSB and in F, it is not possible to<br />

Page 22 of 151


estimate the absolute size of the stock or fishing mortality level. These values are, therefore,<br />

not reproduced here.<br />

Kupschus, Smith and Walmsley (CEFAS) presented an update of the UK assessment of stock<br />

status of bass as a Working Document in the ICES WGNEW 2008 report. Because there is a<br />

belief that the introduction of the ‗Buyers and sellers‘ regulation in 2005 has improved the<br />

reliability of FAD data, Kupschus et al. (2008) aimed to compare assessments using datasets<br />

from the official Defra FAD and the CEFAS logbook scheme, and to examine the implications of<br />

using only the former for providing advice on management of sea bass fisheries. The<br />

assessment used the fleet-based separable model described by Pawson et al. (2007b), with<br />

the addition of data for two more years (2005 & 2006).<br />

The results of the updated assessment were in good agreement with previous assessments for<br />

the period up to 2004. Landings of bass by UK vessels from the North Sea remained relatively<br />

high, whilst bass stock levels were estimated to have remained near the series maximum<br />

between 1997and 2006. Comparison between Cefas logbook and FAD-only based<br />

assessments indicate that F levels remained stable in 2004 - 2006 in the North Sea.<br />

Recruitment was good during the mid to late 1990s and this has resulted in the high landings<br />

and stock levels since 2003. The FAD-only assessment indicates relatively higher recent year<br />

class strengths in the North Sea, and is in line with the Thames pre-recruit index which<br />

suggests the 2002 and 2003 year classes were particularly strong (see Figure 4).<br />

The most recent update of the sea bass assessment carried out for WGNEW 2010 used the<br />

FAD-only model and added data for 2007-2009. Although the more recent information seems<br />

to have become more variable, and Kupschus (2010) warns that the assessments are<br />

increasingly uncertain, SSB in the North Sea and eastern channel appears to have continued<br />

to increase.<br />

3.3 Harvest controls<br />

3.3.1 Management unit<br />

The assessment areas (Figure 2) used by ICES (2009) are based on a consideration of both<br />

the current patterns of seasonal movements of bass in the exploited populations (i.e. >36 cm),<br />

as indicated by tag recaptures, and the characteristics of the seasonal fisheries taking them<br />

(Pawson et al., 2007a). The bass population in the North Sea (ICES Divisions IVa,b,c) is<br />

considered to be a single management unit, although there is some movement of both juvenile<br />

and adult sea bass between the North Sea and the English Channel. The main area of<br />

exploitation of this ―stock‖ is in ICES Divisions IVc (southern North Sea) and VIId (eastern<br />

English Channel).<br />

3.3.2 Management advice<br />

From a management viewpoint, assessment results (Pawson et al., 2007b; Kupschus et al.<br />

2008; Kupschus, 2010) suggest that sea bass in ICES Divisions IVb,c are being exploited<br />

sustainably, at a moderate level of F and with an exploitation pattern that gives a near maximum<br />

yield per recruit, and that this has led to an increase in exploitable biomass since the early<br />

1990s.<br />

Kupschus et al. (2008) and Kupschus (2010) point out that, since it is difficult to quantify the<br />

process errors in the current models used for sea bass, these assessments are unsuitable for<br />

Page 23 of 151


short-term forecasts and setting TACs. However, the output can still be used to give sound<br />

precautionary management advice in relation to stock status and sustainability. For example,<br />

selectivity patterns in the UK fishery have already been used in simulations of increases in the<br />

size at which bass are first exploited (due to a potential increase in MLS) to indicate the relative<br />

magnitude of changes in yield to the various métiers and in the age structure of the underlying<br />

bass population (M. Smith, Cefas, pers. comm.). The results were similar to and updated those<br />

obtained by Pawson et al (2005), indicating that Y/R gains (and losses) with progressive<br />

increases in the MLS (above 36 cm) were gear specific, but were likely to provide most benefit<br />

to rod-and-line fisheries and least to trawl and net metiers.<br />

3.3.3 Biological reference points<br />

The common patterns in the recruitment time-series for sea bass ―stocks‖ in the North Sea,<br />

English Channel, and along the west coast of England and Wales indicate that sea bass<br />

populations around England and Wales are linked biologically (see Pickett et al., 2004) and/or<br />

that recruitment is controlled by large-scale environmental patterns. It is known that warm or<br />

cold summers and winters can have a considerable influence on the survival of 0-group bass<br />

through their first year (Kelley, 1986), and that strong year classes are associated with higher<br />

temperatures (Pawson, 1992; Pawson, 2008) rather than SSB. There is, therefore, no stockrecruit<br />

relationship for bass that could be modelled, either to explain past or to predict future<br />

recruitment patterns (Pawson et al., 2007b). The relative size of the spawning stock bears no<br />

relationship to past recruitment over the period for which data are available (1984 – 2008),<br />

which means that it has not been possible to set absolute or even relative reference points<br />

based on stock-recruit considerations. There is, however, no sign of recruitment-overfishing,<br />

and management decisions have been taken based on considerations of Y/R and MSY in<br />

relation to exploitation patterns (essentially F-at-age, based on a good knowledge of biological<br />

parameters and local fishing patterns).<br />

3.3.4 Scientific background to management advice for sea bass<br />

Research on the sea bass and its fisheries started in the 1970s, when recreational anglers in<br />

particular began to be concerned for the future of the bass stocks around the coasts of<br />

England, Wales and Ireland. What little was known of its biology was, nevertheless, sufficient<br />

to indicate that protection of juveniles was bound to assist conservation of bass (Holden and<br />

Williams, 1974). Though ICES established a study group in 2001 to respond to the European<br />

Commission‘s request for information on sea bass fisheries, stock identity, assessment data<br />

and conservation requirements in European waters (ICES, 2002), there was no assessment of<br />

the size of the bass population - even in relative terms - and of its productivity and mortality<br />

rates until 2003, and thus any restraint on exploitation (if this was necessary) could not be<br />

justified on the basis of an analytical assessment.<br />

In the UK, however, a scientific recommendation to increase the sea bass MLS above the then<br />

current 26 cm (Holden and Williams, 1974) resulted in a dedicated research programme<br />

initiated by Cefas in 1981, the publication of a summary of the results of which (Pawson and<br />

Pickett, 1987) served as an aide memoir for forthcoming discussions and consultations on<br />

management measures. This included a Y/R analyses that showed strong evidence of growthoverfishing<br />

in many areas around English and Welsh coasts, owing to local fisheries targeting<br />

3-5 year-old sea bass in and around harbours and estuaries. It was concluded that an MLS of<br />

36 cm would satisfy the management objective of reducing growth-overfishing, whilst allowing<br />

some important small-boat fisheries to remain viable.<br />

Page 24 of 151


Bearing in mind the vulnerability to capture of juvenile sea bass, additional measures were<br />

needed to support a higher MLS. Conventionally, a minimum mesh size that effectively<br />

complements the MLS would help fishermen minimise the number of undersized fish they had<br />

to discard from their catch. Catch data from gill nets showed that they are highly selective for<br />

sea bass (Reis and Pawson, 1992), and it was proposed that a minimum mesh size of 90 mm<br />

(stretched mesh, measured knot to opposite knot) be introduced for all enmeshing gears,<br />

chiefly because of the difficulty in identifying a bass gill net fishery. Because fisheries for the<br />

small pelagic species - sprat, Sprattus sprattus, herring, Clupea harengus, mackerel and<br />

pilchard Sardina pilchardus -would not be viable with a 90 mm minimum mesh size, a banned<br />

range of mesh sizes (65 - 90 mm) was proposed for enmeshing nets used in England and<br />

Wales, which would allow these fisheries for continue.<br />

The most radical part of the bass management measures proposed for the UK was a restriction<br />

on fishing activities that were likely to take sea bass in areas where most fish in the local<br />

population were below 36 cm. These came to be known as the bass "nursery areas", in which<br />

juvenile fish of 3-5 years old are found in sheltered or enclosed inshore areas (i.e. estuaries,<br />

inlets and harbours) for most of the year, and where tagging had shown exploitation rates as<br />

high as 50% (Pawson et al., 1987). Prior to the period of ―climate warming‖ in the winters of<br />

1988 - 1990 (Pawson, 1992), the susceptibility of 0-group sea bass to low temperatures in<br />

winter (Lancaster, 1991) meant that potential nursery habitats on the North Sea coast were<br />

unlikely to contain sufficient small sea bass in most years to merit protective measures in<br />

addition to MLS and mesh size controls. The main exceptions are where small sea bass are<br />

attracted to warm water discharged from coastal power stations, such as at Kingsnorth in the<br />

Medway Estuary and Bradwell in the Blackwater Estuary, Essex (Turnpenny, 1988).<br />

A package of technical measures was introduced in England and Wales in 1990, which made it<br />

illegal to land bass


The landings of cod by the UoC are counted against the cod quota that has been established<br />

in the framework of the cod recovery plan, although in 2009 they represent less than 0.1 % of<br />

the total cod TAC for ICES Area IV (33,600 t). ICES evaluated the EU long-term cod recovery<br />

plan in 2009 and concluded that it is in accordance with the precautionary approach if<br />

implemented and enforced adequately (ICES, 2010). The rules of the cod recovery plan have<br />

been applied to the 2010 cod TAC.<br />

According to the client, cod that are smaller than the EU minimum landing size (35 cm) and are<br />

discarded represent less than 5 % of the cod catch. On this basis, it is clearly highly unlikely<br />

that the levels of cod landed or discarded by the UoC will have a significantly negative impact<br />

on the objective of rebuilding the North Sea cod spawning stock biomass.<br />

Table 2. Landings (kg) of sea bass, cod and pollack by the members of the VBHL in the period<br />

2006-2009, and by catch percentage (source VIRIS).<br />

2006 2007 2008 2009<br />

sea bass 33,446 56,431 62,322 56,716<br />

cod 6,076 8,478 13,641 16,101<br />

% cod 18.2 15.0 21.9 28.4<br />

pollack 37 123 525 150<br />

% pollack 0.1 0.2 0.8 0.3<br />

Picture 4. By catch: Pollack<br />

Pollack is caught in limited numbers and retained. The highest catches were in 2008, when 525<br />

kg were landed, less than 1 % of the total landings of sea bass. Therefore, pollack is not<br />

considered as a main retained species in this fishery. There is no TAC for pollack in ICES area<br />

IV (North Sea).<br />

Ling (Molva molva) and gurnard (Triglidae) are also caught occasionally, but the quantity of<br />

these catches and their effect on the species‘ stocks are negligible.<br />

Page 26 of 151


4.2 Discarding<br />

The client fishery is a very clean fishery, and all there is no discarding of species other than<br />

those that might be retained and landed.<br />

4.3 Endangered, threatened and protected species (ETP)<br />

Very occasionally a shark is caught in this fishery. The official VIRIS data show that one shark<br />

was landed in 2008. Sometimes a sea bird (gull) gets itself entangled in the fishing line, but<br />

these birds are released unharmed.<br />

4.4 Habitat<br />

The only potential impact from this fishery on North Sea habitat is due to anchoring on the sea<br />

floor. The anchors used in this fishery are relatively lightweight since the boats are relatively<br />

small. The seafloor and habitat structures in the southern North Sea are not considered<br />

sensitive to the impact of anchoring.<br />

4.5 Ecosystem impacts<br />

The only impact of this fishery on the ecosystem is the removal of predatory fish (sea bass, cod<br />

and pollack) from the ecosystem. It is considered highly unlikely that the quantities involved will<br />

affect ecosystem structure, trophic relationships or biodiversity to a point where there would be<br />

a serious or irreversible harm.<br />

The artificial baits used in this fishery usually contain lead, which is known to be toxic when it is<br />

accumulated in animal tissue in high concentrations. Sometimes a bait will get stuck on<br />

structures on the seafloor like rocks or wrecks and consequently lost. Although this can be<br />

considered a minor issue, the VBHL is currently looking into possibilities to replace the lead in<br />

the baits with another metal (steel).<br />

3. FISHERY MANAGEMENT FRAMEWORK (P3)<br />

5.1 Legislation and regulation<br />

The Netherlands are a Member State of the European Union (EU), and its fishery is subject to<br />

the principles and practices of the Common Fisheries Policy (CFP). The fishery is managed<br />

through the CFP in accordance with the basic Fisheries Regulation (2371/2002). In force since<br />

1983, the CFP aims to reconcile resource conservation with the preservation of income and<br />

jobs in coastal zones that offer few alternatives in terms of production or employment. It<br />

therefore covers not just resources but also markets and structures. The CFP was reviewed<br />

thoroughly in 2002.<br />

The basic Fisheries Regulation is a ‗chapeau‘ regulation, setting out the strategic aims of the<br />

CFP and enabling the <strong>Council</strong> of Ministers or, in certain cases, the European Commission<br />

(EC), to make more detailed regulations. These include ones dealing with control requirements,<br />

fleet structure, technical conservation, marketing and annual total allowable catches (TAC) etc.<br />

Implementation of the CFP at a national level is carried out through the individual Member<br />

States, whose fisheries enforcement authorities co-operate in policing the fishery (e.g. satellite<br />

Page 27 of 151


monitoring, landing recording, etc.). National fisheries administrations are responsible for a<br />

range of management and regulatory duties, including management of fleet activity and of<br />

national quota, monitoring and control of all fisheries occurring within national jurisdiction,<br />

collection, collation and transmitting of key fishery data, and undertaking at least a base range<br />

of scientific monitoring and development work.<br />

The general legislative instrument of fisheries management in the Netherlands is the Fisheries<br />

Act (Visserijwet 1963). The Fisheries Act establishes powers and responsibilities to regulate<br />

the Dutch fishery. The Minister of Economic Affairs, Agriculture and Innovation is empowered<br />

by the Royal Act (KoninklijkBesluit) ―Reglement Zee- en Kustvisserij‖ to regulate the fishery by<br />

establishing closed areas, closed times, quota, minimum landing sizes etc. Important<br />

regulations include the ―Beschikkingvisserij, visserijzone, zeegebied en kustwateren‖ and the<br />

―Regelingvangstbeperking‖, in which the fishing areas and fishing gears are legally defined.<br />

Sea bass catches are not regulated by the EU through TACs, and there are no other direct<br />

controls on either the catch or fishing effort in sea bass fisheries.<br />

The EU set a minimum landing size of 36 cm for sea bass in 1990 in Regions 2 and 3 of<br />

Community waters. <strong>Council</strong> Regulation 850/1998 prohibits the use of fixed gill nets with a mesh<br />

size between 70 and 90 mm (to protect juvenile sea bass). Though mesh size controls for<br />

towed gear fisheries in which bass is a target species are included in this regulation, most bass<br />

are taken as a by catch in towed gears for which mesh size controls depend on other target<br />

species.<br />

In the Republic of Ireland, sea bass has been designated as a sport fishing species since<br />

1990. Commercial fishing is effectively banned by a bag limit of 2 sea bass per fisher in a 24<br />

hour period, and there is a closed season from May 15 to June 15 and a minimum size of 40<br />

cm.<br />

In France, a national regulation limiting bass landings by French pelagic trawlers fishing in the<br />

English Channel was set up in 1996, and sea bass landings by all French trawlers have been<br />

limited to 5t/boat /week from 1 January to 30 April since 1998.<br />

There are no bass-related local regulations in Scotland, but the weekly landing limit of 5 t per<br />

vessel adopted for French trawlers in 1998 was adopted by the UK (largely for Scottish vessels<br />

working in VIIe) in 2000 to prevent excessive landings in the winter offshore fishery.<br />

There are no species-specific regulations protecting sea bass in the Netherlands other than the<br />

EU minimum landing size and fixed-net mesh size controls.<br />

5.2 Roles & Responsibilities<br />

There are several relevant organisations and bodies that take an active role in the fishery<br />

under assessment.<br />

Netherlands Industry Representation<br />

The most important tier of industry representation in the Netherlands is provided by the<br />

National Fishermen Organisations. For the cutter fleet, these are the NederlandseVissersbond<br />

and the Federatie van Visserijverenigingen, both of which are closely linked with one or more<br />

Producers Organisations. A few members of the VBHL are members of the<br />

NederlandseVissersbond.<br />

Regional Advisory <strong>Council</strong>s<br />

Page 28 of 151


The creation of Regional Advisory <strong>Council</strong>s (RACs) was one of the pillars of the 2002 reform of<br />

the CFP, in response to the EU and stakeholders‘ desire to increase the latter‘s participation in<br />

the CFP process. The RACs are made up of representatives of the fisheries sector and other<br />

stakeholder groups affected by the CFP, while scientists are invited to participate in the<br />

meetings of the RACs as experts. The Commission and regional and national representatives<br />

of Member States may be present at the meetings as observers. The North Sea Demersal<br />

RAC has greatly improved effective communication links between industry, NGO‘s, managers<br />

and scientists. The sea bass fishery does not appear to have been discussed within the North<br />

Sea RAC.<br />

Scientific Advice<br />

The scientific basis for the management of the sea bass fishery is the advice provided by the<br />

ICES Advisory Committee (ACOM), which draws on the work of international scientists from<br />

relevant research laboratories and institutions on fish stock biology and marine science.<br />

The results of scientific research and assessments are co-ordinated, compiled and reported by<br />

ICES Working Groups, in this case WGNEW, which ICES established in 2005 to provide the<br />

EC with advice on stock status and management of so called MoU (Memorandum of<br />

Understanding) species (including sea bass). Prior to this, sea bass had been covered by the<br />

ICES Bass Study Group (2001– 2004). The reports are reviewed and evaluated by the ICES<br />

Advisory Committee (ACOM), which then provides advice on the status of target and nontarget<br />

stocks to the European Commission. ICES advice, via Commission proposals, informs<br />

the annual EU <strong>Council</strong> of Ministers regulation establishing management measures, in particular<br />

TACs and quotas.<br />

Stock assessment and data gathering methodologies are regularly reviewed - at ICES level<br />

and at the level of the contributing laboratories and research institutions. Within ICES, a<br />

methods working group keeps methods for fish stock assessment under regular review, and<br />

there are specific working groups dealing with various issues relevant to the fishery.<br />

In The Netherlands and the UK, IMARES and CEFAS are the main institutes working in the<br />

area of fisheries science and, specifically, sea bass. Their scientists are closely involved in the<br />

stock assessment work of ICES, and contribute to WGNEW.<br />

National Management Bodies<br />

The Fisheries Directorate (DirectieVisserij) of the Dutch Ministry of Economic Affairs,<br />

Agriculture and Innovation (Ministerie van EconomischeZaken, Landbouw en Innovatie (EL&I)<br />

is the main fisheries management body in The Netherlands.<br />

5.4 Monitoring, Control and Surveillance<br />

EU and national legislation is monitored and enforced in The Netherlands by the General<br />

Inspection Service (AlgemeneInspectiedienst, AID) of the Ministry of EL&I. The AID is<br />

responsible for enforcing fishery regulations and collecting information on fishing activity and<br />

catches in ports and at sea within the nation state‘s fishery limits, and also monitors<br />

compliance by the fishing industry. The AID also applies the EC satellite Vessel Monitoring<br />

System (VMS) to track vessels over 15 m overall length. Fishing effort (days at sea) is also<br />

monitored by the flag state through the VMS. Inspections at sea are carried out by the flag<br />

state or the state with national jurisdiction over the area. At sea, gear (mesh size), logbooks<br />

and content of fish holds are checked. National authorities are also responsible for aggregating<br />

national fleet catches to a national total and policing other EC control requirements applicable<br />

on landing and as the fish moves through the distribution chain. Given its small vessel size<br />

Page 29 of 151


and use only of rod-and-line, with little threat to national quotas, the UoC operates on the<br />

periphery of this system.<br />

All registered fishing vessels are required to keep logbooks in accordance with EC Regulation<br />

No. 2807/83 (and subsequent amendments). Fishing vessels under 10 m overall length are<br />

obliged to record all quantities of all species kept on board on daily log sheets. At least half an<br />

hour before entering a port, and immediately before landing the fish, a rod-and-line fishing<br />

vessel has to notify the local authorities (AID). After entering a port, fishing vessels have to<br />

deliver a log sheet with all landed quantities and species to the AID (in a special post box).<br />

5.4 Compliance<br />

Non-compliance is dealt with by the relevant Dutch authorities through their criminal justice<br />

systems, and using agreed and tested procedures. Dutch fishery officials (LNV) report no<br />

compliance issues specific to the UoC vessels. Communication within the group is good and<br />

they act as one to ensure overall compliance.<br />

The client considers that there is insufficient control effort directed at vessels under 10 m. They<br />

have mentioned that there are several unregistered vessels using rod and line that land sea<br />

bass and cod with the intention of sale, which is prohibited under the official regulations.<br />

5.5 Dispute resolution<br />

Disputes that arise are initially dealt with by individual fishermen and inside the VBHL. In the<br />

latter case, the Klapwijkfirm located in Burgh Haamstede plays an important role. The level of<br />

social control is relatively high since the majority of the members depend on a group marketing<br />

system. The fish landed by most members are collected at the Klapwijk firm facility, labelled<br />

there and transported to the IJmuiden auction.<br />

Just two of the members of the VBHL are a member of a national fishermen‘s organisation.<br />

The Dutch national organisations are also linked to a Producers Organisation (PO). The<br />

membership of a PO could be advantageous in resolving disputes.<br />

The Ministry of Economic Affairs, Agriculture and Innovation and national representatives<br />

(Embassies) will be involved when serious international disputes arise that cannot be solved at<br />

a lower level.<br />

All EU member states have signed up to CFP, and are bound by European legislation.<br />

Disputes between Member States and the Commission are resolved in the <strong>Council</strong> of<br />

Ministers. Where appropriate, European legislation is enacted at the national level through<br />

relevant primary and secondary legislation. Formal procedures apply for the resolution of<br />

disputes through the national court systems.<br />

6. Other fisheries in the area affecting the target stock<br />

In the North Sea, the main commercial catch of sea bass taken in directed fisheries is by drifted<br />

and fixed gillnets and by rod and line operating along the English and Dutch coasts (Dutch<br />

landings were around 30 t in 2009). The main fishing season normally lasts from April until<br />

November.<br />

French and Belgian trawlers also take substantial quantities of sea bass in the southern North<br />

Sea, chiefly as a by catch in demersal fisheries (see Table 1).<br />

Page 30 of 151


Sea bass is taken as a by catch in several Dutch fisheries. Landings of fly-shooters were nearly<br />

60 t in 2009 and landings of twin riggers about 30 t, whilst nearly 175 t of sea bass were landed<br />

by the Dutch beam trawl fleet (the largest Dutch fleet segment) in 2009. According to<br />

information provided by the client, these landings include catches by several Dutch beam<br />

trawlers from bass shoals that are aggregated near the wrecks were the rod and line fishery<br />

takes place Occasionally, this practice results in several tonnes of sea bass taken in one haul.<br />

The total landings of sea bass by Dutch fisheries in 2009 was 341 t (375 t in 2008, Table 1), of<br />

which the members of VBHL landed nearly 57 t.<br />

Catches of sea bass taken by recreational anglers may also comprised a substantial part of the<br />

overall landings of sea bass from the North Sea. Dutch recreational landings in 2006 were<br />

estimated at 195 t (Kroon, 2007).<br />

Page 31 of 151


7. STANDARD USED<br />

The MSC Principles and Criteria for Sustainable Fisheries form the standard against which the<br />

fishery is assessed and are organised in terms of three principles.<br />

Principle 1 addresses the need to maintain the target stock at a sustainable level.<br />

Principle 2 addresses the need to maintain the ecosystem in which the target stock exists.<br />

Principle 3 addresses the need for an effective fishery management system to fulfil Principles 1<br />

and 2 and ensure compliance with national and international regulations.<br />

The Principles and their supporting Criteria are presented below.<br />

Principle 1<br />

A fishery must be conducted in a manner that does not lead to overfishing or depletion<br />

of the exploited populations and, for those populations that are depleted, the fishery<br />

must be conducted in a manner that demonstrably leads to their recovery.<br />

The intent of this principle is to ensure that the productive capacities of resources are<br />

maintained at high levels and are not sacrificed in favour of short term interests. Thus,<br />

exploited populations would be maintained at high levels of abundance designed to retain their<br />

productivity, provide margins of safety for error and uncertainty, and restore and retain their<br />

capacities for yields over the long term.<br />

Criteria:<br />

1. The fishery shall be conducted at catch levels that continually maintain the high productivity<br />

of the target population(s) and associated ecological community relative to its potential<br />

productivity.<br />

2. Where the exploited populations are depleted, the fishery will be executed such that<br />

recovery and rebuilding is allowed to occur to a specified level consistent with the<br />

precautionary approach and the ability of the populations to produce long-term potential yields<br />

within a specified time frame.<br />

3. Fishing is conducted in a manner that does not alter the age or genetic structure or sex<br />

composition to a degree that impairs reproductive capacity.<br />

Principle 2<br />

Fishing operations should allow for the maintenance of the structure, productivity,<br />

function and diversity of the ecosystem (including habitat and associated dependent<br />

and ecologically related species) on which the fishery depends.<br />

The intent of this principle is to encourage the management of fisheries from an ecosystem<br />

perspective under a system designed to assess and restrain the impacts of the fishery on the<br />

ecosystem.<br />

The sequence in which the Principles and Criteria appear does not represent a ranking of their<br />

significance, but is rather intended to provide a logical guide to certifiers when assessing a<br />

fishery. The criteria by which the MSC Principles will be implemented will be reviewed and<br />

Page 32 of 151


evised as appropriate in light of relevant new information, technologies and additional<br />

consultations.<br />

Criteria:<br />

1. The fishery is conducted in a way that maintains natural functional relationships among<br />

species and should not lead to trophic cascades or ecosystem state changes.<br />

2. The fishery is conducted in a manner that does not threaten biological diversity at the<br />

genetic, species or population levels and avoids or minimises mortality of, or injuries to<br />

endangered, threatened or protected species.<br />

3. Where exploited populations are depleted, the fishery will be executed such that recovery<br />

and rebuilding is allowed to occur to a specified level within specified time frames, consistent<br />

with the precautionary approach and considering the ability of the population to produce longterm<br />

potential yields.<br />

Principle 3<br />

The fishery is subject to an effective management system that respects local, national<br />

and international laws and standards and incorporates institutional and operational<br />

frameworks that require use of the resource to be responsible and sustainable.<br />

The intent of this principle is to ensure that there is an institutional and operational framework<br />

for implementing Principles 1 and 2, appropriate to the size and scale of the fishery.<br />

A. Management System Criteria:<br />

The management system shall:<br />

1. Ensure that the fishery shall not be conducted under a controversial unilateral exemption to<br />

an international agreement.<br />

2. Demonstrate clear long-term objectives consistent with MSC Principles and Criteria and<br />

contain a consultative process that is transparent and involves all interested and affected<br />

parties so as to consider all relevant information, including local knowledge. The impact of<br />

fishery management decisions on all those who depend on the fishery for their livelihoods,<br />

including, but not confined to subsistence, artisan, and fishing-dependent communities shall be<br />

addressed as part of this process.<br />

3. Be appropriate to the cultural context, scale and intensity of the fishery – reflecting specific<br />

objectives, incorporating operational criteria, containing procedures for implementation and a<br />

process for monitoring and evaluating performance and acting on findings.<br />

4. Observe the legal and customary rights and long term interests of people dependent on<br />

fishing for food and livelihood, in a manner consistent with ecological sustainability.<br />

5. Incorporates an appropriate mechanism for the resolution of disputes arising within the<br />

system5.<br />

6. Provide economic and social incentives that contribute to sustainable fishing and shall not<br />

operate with subsidies that contribute to unsustainable fishing.<br />

7. Act in a timely and adaptive fashion on the basis of the best available information using a<br />

precautionary approach particularly when dealing with scientific uncertainty.<br />

8. Incorporate a research plan – appropriate to the scale and intensity of the fishery – that<br />

addresses the information needs of management and provides for the dissemination of<br />

research results to all interested parties in a timely fashion.<br />

9. Require that assessments of the biological status of the resource and impacts of the fishery<br />

have been and are periodically conducted.<br />

10. Specify measures and strategies that demonstrably control the degree of exploitation of the<br />

resource, including, but not limited to:<br />

Page 33 of 151


a) setting catch levels that will maintain the target population and ecological community‘s high<br />

productivity relative to its potential productivity, and account for the non-target species (or size,<br />

age, sex) captured and landed in association with, or as a consequence of, fishing for target<br />

species;<br />

b) identifying appropriate fishing methods that minimise adverse impacts on habitat, especially<br />

in critical or sensitive zones such as spawning and nursery areas;<br />

c) providing for the recovery and rebuilding of depleted fish populations to specified levels<br />

within specified time frames;<br />

d) mechanisms in place to limit or close fisheries when designated catch limits are reached;<br />

e) establishing no-take zones where appropriate.<br />

11. Contains appropriate procedures for effective compliance, monitoring, control, surveillance<br />

and<br />

enforcement which ensures that established limits to exploitation are not exceeded and<br />

specifies corrective actions to be taken in the event that they are.<br />

B. Operational Criteria<br />

Fishing operations shall:<br />

1. Make use of fishing gear and practices designed to avoid the capture of non-target species<br />

(and non-target size, age, and/or sex of the target species); minimise mortality of this catch<br />

where it cannot be avoided, and reduce discards of what cannot be released alive<br />

2. Implement appropriate fishing methods designed to minimise adverse impacts on habitat,<br />

especially in critical or sensitive zones such as spawning and nursery areas.<br />

3. Not use destructive fishing practices such as fishing with poisons or explosives;<br />

4. Minimise operational waste such as lost fishing gear, oil spills, on-board spoilage of catch<br />

etc.<br />

5. Be conducted in compliance with the fishery management system and all legal and<br />

administrative requirements.<br />

6. Assist and co-operate with management authorities in the collection of catch, discard, and<br />

other information of importance to effective management of the resources and the fishery.<br />

Page 34 of 151


8.1 Evaluation team<br />

8. BACKGROUND TO THE EVALUATION<br />

Leader assessor: Mr. Sander Buijs<br />

Sander Buijs trained as a food technologist and has worked as a quality manager in the<br />

seafood business for ten years before joining <strong>SGS</strong> as programme manager for the MSC<br />

project.<br />

P1 expert Dr Mike Pawson<br />

Mike Pawson is an independent consultant, having worked as senior fisheries advisor at Cefas,<br />

Lowestoft, during 39 years carrying out biological research and providing scientific advice to<br />

Defra, the EC and other national and international organisations on fish stock abundance,<br />

technical conservation measures and fisheries management regulations, and on related<br />

monitoring, sampling, survey and research programmes. Between 1980 and 1990, he<br />

designed and managed MAFF's coastal fisheries programme, and implemented biological<br />

sampling, trawl surveys, a fishermen‘s logbook scheme and socio-economic evaluation in<br />

relation to sea bass fisheries. Between 1990 and 2002 Mike led the Cefas Western demersal<br />

team, providing analytical assessments and management advice for 13 finfish stocks (including<br />

sea bass) and, since 2002, directed and managed the assessment of salmon and eel stocks in<br />

England and Wales and provided scientific advice on their conservation.<br />

During this time Mike was co-ordinator of the Anglo-French English Channel Fisheries Study<br />

Group (1989-1997), chairman of the ICES Southern Shelf Demersal Stock Assessment<br />

Working Group (1996-98), Sea bass Study Group (2000-04) and Elasmobranch Study Group<br />

(2001-02), and initiated and managed EU-funded multi-national projects on methods for eggproduction<br />

stock biomass estimation, bio-geographical identity of English Channel fish stocks,<br />

bio-economic modelling of Channel fisheries, development of assessment methods for<br />

elasmobranchs, marine recreational fishing, etc. He has been involved with 6 MSC<br />

assessments, two of which involved sea bass.<br />

P2 and P3 expert: Mr Bert Keus<br />

Bert Keus is an independent consultant based in Leiden, the Netherlands. He holds degrees in<br />

biology and law, and has previously held the position of Head of the Environmental Division of<br />

the Dutch Fisheries Board (<strong>Product</strong>schap Vis), and research fellow with the fisheries division of<br />

the Agricultural Economics Research Institute of Holland (LEI-DLO).<br />

Over the years 2003 and 2004 he managed fishing and processing companies in the Gambia<br />

handling fish from industrial and artisan fisheries. Bert maintains contacts with the Gambian<br />

seafood industry. In addition, he has a long association with the shellfish fisheries in the<br />

Netherlands, and he has been involved in efforts to achieve MSC certification of the North Sea<br />

brown shrimp fishery – acting as technical advisor to this multi-stakeholder initiative. Through<br />

this work and several other MSC pre-assessments and certifications he has become<br />

particularly familiar with the MSC certification process, Between the years 1998 and 2003 he<br />

was a Member of the European Sustainable Use Specialist Group (ESUSG), Fisheries Working<br />

Group of IUCN.<br />

Page 35 of 151


8.2 Public consultation<br />

Public announcements of the progression of the assessment were made as per MSC<br />

requirements.<br />

8.3 Stakeholder consultation<br />

Extent of available information<br />

At the time this assessment was undertaken, one other MSC full assessment of a sea bass<br />

fishery in the North Sea had been completed (NESFC sea bass fishery), the findings of which<br />

are presented in a published assessment report on the MSC web site.<br />

A number of stakeholder organisations and individuals having relevant interest in the fishery<br />

assessment were identified and consulted during this assessment. The interest of others not<br />

appearing on this list was solicited through the postings on the MSC website, and by<br />

advertising in the Dutch Visserijnieuws.<br />

Initial approaches were made by email and followed up by phone conversations. Issues raised<br />

during correspondence were investigated during research and information gathering activities,<br />

and during interviews.<br />

Most stakeholders contacted during this exercise either indicated that they had no direct<br />

interest in this fishery assessment, or that they had no particular cause for concern with regard<br />

to its assessment to the MSC standard.<br />

Stakeholder issues<br />

Written and verbal representations were provided to the assessment team expressing a range<br />

of views, opinions and concerns, illustrated by the written responses received from Jan Willem<br />

Wijnstroom (Sportvisserij Nederland, Royal Dutch Angling Association) and Ruud Vergouwen,<br />

(fisherman KG 5), see Appendix 5. The main points raised are summarised below.<br />

Bass is a prime target species for recreational anglers, and the increase in bass abundance in<br />

the North Sea provides the Dutch recreational angling sector with new opportunities, with an<br />

estimated annual socio economic value of 15,8 million Euro.<br />

More than 50 % of Dutch sport anglers advocate improved bass stock management, and there<br />

is common interest with commercial anglers (VBHL) who fish for bass in a management<br />

system that benefits bass and other marine resources. Sportvisserij Nederland wants to be<br />

involved in a regular dialogue with VBHL as a starting point to set up a bass management plan<br />

for both fisheries.<br />

There are very little scientific research data available on eastern North Sea bass populations.<br />

General perception amongst recreational anglers is that mature and bigger bass are getting<br />

scarcer.<br />

Because reference points have not yet been defined for the bass stocks in ICES Sub-area IV, a<br />

main assessment using the default assessment tree would very likely result in a score below<br />

the unconditional level, but above the minimal level. If so, it will attract a condition that requires<br />

the client to liaise with Research Bodies (IMARES, CEFAS) and have a part in the further<br />

development of reference points for the North Sea stock that would support a sustainable<br />

Page 36 of 151


fishery. The formulation of specific management objectives for the Dutch sea bass fishery<br />

should also be a condition of certification.<br />

Sportvisserij Nederland advocates an increase in the MLS for bass to 42 cm, to give bass the<br />

opportunity to grow and to spawn.<br />

Sportvisserij Nederland strongly advocates to fill the gaps in scientific research regarding nonquota<br />

species such as bass that are subject to growing fishing pressure. There is currently a<br />

legal requirement of the Data Collection Framework to provide estimates of the amount of bass<br />

landed by recreational fishermen in western waters, but not in the North Sea. The aggregated<br />

and raised information provided by recreational anglers‘ questionnaires is not adequate.<br />

The current status of the stocks needs to be better investigated to achieve a firm basis for a<br />

future management plan for recreational and commercial fisheries, and Sportvisserij Nederland<br />

endorses the need for a system of monitoring and evaluation of management measures.<br />

During April, May and June schools of bass collect in spawning areas where they are most<br />

vulnerable and large quantities are caught and landed. Assuming that the MSC certificate is<br />

obtained by the VBHL, will sea bass caught in this vulnerable period have the MSC label, or<br />

could this be avoided so that the spawning fish are not targeted?<br />

Although the quantity of fish removed from a stock each year can reasonably be determined<br />

from landings data, no one knows the abundance of sea bass in the Southern North Sea. In<br />

which case, how can one determine whether a fishery is sustainable?<br />

The team considers that the issues raised have been adequately debated and addressed as a<br />

part of the assessment of this fishery, and that none of these issues require separate attention<br />

beyond that represented in this report.<br />

8.4 Interview programme<br />

A number of meetings with key stakeholders were scheduled by the team to fill in information<br />

gaps and to explore and discuss areas of concern. Meetings were held as follows:<br />

Date Name Organisation<br />

31.08.2010 Petra Klapwijk VBHL<br />

31.08.2010 Fred Klapwijk VBHL<br />

31.08.2010 Imre Schep VBHL<br />

31.08.2010 Jan de Jonge VBHL<br />

31.08.2010 Jan Willem Wijnstroom Sportvisserij Nederland<br />

8.4 Other certification evaluations and harmonisation<br />

There has been one previous MSC assessment for sea bass in the North Sea. This<br />

assessment was for the NESFC sea bass fishery in North-East England. The fishery was<br />

Page 37 of 151


certified as sustainable on 3 rd December 2007 and essentially catches sea bass from the same<br />

stock unit exploited by the VBHL fleet. It has been subject to three annual surveillance reports.<br />

Another sea bass fishery, utilizing trawls in the Bristol Channel, has also been subject to MSC<br />

assessment (the draft report is available at http://www.msc.org/track-a-fishery/inassessment/north-east-atlantic/Bristol-Channel-sea-bass/assessment-downloads),<br />

but<br />

certification has not been recommended. In that case, the RBF was used and gave low scores<br />

that reflected concerns about the effect of fishing on the target species‘ population structure<br />

and its stock status (local depletion was clearly illustrated by data provided by stakeholders),<br />

and also the lack of positive management measures to minimise discards of both bass and by<br />

catch species.<br />

The quality of information on these fisheries and the scientific basis for assessment of sea bass<br />

stock status are similar, and therefore of relevance.<br />

9. OBSERVATIONS AND SCORING<br />

9.1 Introduction to scoring methodology<br />

The MSC Principles and Criteria set out the requirements of a certified fishery. These<br />

Principles and Criteria have been developed into a standard (Fishery Assessment<br />

Methodology) assessment tree - Performance Indicators and Scoring Guideposts - by the<br />

MSC, which is used in this assessment.<br />

The Performance Indicators (PIs) are presented on the MSC website. In order to make the<br />

assessment process as clear and transparent as possible, each PI has three associated<br />

Scoring Guideposts (SG) which identify the level of performance necessary to achieve scores<br />

100, 80, or 60 for each Performance Indicator: 100 represents a theoretically ideal level of<br />

performance; 80 a pass; and 60 a measurable shortfall.<br />

For each Performance Indicator, the performance of the fishery is assessed as a ‗score‘. In<br />

order for the fishery to achieve certification, an overall weighted average score of 80 is<br />

necessary for each of the three Principles, and no Indicator should score less than 60. It is not<br />

considered possible to allocate precise scores, and a scoring interval of five is used in<br />

evaluations. As this represents a relatively crude level of scoring, average scores for each<br />

Principle are rounded to the nearest whole number.<br />

Weights and scores for the UoC are presented in the scoring table (Appendix A).<br />

9.2 Risk Based Framework (RBF)<br />

9.2.1 Introduction to RBF<br />

The MSC assessment process is evidence based, in that it seeks to use published (i.e. peer<br />

reviewed) scientific information on stock status of target and by catch species and<br />

environmental impacts of the fishery wherever possible. Where scientific information is lacking,<br />

the MSC have introduced an alternative mechanism by which fisheries can be certified: the<br />

Risk-Based Framework (RBF). This scoring method allows stakeholder knowledge and expert<br />

opinion to be taken into account in data-deficient situations, particularly for the ―outcome‖<br />

performance indicators (PIs) associated with Principles 1 and 2.<br />

Page 38 of 151


The RBF includes a set of methods for assessing the risk to each of these ecological<br />

components from activities associated with the fishery in assessment. The RBF is carried out in<br />

a series of stages that are described in the FAM v2, depending on the outcome of the previous<br />

stage (Figure 6). The next stage is a ‗Scale Intensity Consequence Analysis‖ (SICA), which is<br />

based around a structured discussion with stakeholders. If the outcome of the SICA suggests a<br />

level of risk to the stock that is moderate or above, a ‗<strong>Product</strong>ivity-Susceptibility Analysis‘ (PSA)<br />

is then carried out.<br />

During the scoring meeting for this fishery, the assessment team concluded that there was not<br />

enough scientific information to score Performance Indicator 1.1.1 (Stock status) and that the<br />

RBF should be used to score this indicator.<br />

Figure 6. MSC decision tree to select standard methodology (Fisheries Assessment<br />

Methodology „FAM‟) or RBF.<br />

Page 39 of 151


9.2.2 SICA<br />

A SICA proceeds in several steps. These steps and the results of the consequent stages are<br />

described here.<br />

Scoping for risk-causing activities:<br />

As a first step, the stakeholder group must decide on a list of activities that may have an impact<br />

on the target species population, other species, habitat or ecosystem. Based on the expert<br />

judgment of the assessment team members and stakeholders present at the meeting, the<br />

activities that may cause a risk to the different components were identified and evaluated<br />

qualitatively. The results of this first step are presented in Table 3.<br />

Table 3. Identification table of risk causing effects (** = risk causing effect, * = little effect, - =<br />

no effect, Na = not applicable)<br />

Activity Stock By catch Discard ETP Habitat Ecosystem<br />

Direct<br />

Capture<br />

** * - - - -<br />

Gear loss * * Na Na - *<br />

Unobserved<br />

mortality<br />

* * Na Na Na -<br />

Discarding<br />

Other:<br />

* * Na Na Na Na<br />

Bait collection - - - - * -<br />

Steaming - - - * - -<br />

Anchoring - - - - * -<br />

Littering - - - - * -<br />

From this rather subjective analysis it was concluded that the ‗worst plausible case‘ is the<br />

impact of the fishery (direct capture) on the sea bass stock (sub-component) in the North Sea.<br />

Scale and intensity of fishery. In the second step of the SICA, the stakeholder group is asked<br />

to consider the spatial scale, the temporal scale and the intensity of each activity, in this case<br />

the direct capture of sea bass (Table 4). These scores do not feed directly into the final score<br />

for the SICA, but help to start off the discussion and ease participants into the idea of allocating<br />

scores.<br />

Spatial scale<br />

The spatial scale score depends on the overlap of the activity with the geographical distribution<br />

of the stock. A spatial scale score of 4 was given because the UoC fishes for sea bass over a<br />

wide area of the southern North Sea, but less than 50% of the stock‘s geographical range.<br />

Temporal scale<br />

Though the UoC takes place during about 60-90 days in a year, a temporal scale score of 4<br />

was given because there are other seasonal fisheries for bass in coastal areas of the North<br />

Sea and in the eastern English Channel Therefore it has been assumed that the fishery for<br />

bass takes place during 100-200 days a year.<br />

Page 40 of 151


Intensity<br />

An intensity score of 3 was given because, based on the temporal and spatial scale of the<br />

fishery and expert knowledge, it was judged that the direct impact of the sea bass fishery is<br />

moderate (fishing mortality values of 0.2-0.4 estimated for sea bass in North Sea 1995-2005,<br />

Pawson et al., 2007).<br />

Page 41 of 151


Table 4.SICA tables from the MSC Fisheries Assessment Methodology.<br />

Consequence scoring: The third step is to score the potential risk posed by each activity to<br />

the sea bass population. This is done by considering four ‗components‘ of population<br />

dynamics: population size, reproductive capacity and/or recruitment, age/size/sex ratio and<br />

geographic range. The likely impact of each activity on each component is scored separately.<br />

Fishing activities are then ranked according to their likely impact on the population dynamics,<br />

identifying the highest risk activities along with the element of the population on which they act.<br />

Given the lack of quantitative knowledge about the current level of exploitation on bass in the<br />

North Sea (in particular, the mortality due to non-commercial fishermen, including recreational<br />

anglers) and its impact on the population, the assessment team were undecided whether a<br />

consequence score of 2 or 3 was most appropriate. It was concluded that there may be<br />

detectable changes in age/size/sex structure resulting from the bass fishery, but that the stock<br />

dynamics are mainly driven by environmental factors in the sense that the stock of bass in the<br />

North Sea has increased due to warming.<br />

Page 42 of 151


Table 5. SICA table for PI 1.1.1<br />

The team therefore decided to give a SICA consequence score of 3 (which is converted to an<br />

MSC equivalent score of 60, but not used further in the assessment, Table 5), thus triggering<br />

further evaluation of Principle 1 using <strong>Product</strong>ivity-Susceptibility Analysis (PSA). This<br />

represents a relatively precautionary measure of the risk to the sea bass stock in the North Sea<br />

from fishing activities.<br />

9.2.3 PSA<br />

There are four steps for the MSC PSA.<br />

1. Score productivity attributes<br />

2. Score susceptibility attributes<br />

3. Calculate risk scores and plot individual species onto a PSA plot.<br />

4. Convert PSA scores into MSC scores and feed back into default assessment tree.<br />

The calculations of the scores under steps 3 and 4 have been carried out using the Excel<br />

workbook entitled PSA for MSC.xls which accompanies the FAM v2. This Excel workbook<br />

automatically generates PSA scores and the PSA plot when attribute scores are completed for<br />

the species.<br />

The PSA productivity and susceptibility attributes can be found in Table B4.2 and B4.3 of the<br />

FAM.<br />

PSA step 1. Score productivity attributes.<br />

Each productivity attribute was scored on the three point risk scale as presented in Table 6<br />

(from Table B4.2 of the FAM).The results of this scoring and the rational are given in Table 7<br />

Page 43 of 151


Table 6. PSA <strong>Product</strong>ivity attributes and scores.<br />

Table 7. PSA productivity scores for the North Sea bass stock.<br />

Score Rationale<br />

Average age at maturity 2 5-6 years<br />

Average maximum age 2 10-25 years<br />

Fecundity 1 > 100,000 eggs per year<br />

Average maximum size 1


the spots where they are most abundant, which is where the trawl and gill net fisheries are also<br />

most likely to encounter bass. Consequently, a score of 2 was given.<br />

Whilst the selectivity for the hook and line fishery could have been scored using Table B 4.4 of<br />

the FAM, strict application of the attributes in this table would result in a high risk score (bait<br />

used is attractive to bass and the fish can not break the line), which does not seem appropriate<br />

for this metier since the hook and line fishery is highly selective in catching larger fish as it<br />

targets fishing locations (wrecks) were larger fish aggregate. Undersized fish are rarely caught<br />

and always released alive. The team therefore awarded a medium risk score of 2.<br />

The selectivity of the gill net fishery was scored using Table B4.3 of the FAM. The team<br />

considered that the minimum mesh size of gill nets was based on gear trials and has been set<br />

to minimise the by catch of undersized fish. Therefore, the gill net fishery is considered<br />

selective and a medium risk score of 2 was attributed.<br />

The selectivity of trawl nets was given a high risk score of 3. . The assessment team and the<br />

stakeholders considered that many smaller bass would be retained with the mesh size used in<br />

the trawl fishery and the chances that the fish survive discarding was considered low.<br />

Post capture mortality was scored at the high risk score of 3 for all three fishing metiers. In the<br />

gill net and hook and line fishery most fish are retained when captured. In the trawl fishery<br />

discarded bass have a rather low chance to survive.<br />

The scores derived above for productivity and susceptibility have been fed into the PSA for<br />

MSC.xls workbook. The spreadsheet calculated PSA risk scores of 2.22 for both the rod and<br />

line and gill net fisheries for bass, and a score of 2.45 for the trawl fishery.<br />

To calculate an overall risk score for the whole fishery taking sea bass in the North Sea, the<br />

team weighted the selectivity values for each of the hook and line, gill net and trawl fisheries<br />

(2,2,3) by the proportional landings taken by the 3 metiers in the North Sea (in Table 9). This<br />

score (2.7) was fed into the work book and resulted in a PSA Risk Score of 2.38.<br />

Using the formula in paragraph 4.4.2 of the FAM a MSC score of 87 was calculated for<br />

Performance Indicator 1.1.1.<br />

The PSA graph for the North Sea bass fishery (Figure 7 below) shows that all three metiers<br />

(trawl, gill net and rod and line) fall into the low susceptibility zone and warrant a score of 80 or<br />

more.<br />

Page 45 of 151


Table 9. FAM Workbook Table with scores.<br />

COMMON<br />

NAME<br />

Average age at maturity<br />

Average max age<br />

Fecundity<br />

Sea bass,<br />

ROD/LINE 2 2 1 1 1 1 3 1,57<br />

Sea bass,<br />

TRAWL 2 2 1 1 1 1 3 1,57<br />

Sea bass,<br />

GILL NETS 2 2 1 1 1 1 3 1,57<br />

()<br />

3,00<br />

2,500<br />

2,00<br />

1,500<br />

1,00<br />

<strong>Product</strong>ivity Scores [1 3] Susceptibility Scores [1 3]<br />

Average max size<br />

2 2 1 1 1 1 3 1,57<br />

PSA Graph<br />

1,00 1,500 2,00 2,500 3,00<br />

Average size at Maturity<br />

()<br />

Reproductive strategy<br />

Trophic level (fishbase)<br />

Total <strong>Product</strong>ivity (average)<br />

Availability<br />

Encounterability<br />

Selectivity<br />

Post-capture mortality<br />

Weight<br />

relative<br />

Weighted selectivity<br />

Total (multiplicative)<br />

Colour on PSA plot<br />

PSA<br />

Score<br />

2 2 2 3 200 0,143 0,286 1,58 2,22<br />

2 2 3 3 1000 0,714 2,143 1,88 2,45<br />

2 2 2 3 200 0,143 0,286 1,58 2,22<br />

2 2 2,7 3 2,714 1,79 2,38<br />

Figure 7. PSA Graph for North Sea bass fishery (red = trawl fishery, light blue = gill net,<br />

dark blue = hook and line fishery).<br />

Page 46 of 151


9.3 Scoring of performance against MSC Principles<br />

The assessment team convened a scoring meeting on 1 and 2 September 2010, the outcome<br />

from which is shown in the scoring tables forming Appendix A to this report and in paragraph<br />

9.2 above. The scores allocated to the assessment tree at sub-criterion, Criterion and Principle<br />

levels are shown in Table 10. Full details of the justification for these scores are provided in the<br />

assessment tree (Appendix A).<br />

Further details are provided below on those areas where current practices (or stock status) are<br />

considered to be below good industry practice. In all cases, these are not sufficiently below<br />

best practice to warrant an automatic failure (i.e. none score less than 60).<br />

For Principle 1, there was one performance indicator that scored below 80 and therefore<br />

triggered a condition. This condition relates to the harvest control rule.<br />

No performance indicators for Principle 2 fell below the 80 pass mark and, whilst there are<br />

therefore no conditions related to Principle 2, there are some recommendations applicable.<br />

For Principle 3, there were three performance indicators that scored below the 80 pass mark<br />

and therefore attract a condition. These three performance indicators are closely connected<br />

and relate to the fishery-specific management system for the sea bass fishery in the<br />

Netherlands.<br />

Further explanation of the attached conditions is provided in section 10.2.<br />

Page 47 of 151


10.1 Performance<br />

10. ASSESSMENT RESULTS<br />

Table 10.Performance indicators and scores attributed.<br />

Principle Wt<br />

(L1)<br />

Component Wt<br />

(L2)<br />

PI<br />

No.<br />

Performance Indicator<br />

(PI)<br />

One 1 Outcome 0,5 1.1.1 Stock status 87<br />

Score<br />

1.1.2 Reference points 80<br />

1.1.3 Stock rebuilding<br />

Management 0,5 1.2.1 Harvest strategy 80<br />

1.2.2 Harvest control rules &<br />

tools<br />

75<br />

1.2.3 Information & monitoring 80<br />

1.2.4 Assessment of stock<br />

status<br />

80<br />

Two 1 Retained 0,2 2.1.1 Outcome 80<br />

species<br />

2.1.2 Management 80<br />

2.1.3 Information 80<br />

By catch 0,2 2.2.1 Outcome 100<br />

species<br />

2.2.2 Management 100<br />

2.2.3 Information 80<br />

ETP species 0,2 2.3.1 Outcome 100<br />

2.3.2 Management 80<br />

2.3.3 Information 80<br />

Habitats 0,2 2.4.1 Outcome 95<br />

2.4.2 Management 80<br />

2.4.3 Information 80<br />

Ecosystem 0,2 2.5.1 Outcome 90<br />

2.5.2 Management 80<br />

2.5.3 Information 90<br />

Three 1 Governance<br />

and policy<br />

Fishery<br />

specific<br />

management<br />

system<br />

0,5 3.1.1 Legal & customary<br />

framework<br />

85<br />

3.1.2 Consultation, roles &<br />

responsibilities<br />

85<br />

3.1.3 Long term objectives 90<br />

3.1.4 Incentives for sustainable<br />

fishing<br />

80<br />

0,5 3.2.1 Fishery specific<br />

objectives<br />

70<br />

3.2.2 Decision making<br />

processes<br />

70<br />

3.2.3 Compliance &<br />

enforcement<br />

80<br />

3.2.4 Research plan 80<br />

3.2.5 Management<br />

performance evaluation<br />

75<br />

Page 48 of 151


The Performance of the Fishery in relation to MSC Principles 1, 2 and 3 are summarised<br />

below:<br />

MSC Principle Fishery Performance<br />

Principle 1: Sustainability of exploited stock Overall: 81,1 points PASS<br />

Principle 2: Maintenance of ecosystem Overall: 86,3 points PASS<br />

Principle 3: Effective management system Overall: 80,0 points PASS<br />

10.2 Conditions<br />

The fishery attained a score of below 80 against four Performance Indicators. The assessment<br />

team has therefore set conditions for continuing certification that the Vereniging Beroepsmatige<br />

Handlijnvissers Nederland (VBHL), as the client for certification, is required to address. The<br />

conditions are applied to improve performance to at least the 80 level within a period set by the<br />

certification body but no longer than the term of the certification.<br />

As a standard condition of certification, the client shall develop an 'Action Plan‘ for meeting the<br />

conditions for continued certification, to be approved by <strong>SGS</strong>.<br />

The conditions, associated timescales and relevant Performance Indicators are set out below<br />

(note that PIs for SGs 60 and 80 are assumed for SG 100).<br />

Condition 1<br />

Harvest Strategy 1.2.2 Harvest control rule<br />

PI There are well defined and effective harvest control rules in place<br />

SG 60 Generally understood harvest control rules are in place that are<br />

consistent with the harvest strategy and which act to reduce the<br />

exploitation rate as limit reference points are approached.<br />

There is some evidence that tools used to implement harvest<br />

control rules are appropriate and effective in controlling<br />

exploitation.<br />

SG 80 Well defined harvest control rules are in place that are consistent<br />

with the harvest strategy and ensure that the exploitation rate is<br />

reduced as limit reference points are approached.<br />

The selection of the harvest control rules takes into account the<br />

main uncertainties.<br />

Available evidence indicates that the tools in use are appropriate<br />

and effective in achieving the exploitation levels required under the<br />

harvest control rules<br />

SG 100 The design of the harvest control rules take into account a wide<br />

range of uncertainties.<br />

Evidence clearly shows that the tools in use are effective in<br />

achieving the exploitation levels required under the harvest control<br />

rules.<br />

Scoring 75<br />

Rationale Technical conservation measures are in place (MLS and mesh size<br />

Page 49 of 151


controls) that seek to maximise Y/R, but the HCRs that are in place<br />

do not ensure that the exploitation rate is reduced as limit<br />

reference points are approached (with respect to MSY, since<br />

recruitment is not stock-driven).<br />

Condition Condition 1. Client should liaise with management and research<br />

bodies to determine what part they can play in the development of<br />

a harvest control rule that better ensures that the exploitation rate<br />

by fishing metiers taking sea bass in the North Sea, including<br />

trawling and gill netting, is reduced as limit reference points are<br />

approached.<br />

Client Action<br />

Plan<br />

Condition 2<br />

Fishery specific<br />

management<br />

system<br />

Timescale: By first surveillance audit: written evidence is required<br />

of appropriate action by the client towards management authorities<br />

and research institutes, and of their response.<br />

Liaise with fisheries management and research bodies to develop<br />

appropriate harvest control rules (related to MSY) within the<br />

fisheries for North Sea bass<br />

3.2.1 Fishery specific objectives<br />

P3 The fishery has clear, specific objectives designed to achieve the<br />

outcomes expressed by MSC‘s Principles 1 and 2.<br />

SG 60 Objectives, which are broadly consistent with achieving the<br />

outcomes expressed by MSC‘s Principles 1 and 2, are implicit<br />

within the fishery‘s management system.<br />

SG 80 Short and long term objectives, which are consistent with achieving<br />

the outcomes expressed by MSC‘s Principles 1 and 2, are explicit<br />

within the fishery‘s management<br />

system.<br />

SG 100 Well defined and measurable short and long term objectives, which<br />

are demonstrably consistent with achieving the outcomes<br />

expressed by MSC‘s Principles 1 and 2, are explicit within the<br />

fishery‘s management<br />

system.<br />

Scoring 70<br />

Rationale Although there are clearly defined management objectives for<br />

Dutch North Sea fisheries in general, fishery-specific management<br />

objectives are not explicitly formulated for the rod and line sea<br />

bass fishery. Specific management objectives for the sea bass<br />

fishery (as a whole, preferably) should be developed within the<br />

context of regulations as set out by the management authorities.<br />

This would preferably be done by the management authorities and<br />

with input from scientists.<br />

Condition Condition 2. The client should liaise with the relevant authorities<br />

and scientists (IMARES and ICES) and encourage them to develop<br />

specific management objectives for this fishery, which would<br />

Page 50 of 151


Client Action<br />

Plan<br />

Condition 3<br />

Fishery specific<br />

management<br />

system<br />

preferably also account for other fishing metiers targeting sea<br />

bass, such as trawling and gill net fishing.<br />

The Client should also formulate management objectives for the<br />

sea bass fishery within the VBHL management plan.<br />

Timescale: By first surveillance audit, written evidence is required<br />

of appropriate action by the client to encourage the relevant<br />

management authorities to formulate management objectives for<br />

this fishery, and to demonstrate that a management objective for<br />

the sea bass fishery is incorporated within the VBHL management<br />

plan.<br />

Liaise with authorities and scientists to develop specific fishery<br />

objectives and implement these objectives within the VBHL<br />

management plan<br />

3.2.2 Decision making process<br />

P3 The fishery-specific management system includes effective<br />

decision making processes that result in measures and strategies<br />

to achieve the objectives.<br />

SG 60 There are informal decision-making processes that result in<br />

measures and strategies to achieve the fishery-specific objectives.<br />

Decision-making processes respond to serious issues identified in<br />

relevant research, monitoring, evaluation and consultation, in a<br />

transparent, timely and adaptive manner and take some account of<br />

the wider implications of decisions.<br />

SG 80 There are established decision-making processes that result in<br />

measures and strategies to achieve the fishery-specific objectives.<br />

Decision-making processes respond to serious and other important<br />

issues identified in relevant research, monitoring, evaluation and<br />

consultation, in a transparent, timely and adaptive manner and<br />

take account of the wider implications of decisions.<br />

Decision-making processes use the precautionary approach and<br />

are based on best available information.<br />

Explanations are provided for any actions or lack of action<br />

associated with findings and relevant recommendations emerging<br />

from research, monitoring, evaluation and review activity.<br />

SG 100 Decision-making processes respond to all issues identified in<br />

relevant research, monitoring, evaluation and consultation, in a<br />

transparent, timely and adaptive manner and take account of the<br />

wider implications of decisions.<br />

Formal reporting to all interested stakeholders describes how the<br />

Page 51 of 151


management system responded to findings and relevant<br />

recommendations emerging from research, monitoring, evaluation<br />

and review activity.<br />

Scoring 70<br />

Rationale Management systems for Dutch North Sea fisheries are well<br />

established and generally effective. The decision-making<br />

processes are well developed and fishery representatives are<br />

regularly consulted by the relevant authorities. However, the rod<br />

and line fishery for bass is a relatively small sector and most rod<br />

and line fishermen are not represented by the National<br />

Fishermen‘s organisations.<br />

Condition Condition 3: The client should encourage the relevant<br />

management authorities to include this fishery in the formal<br />

decision-making processes.<br />

Client Action<br />

Plan<br />

Condition 4<br />

Fishery specific<br />

management<br />

system<br />

Timescale: By first surveillance visit: written evidence is required<br />

of actions by the client to encourage the relevant management<br />

authorities to develop a formal decision making process for the sea<br />

bass fishery, and of their response.<br />

By the third surveillance visit, evidence is required that the sea<br />

bass fishery is included in the decision-making process.<br />

Encourage authorities to include this fishery within national<br />

decision-making processes.<br />

3.2.5 Information and monitoring<br />

P3 There is a system for monitoring and evaluating the performance of<br />

the fishery-specific management system against its objectives.<br />

There is effective and timely review of the fishery-specific<br />

management system.<br />

SG 60 The fishery has in place mechanisms to evaluate some parts of the<br />

management system and is subject to occasional internal review.<br />

SG 80 The fishery has in place mechanisms to evaluate key parts of the<br />

management system and is subject to regular internal and<br />

occasional external review.<br />

SG 100 The fishery has in place mechanisms to evaluate all parts of the<br />

management system and is subject to regular internal and external<br />

review.<br />

Scoring 75<br />

Rationale Because fishery-specific management objectives are not explicitly<br />

formulated for the rod and line sea bass fishery, there is no<br />

provision for evaluation of the fishery‘s performance against these<br />

objectives.<br />

Condition Condition 4.<br />

Once fishery-specific objectives are identified and set (Condition<br />

2), the client should liaise with the relevant management<br />

Page 52 of 151


Client Action<br />

Plan<br />

13.3 Recommendations<br />

authorities and scientists (IMARES and ICES) to develop a system<br />

of collecting information that can be used to evaluate the<br />

performance of the fishery against these management objectives,<br />

and which includes independent review.<br />

Timescale: By the third surveillance visit, evidence is required of<br />

that information is being collected and used to evaluate the<br />

performance of the fishery against management objectives.<br />

Ensure that proper (scientific) monitoring and evaluation<br />

management options takes place within the fishery management<br />

system.<br />

In addition to the four Conditions outlined above, the assessment team consider that<br />

improvements on the performance of the fishery against the MSC Principles and Criteria are<br />

required in some areas that relate to Performance Indicators where the client vessels scored<br />

80 or better.<br />

The assessment team has made a number of recommendations. These are not required to<br />

maintain certification and the action taken and timescales are at the discretion of the client.<br />

Recommendations are made in respect of:<br />

Recommendation 1 –Research plan (Performance Indicator 3.2.4)<br />

The Client should encourage IMARES to extend the collection of biological information on sea<br />

bass in the Netherlands, and to be involved in any relevant research<br />

Recommendation 2 – Retained species and Species specific management<br />

system (Performance Indicators 2.1.2 and 3.2.3)<br />

Though there are sanctions to deal with non-compliance, and compliance by the UoC is<br />

probably high, the actual control of small-scale landings is considered rather poor. This could<br />

result in underreporting of quota species (e.g. cod), because cod landings under 50 kg of wet<br />

weight are not counted against individual quotas. The Client should address this issue in its<br />

fisheries management plan, and implement appropriate controls to prevent under-reporting of<br />

cod catches.<br />

Recommendation 3 – Ecosystem Management strategy (Performance<br />

Indicators 2.5.2)<br />

The Client‘s management plan should require that litter is taken to shore and disposed of in a<br />

responsible way, and that VBHL continue to look into the possibilities to replace the lead in the<br />

baits with another metal (steel).<br />

Page 53 of 151


Recommendation 4 – Governance and policy (Performance Indicators, 3.1.2,<br />

Consultation, roles and responsibility.)<br />

The VBHL is recommended to seek a more professional representation, possibly through a<br />

national fishery organisation.<br />

11.1 Traceability<br />

11. LIMIT OF IDENTIFICATION OF LANDINGS FROM THE FISHERY<br />

Directly after the fish are caught and killed, the fish receive a gill tag which is only available to<br />

VHBL members. The gill tag is non-removable and non-reusable without damaging the fish,<br />

because of which it is unlikely that fraud with gill tags used by non-member fishermen will take<br />

place.<br />

Client group members land the fish each day into the harbour of ‗NeeltjeJans‘, and no multi day<br />

trips take place. Some members carry their fish to local traders, but most members transport<br />

the fish to the nearby facility of ‗Fred Klapwijk‘ where the fish is weighed, iced, labelled and<br />

prepare for transportation to the fish auction in Ijmuiden.<br />

Fred Klapwijk as well as the Fish auction at Ijmuiden hold their own MSC CoC certificate, thus<br />

ensuring traceability<br />

11.2 At-sea processing<br />

There is no at-sea processing in this fishery except for icing and applying the gill tag.<br />

No gutting takes place at sea or on shore.<br />

11.3 Points of landing<br />

The members of the UoC land fish in the port of NeeltjeJans. The fish is transported to the Fred<br />

Klapwijk facility by the fishermen‘s private cars. Until the point of reception by Fred Klapwijk,<br />

the fishermen remain responsible for the fishes‘ traceability.<br />

11.4 Eligibility data<br />

The products originating from this fishery are eligible to carry the MSC logo or ‗<strong>Marine</strong><br />

<strong>Stewardship</strong> <strong>Council</strong>‘ phrase from the date of certification.<br />

Page 54 of 151


12. OBJECTIONS<br />

This being not the final report, no objections can be included (yet)<br />

Page 55 of 151


13.1 Logo use<br />

13. MSC LOGO LICENSING RESPONSIBILITIES<br />

The client group members can use the MSC logo (after prior approval from MSCI) free of<br />

charge for promotional use only. If the client group wishes to use the logo on the FBHL gill<br />

tags, this should be approved by MSC and a logo use fee could be charged.<br />

Logo use by the Fred Klapwijk facility is beyond the scope of this certification: this is dealt with<br />

in the MSC CoC certification of Fred Klapwijk.<br />

Page 56 of 151


14. CONCLUSION<br />

Page 57 of 151


APPENDICES<br />

APPENDIX A: SCORING TABLE<br />

Principle 1 A fishery must be conducted in a manner that does not lead to over-fishing or depletion of the exploited populations<br />

and, for those<br />

populations that are depleted, the fishery must be conducted in a manner that demonstrably leads to their recovery.<br />

Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

1.1 Management<br />

outcome<br />

1.1.1 Stock status: The<br />

stock is at a level<br />

which maintains high<br />

productivity and has a<br />

low probability of<br />

recruitment<br />

overfishing<br />

(1-60) It is likely that the stock is<br />

above the point where recruitment<br />

would be impaired.<br />

(1-80) It is highly likely that the<br />

stock is above the point where<br />

recruitment would be impaired.<br />

(2-80) The stock is at or<br />

fluctuating around its target<br />

reference point.<br />

(1-100) There is a high degree of<br />

certainty that the stock is above<br />

the point where recruitment<br />

would be impaired.<br />

(2-100) There is a high degree of<br />

certainty that the stock has been<br />

fluctuating around its target<br />

reference point, or has been<br />

above its target reference point,<br />

over recent years.<br />

Scoring comments<br />

The status of the bass stock relative to an unfished population cannot be estimated. The most recent peer-reviewed assessment for the North<br />

Sea ―stock‖ ran to 2004 and was updated for UK fisheries to 2006 and then to 2009, though these updates are considered to be increasingly<br />

uncertain in relation to bass stock dynamics in the North Sea. The assessment team concluded that the Risk Based Framework should be used<br />

to assess the stock status.<br />

The assessment results presented by ICES suggest that bass stock in ICES Divisions IVb,c and VIId were being exploited sustainably in 2006,<br />

at a moderate level of F and with an exploitation pattern that gives a near maximum yield per recruit, and that this has led to an increase in<br />

exploitable biomass since the early 1990s to levels considered to be at, or close to, series maxima. Recruitment was above-average during the<br />

mid to late 1990s, and this has resulted in high landings and stock levels. The most recent assessment (to 2009) suggests that these trends<br />

have continued.


The results of the RBF assessment of stock status is a PSA score of 87 for the fishery (see Chapter 9). The score reflects the assessment‘s<br />

team observation that there has been an expansion of the sea bass population into the North Sea since the early 1990s, yields there have been<br />

maintained since 2003, see Table 1, and there has been an increasing trend in recruitment since the late 1990s.<br />

Score:<br />

RBF score 87<br />

Audit trace references<br />

ICES, 2004; Pawson et al., 2007a; Kupschus et al., 2007; Kupschus 2010 (in ICES 2010).<br />

Page 59 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

1.1.2 Reference Points:<br />

Limit<br />

and target reference<br />

points<br />

are appropriate for the<br />

stock.<br />

(1-60) Generic limit and target<br />

reference points are based on<br />

justifiable and reasonable<br />

practice appropriate for the<br />

species category.<br />

(1-80) Reference points are<br />

appropriate for the stock and can<br />

be estimated.<br />

(2-80) The limit reference point<br />

is set above the level at which<br />

there is an appreciable risk of<br />

impairing reproductive capacity.<br />

(3-80) The target reference point<br />

is such that the stock is<br />

maintained at a level consistent<br />

with BMSY or some measure or<br />

surrogate with similar intent or<br />

outcome.<br />

(4-80) For low trophic level<br />

species, the target reference<br />

point takes into account the<br />

ecological role of the stock.<br />

(1-100) Reference points are<br />

appropriate for the stock and can<br />

be estimated.<br />

(2-100) The limit reference point<br />

is set above the level at which<br />

there is an appreciable risk of<br />

impairing reproductive capacity<br />

following consideration of<br />

relevant precautionary issues.<br />

(3-100) The target reference<br />

point is such that the stock is<br />

maintained at a level consistent<br />

with BMSY or some measure or<br />

surrogate with similar intent or<br />

outcome, or a higher level, and<br />

takes into account relevant<br />

precautionary issues such as the<br />

ecological role of the stock with<br />

a high degree of certainty.<br />

Scoring comments<br />

The assessment team notes that there are no reference points in terms of SSB or F agreed for this or any other European sea bass stock, and<br />

explicit (formal) reference points have not yet been defined for the bass stock in ICES Sub-area IV. Spawning success and juvenile survival for<br />

sea bass are heavily dependent on climatic conditions, especially temperature, and there appears to be no relationship between stock and<br />

Page 60 of 151


subsequent recruitment. Though it has not been possible to set absolute or relative F reference points on this basis, the harvest strategy<br />

clearly uses an appropriate proxy for reference points, being designed to achieve management objectives in terms of yield per recruit and MSY.<br />

These metrics are more appropriate to a species like sea bass where a wide variability in recruitment is related to environmental factors rather<br />

than SSB.<br />

A score of 80 is awarded here because the RBF has been used for Performance Indicator 1.1.1.<br />

Score:<br />

80 (default score)<br />

Audit trace references<br />

Page 61 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

1.1.3 Stock Rebuilding:<br />

Where the stock is<br />

depleted, there is<br />

evidence of stock<br />

rebuilding.<br />

(1-60) Where stocks are<br />

depleted rebuilding strategies<br />

which have a reasonable<br />

expectation of success are in<br />

place.<br />

(2-60) Monitoring is in place to<br />

determine whether they are<br />

effective in rebuilding the stock<br />

within a specified timeframe.<br />

(1-80) Where stocks are<br />

depleted rebuilding strategies<br />

are in place.<br />

(2-80) There is evidence that<br />

they are rebuilding stocks, or it is<br />

highly likely based on simulation<br />

modelling or previous<br />

performance that they will be<br />

able to rebuild the stock within a<br />

specified timeframe.<br />

(1-100) Where stocks are<br />

depleted, strategies are<br />

demonstrated to be rebuilding<br />

stocks continuously and there is<br />

strong evidence that rebuilding<br />

will be complete within the<br />

shortest practicable timeframe.<br />

Scoring comments<br />

There is no evidence of depletion of the North Sea bass stock. Although the available assessments do not allow the abundance of sea bass to<br />

be determined in absolute quantitative terms, stock abundance indicators suggest that the sea bass population in the North Sea has become<br />

more productive since 1990, with increased levels of recruitment, a higher SSB and an extension of its geographical range to the north.<br />

Score:<br />

N/A<br />

Audit trace references<br />

ICES, 2004, 2008; Pawson et al, 2007; Kupschus, 2007; Kupschus 2010<br />

Page 62 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

1.2 Harvest Strategy (management)<br />

1.2.1 Harvest Strategy:<br />

There is a robust and<br />

precautionary harvest<br />

strategy in place<br />

Scoring comments<br />

(1-60) The harvest strategy is<br />

expected to achieve stock<br />

management objectives<br />

reflected in the target and limit<br />

reference points.<br />

(2-60) The harvest strategy is<br />

likely to work based on prior<br />

experience or plausible<br />

argument.<br />

(3-60) Monitoring is in place that<br />

is expected to determine<br />

whether the harvest strategy is<br />

working.<br />

(1-80) The harvest strategy is<br />

responsive to the state of the<br />

stock and the elements of the<br />

harvest strategy work together<br />

towards achieving management<br />

objectives reflected in the target<br />

and limit reference points.<br />

(2-80) The harvest strategy may<br />

not have been fully tested but<br />

monitoring is in place and<br />

evidence exists that it is<br />

achieving its objectives.<br />

(1-100) The harvest strategy is<br />

responsive to the state of the<br />

stock and is designed to achieve<br />

stock management objectives<br />

reflected in the target and limit<br />

reference points.<br />

(2-100) The performance of the<br />

harvest strategy has been fully<br />

evaluated and evidence exists to<br />

show that it is achieving its<br />

objectives including being clearly<br />

able to maintain stocks at target<br />

levels.<br />

(3-100) The harvest strategy is<br />

periodically reviewed and<br />

improved as necessary.<br />

The harvest strategy for the sea bass fishery is designed to avoid growth overfishing and maximise recruitment to the adult stock by protecting<br />

bass smaller than 36 cm (see report section 3.1). There is a robust and precautionary strategy that has been in place and monitored for 20<br />

years, which has been demonstrated to have achieved its stock management objectives in UK waters in terms of yield per recruit and MSY.<br />

The performance of the harvest strategy has been periodically reviewed and evaluated, which has demonstrated that the growth overfishing that<br />

took place in the 1980‘s has ameliorated and there are no signs of recruitment overfishing.<br />

There are no target or limit reference points in terms of SSB and F for this stock, but the assessment team has not penalised the fishery for the<br />

absence of clearly defined reference points under this Performance Indicator, since the harvest strategy clearly uses an appropriate proxy for<br />

reference points. Instead, the harvest strategy is designed to achieve management objectives in terms of yield per recruit and MSY. These<br />

Page 63 of 151


metrics are more appropriate to a species like sea bass where a wide variability in recruitment is related to environmental factors rather than<br />

SSB. The harvest strategy may not have been fully tested but monitoring is in place and evidence exists that it is achieving its objectives.<br />

The harvest strategy is likely to work based on prior experience (for the UK fishery), but this has not been demonstrated in other bass fisheries<br />

in the North Sea (though plausible argument suggests that it is likely), and monitoring is in place to determine whether the harvest strategy is<br />

working for the stock as a whole. Moreover, though ICES advised (ACOM, 2004) that effort should not be increased for sea bass in any area, it<br />

is apparent that trawl fisheries in particular have been increasingly directed at sea bass as catch quotas on other species have been reduced.<br />

Nevertheless, decommissioning, fleet restructuring and effort controls (e.g. days-at-sea) have clearly led to a reduction in F in all North Sea<br />

towed-gear fisheries (ICES 2010), with a consequent constraint on effort that might take bass.<br />

Score: All elements of SG60 and SG 80 are satisfied, and a score of 80 awarded.<br />

Score:<br />

80<br />

Audit trace references<br />

(ICES, 2004; Pawson et al., 2005; ICES, 2008).<br />

Page 64 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

1.2.2 Harvest control rules<br />

and tools: There are<br />

well defined and<br />

effective harvest<br />

control rules in place<br />

Scoring comments<br />

(1-60) Generally understood<br />

harvest control rules are in place<br />

that are consistent with the<br />

harvest strategy and which act to<br />

reduce the exploitation rate as<br />

limit reference points are<br />

approached.<br />

(2-60) There is some evidence<br />

that tools used to implement<br />

harvest control rules are<br />

appropriate and effective in<br />

controlling exploitation.<br />

(1-80) Well defined harvest<br />

control rules are in place that are<br />

consistent with the harvest<br />

strategy and ensure that the<br />

exploitation rate is reduced as<br />

limit reference points are<br />

approached.<br />

(2-80) The selection of the<br />

harvest control rules takes into<br />

account the main uncertainties.<br />

(3-80) Available evidence<br />

indicates that the tools in use are<br />

appropriate and effective in<br />

achieving the exploitation levels<br />

required under the harvest<br />

control rules<br />

(1-100) Well defined harvest<br />

control rules are in place that are<br />

consistent with the harvest<br />

strategy and ensure that the<br />

exploitation rate is reduced as<br />

limit reference points are<br />

approached.<br />

(2-100) The design of the<br />

harvest control rules take into<br />

account a wide range of<br />

uncertainties.<br />

(3-100) Evidence clearly shows<br />

that the tools in use are effective<br />

in achieving the exploitation<br />

levels required under the harvest<br />

control rules.<br />

The harvest strategy developed for the UK sea bass fishery and adopted by the EC is designed to modify exploitation patterns so that<br />

exploitation rates are sustainable. It has achieved this by using well defined and understood tools in the form of a minimum legal landing size,<br />

gill-mesh size controls, and (in the UK) nursery area closures to protect juvenile bass. Both the harvest strategy and the harvest control rules<br />

and tools have been selected and designed to take account of the main uncertainties in this fishery, which are recruitment variability and the<br />

inshore small-boat nature of the much of the fishery. A lesser uncertainty is the outcome in response to management in terms of exploitation<br />

levels, which are not controlled directly.<br />

The available evidence indicates that the package of measures introduced by the UK in 1990 has been effective in achieving appropriate<br />

exploitation patterns and levels as required by the harvest strategy, except in the case of trawl fisheries where gear selectivity is not well<br />

matched to the MLS of the target species and effort directed at bass is uncontrolled. There are no explicit decision rules for the sea bass fishery<br />

in the North Sea. As stated under 1.2.1, technical harvest control measures are in place and could be extended when considered necessary.<br />

Page 65 of 151


This is regarded as an implicit harvest control rule.<br />

The assessment team has not penalised the fishery for the absence of clearly defined reference points under this Performance Indicator, since<br />

the harvest strategy clearly uses an appropriate proxy for reference points.<br />

All of the SGP 60 requirements and the second and third SG80 requirements are met, but the HCRs that are in place do not ensure that the<br />

exploitation rate is reduced as limit reference points are approached (with respect to MSY, since recruitment is not stock-driven). A score of 75<br />

is therefore awarded.<br />

Condition: the client will be asked to liaise with management and research bodies and to determine what part they can play in the development<br />

of an appropriate harvest control rule.<br />

Score:<br />

75<br />

Audit trace references<br />

Page 66 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

1.2.3 Information /<br />

monitoring: Relevant<br />

information is<br />

collected to support<br />

the harvest strategy<br />

Scoring comments<br />

(1-60) Some relevant information<br />

related to stock structure, stock<br />

productivity and fleet<br />

composition is available to<br />

support the harvest strategy.<br />

(2-60) Stock abundance and<br />

fishery removals are monitored<br />

and at least one indicator is<br />

available and monitored with<br />

sufficient frequency to support<br />

the harvest control rule.<br />

(1-80) Sufficient relevant<br />

information related to stock<br />

structure, stock productivity, fleet<br />

composition and other data is<br />

available to support the harvest<br />

strategy.<br />

(2-80) Stock abundance and<br />

fishery removals are regularly<br />

monitored at a level of accuracy<br />

and coverage consistent with the<br />

harvest control rule, and one or<br />

more indicators are available<br />

and monitored with sufficient<br />

frequency to support the harvest<br />

control rule.<br />

(3-80) There is good information<br />

on all other fishery removals<br />

from the stock.<br />

(1-100) A comprehensive range<br />

of information (on stock<br />

structure, stock productivity, fleet<br />

composition, stock abundance,<br />

fishery removals and other<br />

information such as<br />

environmental information),<br />

including some that may not be<br />

directly relevant to the current<br />

harvest strategy, is available.<br />

(2-100) All information required<br />

by the harvest control rule is<br />

monitored with high frequency<br />

and a high degree of certainty,<br />

and there is a good<br />

understanding of the inherent<br />

uncertainties in the information<br />

[data] and the robustness of<br />

assessment and management to<br />

this uncertainty.<br />

Good information is available on fleet structure and commercial fishery removals of sea bass, indicators of stock abundance and stock<br />

productivity are available, and there is a good understanding of the uncertainties in this information. Netherlands and UK surveys have provided<br />

valuable fishery-independent data on year class strength. Monitoring of length, weight and age is carried out on a structural basis (in the UK and<br />

France: biological sampling of sea bass in the Netherlands is very limited) and is consistent with the harvest control rule.<br />

While there is no comprehensive information about the recreational angling catch of sea bass, the consequences of these and other fishery<br />

Page 67 of 151


emovals are apparent in the range of information available for the stock. The assessment team considers that, though there are some inherent<br />

uncertainties such as the absolute stock size or the scale of all removals from the stock, the comprehensive range of information on the biology<br />

of sea bass and its response to environmental influences is sufficient to support the current harvest strategy.<br />

Recommendation: Encouragement of the extension of the collection of biological information on sea bass landed in the Netherlands.<br />

All SG 60 and SG 80 requirements are satisfied. A score of 80 is therefore awarded.<br />

Score:<br />

80<br />

Audit trace references<br />

Page 68 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

1.2.4 Assessment of stock<br />

status: There is an<br />

adequate assessment<br />

of the stock status<br />

(1-60) The assessment<br />

estimates stock status relative to<br />

reference points.<br />

(2-60) The major sources of<br />

uncertainty are identified.<br />

(1-80) The assessment is<br />

appropriate for the stock and for<br />

the harvest control rule, and is<br />

evaluating stock status relative<br />

to reference points.<br />

(2-80) The assessment takes<br />

uncertainty into account.<br />

(3-80) The stock assessment is<br />

subject to peer review.<br />

(1-100) The assessment is<br />

appropriate for the stock and for<br />

the harvest control rule and<br />

takes into account the major<br />

features relevant to the biology<br />

of the species and the nature of<br />

the fishery.<br />

(2-100) The assessment takes<br />

into account uncertainty and is<br />

evaluating stock status relative<br />

to reference points in a<br />

probabilistic way.<br />

(3-100) The assessment has<br />

been tested and shown to be<br />

robust. Alternative hypotheses<br />

and assessment approaches<br />

have been rigorously explored.<br />

(4-100) The assessment has<br />

been internally and externally<br />

peer reviewed.<br />

Scoring comments<br />

There is an assessment methodology for evaluating sea bass stock status relative to the reference points defined in the harvest strategy (yield<br />

per recruit and MSY), which takes account of all of the major features relevant to the biology of the species and the nature of the fishery. The<br />

assessments take uncertainty into account, and have been subject to peer review (Kupschus,et al., 2007 and Kupschus, 2010, by ICES), and<br />

published (Pawson et al., 2005; Pawson et al., 2007b). These models are considered appropriate for the stock by ICES SGBASS and WGNEW<br />

The assessment team notes, however that the most recent assessments of this stock (Kupschus et al., 2007, Kupschus 2010) are thought to be<br />

increasingly uncertain, other than in terms of trends in SSB. Consequently, the stock status at present is uncertain.<br />

Score:<br />

80 (default score RBF on 1.1.1)<br />

Page 69 of 151


Audit trace references<br />

Insert refs quoted under scoring comments<br />

.<br />

Principle 2 Fishing operations should allow for the maintenance of the structure, productivity, function and diversity of the<br />

ecosystem<br />

(including habitat and associated dependent and ecologically related species) on which the fishery depends<br />

Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.1 Retained non-target species<br />

2.1.1 Status: The fishery<br />

does not pose a risk of<br />

serious or irreversible<br />

harm to the retained<br />

species and does not<br />

hinder recovery of<br />

depleted retained<br />

species.<br />

Scoring comments<br />

(1-60) Main retained species are<br />

likely to be within biologically<br />

based limits or if outside the<br />

limits there are measures in<br />

place that are expected to<br />

ensure that the fishery does not<br />

hinder recovery and rebuilding of<br />

the depleted species.<br />

(2-60) If the status is poorly<br />

known there are measures or<br />

practices in place that are<br />

expected to result in the fishery<br />

not causing the retained species<br />

to be outside biologically based<br />

limits or hindering recovery.<br />

(1-80) Main retained species are<br />

highly likely to be within<br />

biologically based limits, or if<br />

outside the limits there is a<br />

partial strategy of demonstrably<br />

effective management measures<br />

in place such that the fishery<br />

does not hinder recovery and<br />

rebuilding.<br />

(1-100) There is a high degree of<br />

certainty that retained species<br />

are within biologically based<br />

limits.<br />

(2-100) Target reference points<br />

are defined and retained species<br />

are at or fluctuating around their<br />

target reference points.<br />

Page 70 of 151


The main retained species besides sea bass is cod. Cod in the North Sea is currently outside safe biological limits and a recovery plan is in<br />

place. The members of the VBHL generally have sufficient cod quota to cover the total catch of cod that the UoC landed in the years 2006 –<br />

2009 (below 30 t p a), which is considered too low to significantly hinder the recovery of the cod stock. A recovery plan for cod is in place, with<br />

the aim to achieve a target fishing mortality of 0.4 to which the UoC is a negligible contributor.<br />

Cod is the only species that is considered a main retained species in this fishery. The catches of other species are (pollack, ling, gurnards) are<br />

so low that they need not be considered here.<br />

The main retained species other than sea bass is cod, which ICES (ICES 2010) considers to be suffering reduced reproductive capacity and is<br />

in danger of being harvested unsustainably. However, there is a partial strategy of demonstrably effective management measures in place such<br />

that the UoC fishery does not hinder recovery and rebuilding of North Sea cod.<br />

All SG 80 requirements are satisfied.<br />

Score:<br />

80<br />

Audit trace references<br />

ICES, 2010<br />

Page 71 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.1.2 Management<br />

strategy: There is a<br />

strategy in place for<br />

managing retained<br />

species that is<br />

designed to ensure<br />

the fishery does not<br />

pose a risk of serious<br />

or irreversible harm to<br />

retained species.<br />

(1-60) There are measures in<br />

place, if necessary, that are<br />

expected to maintain the main<br />

retained species at levels which<br />

are highly likely to be within<br />

biologically based limits, or to<br />

ensure the fishery does not<br />

hinder their recovery and<br />

rebuilding.<br />

(2-60) The measures are<br />

considered likely to work, based<br />

on plausible argument (e.g.,<br />

general experience, theory or<br />

comparison with similar<br />

fisheries/species).<br />

(1-80) There is a partial strategy<br />

in place, if necessary that is<br />

expected to maintain the main<br />

retained species at levels which<br />

are highly likely to be within<br />

biologically based limits, or to<br />

ensure the fishery does not<br />

hinder their recovery and<br />

rebuilding.<br />

(2-80) There is some objective<br />

basis for confidence that the<br />

partial strategy will work, based<br />

on some information directly<br />

about the fishery and/or species<br />

involved.<br />

(3-80) There is some evidence<br />

that the partial strategy is being<br />

implemented successfully.<br />

(1-100) There is a strategy in<br />

place for managing retained<br />

species.<br />

(2-100) The strategy is mainly<br />

based on information directly<br />

about the fishery and/or species<br />

involved, and testing supports<br />

high confidence that the strategy<br />

will work.<br />

(3-100) There is clear evidence<br />

that the strategy is being<br />

implemented successfully, and<br />

intended changes are occurring.<br />

(4-100) There is some evidence<br />

that the strategy is achieving its<br />

overall objective.<br />

Scoring comments<br />

There is an EU Norway recovery plan for cod that was updated in 2008, when a long-term management plan for this stock was adopted (<strong>Council</strong><br />

Regulation (EC) 1342/2008). Thus, there is a partial strategy in place that is expected to ensure the UoC fishery does not hinder the recovery<br />

and rebuilding of North Sea cod. The rules in the long-term management plan have been implemented through the TACs set by the European<br />

Commission, and there is evidence that the fishing mortality has been reduced<br />

ICES evaluated both plans in 2009 and concluded they are in accordance with the precautionary approach if implemented and enforced<br />

adequately. Therefore, there is some objective basis for confidence that the partial strategy will work, based on information directly about the<br />

fishery and/or species involved.<br />

Page 72 of 151


The vessels within the UoC have been able to obtain enough quota to cover their cod landings, which are small and are counted against the cod<br />

quota that has been established in the framework of the cod recovery plan.<br />

Whilst cod landings under 50 kg of wet weight have to be reported at landing and are counted against the national cod quota, they are not<br />

counted against individual quotas. This rule could be an incentive for underreporting or high grading with the aim of staying below 50 kg limit.<br />

The overall landings of the client fishery are considered to be too low to have any significant impact on cod stock recovery in the North Sea.<br />

Recommendation: Develop measures in the fisheries management plan to prevent high grading or underreporting.<br />

All SG 80 requirements are satisfied.<br />

Score:<br />

80<br />

Audit trace references<br />

COUNCIL REGULATION (EC) No 1342/2008 of 18 December 2008 establishing a long-term plan for cod stocks and the fisheries exploiting<br />

those stocks and repealing Regulation (EC) No 423/2004; ICES 2010.<br />

Page 73 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.1.3 Information /<br />

monitoring:<br />

Information on the<br />

nature and extent of<br />

retained species is<br />

adequate to determine<br />

the risk posed by the<br />

fishery and the<br />

effectiveness of the<br />

strategy to manage<br />

retained species.<br />

(1-60) Qualitative information is<br />

available on the amount of main<br />

retained species taken by the<br />

fishery.<br />

(2-60) Information is adequate to<br />

qualitatively assess outcome<br />

status with respect to biologically<br />

based limits.<br />

(3-60) Information is adequate to<br />

support measures to manage<br />

main retained species.<br />

(1-80) Qualitative information and<br />

some quantitative information are<br />

available on the amount of main<br />

retained species taken by the<br />

fishery.<br />

(2-80) Information is sufficient to<br />

estimate outcome status with<br />

respect to biologically based<br />

limits.<br />

(3-80) Information is adequate to<br />

support a partial strategy to<br />

manage main retained species.<br />

(4-80) Sufficient data continue to<br />

be collected to detect any<br />

increase in risk level (e.g. due to<br />

changes in the outcome indicator<br />

scores or the operation of the<br />

fishery or the effectiveness of the<br />

strategy).<br />

(1-100) Accurate and verifiable<br />

information is available on the<br />

catch of all retained species and<br />

the consequences for the status<br />

of affected populations.<br />

(2-100) Information is sufficient to<br />

quantitatively estimate outcome<br />

status with a high degree of<br />

certainty.<br />

(3-100) Information is adequate<br />

to support a comprehensive<br />

strategy to manage retained<br />

species, and evaluate with a high<br />

degree of certainty whether the<br />

strategy is achieving its objective.<br />

(4-100) Monitoring of retained<br />

species is conducted in sufficient<br />

detail to assess ongoing<br />

mortalities to all retained species.<br />

Scoring comments<br />

Quantitative information about the amount of cod landed by the fishery is available through the logbook system. The data are stored in the VIRIS<br />

system of the AID (1-80). The information is sufficient to conclude that the amount of cod taken in this fishery will not significantly affect the<br />

outcome status with respect to biologically based limits (2-80). The information is adequate to support a partial strategy to manage main retained<br />

species (cod) (3-80).<br />

Since all cod landings are recorded and discarding of cod is very limited, sufficient data continue to be collected from the UoC to detect any<br />

increase in risk level (e.g. due to changes in the outcome indicator scores or the operation of the fishery or the effectiveness of the strategy).<br />

Page 74 of 151


All SG 80 requirements are satisfies and a score of 80 awarded.<br />

Score:<br />

80<br />

Audit trace references<br />

Landing statistics in the VIRIS system<br />

Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.2 Discarded species (also known as “by catch” or<br />

“discards”)<br />

2.2.1 Status: The fishery<br />

does not pose a risk of<br />

serious or irreversible<br />

harm to the by catch<br />

species or species<br />

groups and does not<br />

hinder recovery of<br />

depleted by catch<br />

species or species<br />

groups.<br />

(1-60) Main by catch species are<br />

likely to be within biologically<br />

based limits, or if outside such<br />

limits there are mitigation<br />

measures in place that are<br />

expected to ensure that the<br />

fishery does not hinder recovery<br />

and rebuilding.<br />

(2-60) If the status is poorly<br />

known there are measures or<br />

practices in place that are<br />

expected result in the fishery not<br />

causing the by catch species to<br />

be biologically based limits or<br />

hindering<br />

recovery.<br />

(1-80) Main by catch species are<br />

highly likely to be within<br />

biologically based limits or if<br />

outside such limits there is a<br />

partial strategy of demonstrably<br />

effective mitigation measures in<br />

place such that the fishery does<br />

not hinder recovery and<br />

rebuilding.<br />

(1-100) There is a high degree of<br />

certainty that by catch species<br />

are within biologically based<br />

limits.<br />

Scoring comments<br />

The client fishery is a very clean fishery. All species caught in this fishery are retained species, and there is no discarding of species that are not<br />

retained or otherwise considered to be ETP species. Therefore, the fishery does not pose a risk of serious or irreversible harm to any by catch<br />

species and does not hinder recovery of depleted by catch species<br />

Page 75 of 151


FAMv2 7.1.10 states ―If it can be shown that a fishery has no impact on a particular Component, it would receive a score of 100 under the<br />

Outcome PI‖‖<br />

Therefore a score of 100 is awarded.<br />

Score:<br />

100<br />

Audit trace references<br />

Page 76 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.2.2 Management<br />

strategy: There is a<br />

strategy in place for<br />

managing by catch<br />

that is designed to<br />

ensure the fishery<br />

does not pose a risk of<br />

serious or irreversible<br />

harm to by catch<br />

populations.<br />

Scoring comments<br />

(1-60) There are measures in<br />

place, if necessary, which are<br />

expected to maintain main by<br />

catch species at levels which are<br />

highly likely to be within<br />

biologically based limits or to<br />

ensure that the fishery does not<br />

hinder their recovery.<br />

(2-60) The measures are<br />

considered likely to work, based<br />

on plausible argument (e.g.<br />

general experience, theory or<br />

comparison with similar<br />

fisheries/species).<br />

(1-80) There is a partial strategy<br />

in place, if necessary, for<br />

managing by catch that is<br />

expected to maintain main by<br />

catch species at levels which are<br />

highly likely to be within<br />

biologically based limits or to<br />

ensure that the fishery does not<br />

hinder their recovery.<br />

(2-80) There is some objective<br />

basis for confidence that the<br />

partial strategy will work, based<br />

on some information directly<br />

about the fishery and/or the<br />

species involved.<br />

(3-80) There is some evidence<br />

that the partial strategy is being<br />

implemented successfully.<br />

(1-100) There is a strategy in<br />

place for managing and<br />

minimising by catch.<br />

(2-100) The strategy is mainly<br />

based on information directly<br />

about the fishery and/or species<br />

involved, and testing supports<br />

high confidence that the strategy<br />

will work.<br />

(3-100) There is clear evidence<br />

that the strategy is being<br />

implemented successfully, and<br />

intended changes are occurring.<br />

There is some evidence that the<br />

strategy is achieving its<br />

objective.<br />

The fishing practice is to target only sea bass and cod with lures, and it is expected that it will continue to have no impact on by catch species.<br />

This means that the fishery will continue to have no impact on this component and from monitoring by VBHL of its member catches any change<br />

would be detected. (Therefore the requirement at SG100 is met*.)<br />

*(FAM v2 7.1.26 states: If it has been shown that a fishery has no impact on a particular Component and has therefore scored 100 under the<br />

Outcome PI, it shall still be scored under the Management Strategy PI. But to meet the requirement at SG100 this may simply comprise a<br />

Page 77 of 151


statement of intent about continuing to have no impact and ongoing monitoring to ensure that no impact occurs.)<br />

Score:<br />

100<br />

Audit trace references<br />

Page 78 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.2.3 Information /<br />

monitoring:Information<br />

on the nature and<br />

amount of by catch is<br />

adequate to determine<br />

the risk posed by the<br />

fishery and the<br />

effectiveness of the<br />

strategy to manage by<br />

catch.<br />

Scoring comments<br />

(1-60) Qualitative information is<br />

available on the amount of main<br />

by catch species affected by the<br />

fishery.<br />

(2-60) Information is adequate to<br />

broadly understand outcome<br />

status with respect to biologically<br />

based limits.<br />

(3-60) Information is adequate to<br />

support measures to manage by<br />

catch.<br />

(1-80) Qualitative information<br />

and some quantitative<br />

information are available on the<br />

amount of main by catch species<br />

affected by the fishery.<br />

(2-80) Information is sufficient to<br />

estimate outcome status with<br />

respect to biologically based<br />

limits.<br />

(3-80) Information is adequate to<br />

support a partial strategy to<br />

manage main by catch species.<br />

(4-80) Sufficient data continue to<br />

be collected to detect any<br />

increase in risk to main by catch<br />

species (e.g. due to changes in<br />

the outcome indicator scores or<br />

the operation of the fishery or<br />

the effectiveness of the<br />

strategy).<br />

(1-100) Accurate and verifiable<br />

information is available on the<br />

amount of all by catch and the<br />

consequences for the status of<br />

affected populations.<br />

(2-100) information is sufficient<br />

to quantitatively estimate<br />

outcome status with respect to<br />

biologically based limits with a<br />

high degree of certainty.<br />

(3-100) Information is adequate<br />

to support a comprehensive<br />

strategy to manage by catch,<br />

and evaluate with a high degree<br />

of certainty whether a strategy is<br />

achieving its objective.<br />

(4-100) Monitoring of by catch<br />

data is conducted in sufficient<br />

detail to assess ongoing<br />

mortalities to all by catch<br />

species.<br />

Page 79 of 151


Expert knowledge and the information available on landings form a sound basis for the conclusion that there are no by catch species in this<br />

fishery and that all species caught are retained (when above the minimum landing size). The information is appropriate with the scale and the<br />

intensity of the fishery (1-80) and sufficient to estimate outcome status with respect to biologically based limits (2-80).<br />

Information about the catches in this fishery and the fishing techniques of the VBHL members is adequate to support a partial strategy to manage<br />

main by catch species.<br />

The fishing operations of the client members are monitored by the VBHL. Sufficient data continue to be collected to detect any increase in risk to<br />

main by catch species (e.g. due to changes in the outcome indicator scores or the operation of the fishery or the effectiveness of the strategy) (4-<br />

80).<br />

Recommendation: that monitoring of by catch data is conducted in sufficient detail to assess any mortality of potential by catch species.<br />

Score:<br />

80<br />

Audit trace references<br />

Page 80 of 151


2.3 Endangered, Threatened and Protected (ETP) species<br />

Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.3.1 Status: The fishery<br />

meets<br />

national and<br />

international<br />

requirements for<br />

protection<br />

of ETP species.<br />

The fishery does not<br />

pose a risk of serious<br />

or<br />

irreversible harm to<br />

ETP<br />

species and does not<br />

hinder recovery of<br />

ETP<br />

species.<br />

(1-60) Known effects of the<br />

fishery are likely to be within<br />

limits of national and<br />

international requirements for<br />

protection of ETP species.<br />

(2-60) Known direct effects are<br />

unlikely to create unacceptable<br />

impacts to ETP species.<br />

(1-80) The effects of the fishery<br />

are known and are highly likely<br />

to be within limits of national and<br />

international requirements for<br />

protection of ETP species.<br />

(2-80) Direct effects are highly<br />

unlikely to create unacceptable<br />

impacts to ETP species.<br />

(3-80) Indirect effects have been<br />

considered and are thought to<br />

be unlikely to create<br />

unacceptable impacts.<br />

(1-100) There is a high degree of<br />

certainty that the effects of the<br />

fishery are within limits of<br />

national and international<br />

requirements for protection of<br />

ETP species.<br />

(2-100) There is a high degree of<br />

confidence that there are no<br />

significant detrimental effects<br />

(direct and indirect) of the fishery<br />

on ETP species.<br />

Scoring comments<br />

Because the UoC fishes with rod and line, it is considered impossible that marine mammals are caught. There is a high degree of certainty that<br />

the effects of the fishery are within limits of national and international requirements for protection of ETP species.<br />

Very occasionally a bird might accidentally get tangled up in a fishing line. When this happens the bird will immediately be released and most<br />

probably will survive the incident. Indirect effects have been considered and are thought to be unlikely to create unacceptable impacts.<br />

Page 81 of 151


Rare fish like skates or sturgeons are very unlikely to be caught due to the fishing method. Fishermen state that they have never been caught.<br />

Very occasionally a shark is caught by one of the vessels. These sharks have been described by the client as being spurdog (spiny dogfish).<br />

The retention of spurdog in the North Sea is prohibited as the species is IUCN-red-listed as Near Threatened and the stock is considered over<br />

exploited. There is a high degree of confidence that the occasionally incidental catch of spurdog and its return to the water has no significant<br />

detrimental effects on this species.<br />

All SG 100 requirements are satisfied and a score of 100 awarded.<br />

Score:<br />

100<br />

Audit trace references<br />

Page 82 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.3.2 Management<br />

strategy:<br />

The fishery has in<br />

place<br />

precautionary<br />

management<br />

strategies designed to:<br />

- meet national and<br />

international<br />

requirements;<br />

- ensure the fishery<br />

does<br />

not pose a risk of<br />

serious<br />

or irreversible harm to<br />

ETP species;<br />

- ensure the fishery<br />

does<br />

not hinder recovery of<br />

ETP<br />

species; and<br />

- minimise mortality of<br />

ETP species.<br />

(1-60) There are measures in<br />

place that minimise mortality,<br />

and are expected to be highly<br />

likely to achieve national and<br />

international requirements for<br />

the protection of ETP species.<br />

(2-60) The measures are<br />

considered likely to work, based<br />

on plausible argument (e.g.<br />

general experience, theory or<br />

comparison with similar<br />

fisheries/species).<br />

(1-80) There is a strategy in<br />

place for managing the fishery‘s<br />

impact on ETP species,<br />

including measures to minimise<br />

mortality that is designed to be<br />

highly likely to achieve national<br />

and international requirements<br />

for the protection of ETP<br />

species.<br />

(2-80) There is an objective<br />

basis for confidence that the<br />

strategy will work, based on<br />

some information directly about<br />

the fishery and/or the species<br />

involved.<br />

(3-80) There is evidence that the<br />

strategy is being implemented<br />

successfully.<br />

(1-100) There is a<br />

comprehensive strategy in place<br />

for managing the fishery‘s<br />

impact on ETP species,<br />

including measures to minimise<br />

mortality that is designed to<br />

achieve above national and<br />

international requirements for<br />

the protection of ETP species.<br />

(2-100) The strategy is mainly<br />

based on information directly<br />

about the fishery and/or species<br />

involved, and a quantitative<br />

analysis supports<br />

high confidence that the strategy<br />

will work.<br />

(3-100) There is clear evidence<br />

that the strategy is being<br />

implemented successfully, and<br />

intended<br />

changes are occurring. There is<br />

evidence that the strategy is<br />

achieving its objective.<br />

Scoring comments<br />

The fact that the client fishes with rod and line and specifically and very selectively targets sea bass and cod can be considered an effective<br />

strategy to prevent the catch or mortality of ETP species (1-80).<br />

There is an objective basis for confidence that the strategy will work, based on information directly about the fishery and/or the species involved<br />

(2-80) and there is anecdotal evidence that the strategy is being implemented successfully (3-80).<br />

All SG 80 requirements are satisfied and a score of 80 awarded.<br />

Page 83 of 151


Score:<br />

80<br />

Audit trace references<br />

Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.3.3 Information /<br />

monitoring<br />

Relevant information<br />

is<br />

collected to support<br />

the<br />

management of<br />

fishery<br />

impacts on ETP<br />

species,<br />

including:<br />

- information for the<br />

development of the<br />

management strategy;<br />

- information to assess<br />

the<br />

effectiveness of the<br />

management strategy;<br />

and<br />

- information to<br />

determine<br />

the outcome status of<br />

ETP<br />

species.<br />

(1-60) Information is adequate to<br />

broadly understand the impact of<br />

the fishery on ETP species.<br />

(2-60) Information is adequate to<br />

support measures to manage<br />

the impacts on ETP species<br />

(3-60) Information is sufficient to<br />

qualitatively<br />

estimate the fishery related<br />

mortality of ETP species.<br />

(1-80) Information is sufficient to<br />

determine whether the fishery<br />

may be a threat to protection<br />

and recovery of the ETP<br />

species, and if so, to measure<br />

trends and support a full strategy<br />

to manage impacts.<br />

(2-80) Sufficient data are<br />

available to allow fishery related<br />

mortality and the impact of<br />

fishing to be quantitatively<br />

estimated for ETP species.<br />

(1-100) Information is sufficient<br />

to quantitatively<br />

estimate outcome status with a<br />

high degree of certainty.<br />

(2-100) Information is adequate<br />

to support a<br />

comprehensive strategy to<br />

manage impacts, minimize<br />

mortality and injury of ETP<br />

species, and evaluate with a<br />

high degree of certainty whether<br />

a strategy is achieving its<br />

objectives.<br />

(3-100) Accurate and verifiable<br />

information is<br />

available on the magnitude of all<br />

impacts, mortalities and injuries<br />

and the consequences for the<br />

status of ETP species<br />

Scoring comments<br />

Expert knowledge augmented by information provided by the client allows for the conclusion that information is sufficient to determine that the<br />

fishery is no threat to protection and recovery of ETP species (1-80)<br />

Page 84 of 151


All landings by the client fishery are entered in the logbook. If ETP fish species were caught and retained (which has not been the case in<br />

recent years), these data would allow fishery related mortality and the impact of fishing to be quantitatively estimated. Although there is no<br />

independent verifiable information on possible discards of ETP species, the client has only reported very low levels of spurdog catches and<br />

discards. It is clear that marine mammals are not caught by rod and line, and it can be concluded that mortality caused by this fishery is zero<br />

(2-80)<br />

SG 80 requirements are satisfied and a score of 80 awarded.<br />

Score:<br />

80<br />

Audit trace references<br />

Page 85 of 151


2.4 Habitat<br />

Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.4.1 Status: The fishery<br />

does not cause<br />

serious or<br />

irreversible harm to<br />

habitat<br />

structure, considered<br />

on a<br />

regional or bioregional<br />

basis, and function.<br />

(1-60) The fishery is unlikely to<br />

reduce habitat structure and<br />

function to a point where there<br />

would be serious or irreversible<br />

harm.<br />

(1-80) The fishery is highly<br />

unlikely to reduce habitat<br />

structure and function to a point<br />

where there would be serious or<br />

irreversible harm.<br />

(1-100) There is evidence that<br />

the fishery is highly unlikely to<br />

reduce habitat structure and<br />

function to a point where there<br />

would be serious or irreversible<br />

harm.<br />

Scoring comments<br />

The seafloor and habitat structures in the southern North Sea are not considered sensitive to the only impact likely to be due to the UoC‘s<br />

fishery: namely anchoring with the relatively lightweight anchors. There is some evidence that the fishery is highly unlikely to reduce habitat<br />

structure and function to a point where there would be serious or irreversible harm.<br />

Score:<br />

95<br />

Audit trace references<br />

Page 86 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.4.2 Management<br />

strategy:<br />

There is a strategy in<br />

place<br />

that is designed to<br />

ensure<br />

the fishery does not<br />

pose a<br />

risk of serious or<br />

irreversible harm to<br />

habitat<br />

types.<br />

(1-60) There are measures in<br />

place, if necessary, that are<br />

expected to achieve the Habitat<br />

Outcome 80 level of<br />

performance.<br />

(2-60) The measures are<br />

considered likely to work, based<br />

on plausible argument (e.g.<br />

general experience, theory or<br />

comparison with similar<br />

fisheries/habitats).<br />

(1-80) There is a partial strategy<br />

in place, if necessary, that is<br />

expected to achieve the Habitat<br />

Outcome 80 level of<br />

performance or above.<br />

(2-80) There is some objective<br />

basis for confidence that the<br />

partial strategy will work, based<br />

on some information directly<br />

about the fishery<br />

and/or habitats involved.<br />

(3-80) There is some evidence<br />

that the partial strategy is being<br />

implemented successfully.<br />

(1-100) There is a strategy in<br />

place for managing the impact of<br />

the fishery on habitat types.<br />

(2-100) The strategy is mainly<br />

based on information directly<br />

about the fishery and/or habitats<br />

involved, and testing supports<br />

high confidence that the strategy<br />

will work.<br />

(3-100) There is clear evidence<br />

that the strategy is being<br />

implemented successfully, and<br />

intended changes are occurring.<br />

There is some evidence<br />

that the strategy is achieving its<br />

objective.<br />

Scoring comments<br />

The fishing method used can be considered as a partial strategy that is expected to effectively minimise impacts of the fishery on the sea<br />

bottom so as to achieve the Habitat Outcome 80 level of performance (1-80).<br />

From expert judgment and the plausible argument that fishing with rod and line in the way client operates does not pose a risk of serious or<br />

irreversible harm to habitat types, it is concluded that this partial strategy is likely to work (2-80) and that there is some evidence that the partial<br />

strategy is being implemented successfully.<br />

Score:<br />

80<br />

Audit trace references<br />

Page 87 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.4.3 Information /<br />

monitoring:<br />

Information is<br />

adequate to determine<br />

the risk posed to<br />

habitat types by the<br />

fishery<br />

and the effectiveness<br />

of the strategy to<br />

manage impacts on<br />

habitat types.<br />

(1-60) There is a basic<br />

understanding of the types and<br />

distribution of main habitats in<br />

the area of the fishery.<br />

(2-60) Information is adequate to<br />

broadly understand the main<br />

impacts of gear use on the main<br />

habitats, including spatial extent<br />

of interaction.<br />

(1-80) The nature, distribution<br />

and vulnerability of all main<br />

habitat types in the fishery area<br />

are known at a level of detail<br />

relevant to the scale and<br />

intensity of the fishery.<br />

(2-80) Sufficient data are<br />

available to allow the nature of<br />

the impacts of the fishery on<br />

habitat types to be identified and<br />

there is reliable information on<br />

the spatial extent, timing and<br />

location of use of the fishing<br />

gear.<br />

(3-80) Sufficient data continue to<br />

be collected to detect any<br />

increase in risk to habitat (e.g.<br />

due to changes in the outcome<br />

indicator scores or the operation<br />

of the fishery or the<br />

effectiveness of the measures).<br />

(1-100) The distribution of<br />

habitat types is known over their<br />

range, with particular attention to<br />

the occurrence of vulnerable<br />

habitat types.<br />

(2-100) Changes in habitat<br />

distributions over time are<br />

measured.<br />

(3-100) The physical impacts of<br />

the gear on the habitat types<br />

have been quantified fully.<br />

Scoring comments<br />

The North Sea is the most intensively investigated sea area in the world. Generations of zoologists, botanists and hydrographers — and more<br />

recently microbiologists, meteorologists, climatologists, chemists, pathologists and toxicologists — have produced an impressive body of<br />

knowledge (Kinne, 1995).<br />

The nature, distribution and vulnerability of all main habitat types in the fishery area are known at a level of detail relevant to the scale and<br />

intensity of the fishery (1-80).<br />

The distribution of North Sea bottom habitat types and their sensitivity for bottom impacts such as trawling has been investigated in detail.<br />

Sufficient knowledge is available to allow the nature of the impacts of a rod and line fishery on different types of sea bottom (sand, gravel or<br />

Page 88 of 151


mud) to be identified and from data provided by the client there is reliable information on the spatial extent, timing and location of use of the<br />

fishing gear. (2-80).<br />

The VHBL members only fish with rod and line and no other practices are permitted. The VBHL monitors the activities of its members and this<br />

monitoring ensures that any increase in risk to habitat would be detected in an early stage. (3-80).<br />

Score:<br />

80<br />

Audit trace references<br />

Page 89 of 151


2.5 Ecosystem<br />

Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.5.1 Status: The fishery<br />

does not cause<br />

serious or irreversible<br />

harm to the key<br />

elements of<br />

ecosystem structure<br />

and function.<br />

(1-60) The fishery is unlikely to<br />

disrupt the key elements<br />

underlying ecosystem structure<br />

and function to a point where<br />

there would be a serious or<br />

irreversible harm.<br />

(1-80) The fishery is highly<br />

unlikely to disrupt the key<br />

elements underlying ecosystem<br />

structure and function to a point<br />

where there would be a serious<br />

or irreversible harm.<br />

(1-100) There is evidence that<br />

the fishery is highly unlikely to<br />

disrupt the key elements<br />

underlying ecosystem structure<br />

and function to a point where<br />

there would be a serious or<br />

irreversible harm.<br />

Scoring comments<br />

The only impact of this fishery on the ecosystem is the removal of a limited amount of predatory fish (sea bass, cod and pollack) from the<br />

ecosystem. It is highly unlikely that this will affect ecosystem structure, trophic relationships or biodiversity to a point where there would be a<br />

serious or irreversible harm.<br />

Score:<br />

90<br />

Audit trace references<br />

Page 90 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.5.2<br />

Management<br />

strategy:<br />

There are measures in<br />

place to ensure the<br />

fishery does not pose<br />

a risk of serious or<br />

irreversible harm to<br />

ecosystem structure<br />

and function.<br />

(1-60) There are measures in<br />

place, if necessary, that take into<br />

account potential impacts of the<br />

fishery on key elements of the<br />

ecosystem.<br />

(2-60) The measures are<br />

considered likely to work, based<br />

on plausible argument (e.g.,<br />

general experience, theory or<br />

comparison with similar<br />

fisheries/ ecosystems).<br />

(1-80) There is a partial strategy<br />

in place, if necessary, that takes<br />

into account available<br />

information and is expected to<br />

restrain impacts of the fishery on<br />

the ecosystem so as to achieve<br />

the Ecosystem Outcome 80 level<br />

of performance.<br />

(2-80) The partial strategy is<br />

considered likely to work, based<br />

on plausible argument (e.g.,<br />

general experience, theory or<br />

comparison with similar<br />

fisheries/ ecosystems).<br />

(3-80) There is some evidence<br />

that the measures comprising<br />

the partial strategy are being<br />

implemented successfully.<br />

(1-100) There is a strategy that<br />

consists of a plan, containing<br />

measures to address all main<br />

impacts of the fishery on the<br />

ecosystem, and at least some of<br />

these measures are in place.<br />

The plan and measures are<br />

based on well understood<br />

functional relationships between<br />

the fishery and the Components<br />

and elements of the ecosystem.<br />

(2-100) This plan provides for<br />

development of a full strategy<br />

that restrains impacts on the<br />

ecosystem to ensure the fishery<br />

does not cause serious or<br />

irreversible harm.<br />

(3-100) The measures are<br />

considered likely to work based<br />

on prior experience, plausible<br />

argument or information directly<br />

from the fishery/ecosystems<br />

involved.<br />

(4-100) There is evidence that<br />

the measures are being<br />

implemented successfully.<br />

Scoring comments<br />

The fishing method used can be considered as a partial strategy that is expected to effectively restrain impacts of the fishery on the ecosystem<br />

so as to achieve the Ecosystem Outcome 80 level of performance (1-80).<br />

From expert judgment and the plausible argument that fishing with rod and line in the way client operates does not pose a risk of serious or<br />

Page 91 of 151


irreversible harm to ecosystem structure and function, it is concluded that this partial strategy is likely to work (2-80) and that there is some<br />

evidence that the measures comprising the partial strategy are being implemented successfully (3-80).<br />

Recommendation: It is recommended by the assessment team that the client‘s (draft) management plan includes a requirement that litter is<br />

taken to shore and disposed of in a responsible way, and that a replacement is found for the use of lead in lures.<br />

Score:<br />

80<br />

Audit trace references<br />

Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

2.5.3 Information /<br />

monitoring:<br />

There is adequate<br />

knowledge of the<br />

impacts<br />

of the fishery on the<br />

ecosystem.<br />

(1-60) Information is adequate to<br />

identify the key elements of the<br />

ecosystem (e.g. trophic structure<br />

and function, community<br />

composition, productivity pattern<br />

and biodiversity).<br />

(2-60) Main impacts of the<br />

fishery on these key ecosystem<br />

elements can be inferred from<br />

existing information, but have<br />

not been investigated in detail.<br />

(1-80) Information is adequate to<br />

broadly understand the functions<br />

of the key elements of the<br />

ecosystem.<br />

(2-80) Main impacts of the<br />

fishery on these key ecosystem<br />

elements can be inferred from<br />

existing information, but may not<br />

have been investigated in detail.<br />

(3-80) The main functions of the<br />

Components (i.e. target, By<br />

catch, Retained and ETP<br />

species and Habitats) in the<br />

ecosystem are known.<br />

(1-100) Information is adequate<br />

to broadly understand the key<br />

elements of the ecosystem.<br />

(2-100) Main interactions<br />

between the fishery and these<br />

ecosystem elements can be<br />

inferred from existing<br />

information, and have been<br />

investigated.<br />

(3-100) The impacts of the<br />

fishery on target, By catch,<br />

Retained and ETP species and<br />

Habitats are identified and the<br />

main functions of these<br />

components in the ecosystem<br />

are understood.<br />

Page 92 of 151


Scoring comments<br />

(4-80) Sufficient information is<br />

available on the impacts of the<br />

fishery on these Components to<br />

allow some of the main<br />

consequences for the ecosystem<br />

to be inferred.<br />

(5-80) Sufficient data continue to<br />

be collected to detect any<br />

increase in risk level (e.g. due to<br />

changes in the outcome<br />

indicator scores or the operation<br />

of the fishery or the<br />

effectiveness of the measures).<br />

(4-100) Sufficient information is<br />

available on the impacts of the<br />

fishery on the components and<br />

elements to allow the main<br />

consequences for the ecosystem<br />

to be inferred.<br />

(5-100) Information is sufficient<br />

to support the development of<br />

strategies to manage ecosystem<br />

impacts.<br />

There is extensive research carried out on North Sea fisheries and the North Seas ecosystem The existing Information on the North Sea<br />

ecosystem is adequate to broadly understand the key elements of the ecosystem (1-100).<br />

Although the main impacts of the UoC have not all been studied in detail, the main impacts of the fishery on these key ecosystem elements can<br />

be inferred from expert knowledge (2-80).<br />

The North Sea is the most intensively investigated sea area in the world, which has generated sufficient knowledge such that the main functions<br />

of the Components (i.e. Target, By catch, Retained and ETP species, and Habitats) in the ecosystem are known,(3-80).<br />

Expert knowledge augmented by information provided by the client allows for the conclusion that there is no significant impact from this fishery<br />

on the ecosystem. Sufficient information is available on the impacts of the fishery on these Components to allow some of the main<br />

consequences for the ecosystem to be inferred,(4-80).<br />

The extensive body of knowledge on the North Sea ecosystem and Information about the fishery is sufficient to support the development of<br />

strategies to manage ecosystem impacts, if necessary (5-100).<br />

Score:<br />

90<br />

Audit trace references<br />

Page 93 of 151


Page 94 of 151


Principle 3 The fishery is subject to an effective management system that respects local, national and international laws and<br />

standards and<br />

incorporates institutional and operational frameworks that require use of the resource to be responsible and<br />

sustainable<br />

Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

3.1 Governance and<br />

Policy<br />

3.1.1 Legal and/or<br />

customary<br />

framework:<br />

The management<br />

system<br />

exists within an<br />

appropriate and<br />

effective<br />

legal and/or<br />

customary<br />

framework which<br />

ensures<br />

that it:<br />

- Is capable of<br />

delivering<br />

sustainable fisheries<br />

in<br />

accordance with MSC<br />

Principles 1 and 2;<br />

- Observes the legal<br />

rights<br />

created explicitly or<br />

established by custom<br />

of<br />

people dependent on<br />

fishing for food or<br />

(1-60) The management system<br />

is generally consistent with<br />

local, national or international<br />

laws or standards that are<br />

aimed at achieving sustainable<br />

fisheries in accordance with<br />

MSC Principles 1 and 2.<br />

(2-60) The management system<br />

incorporates or is subject by law<br />

to a mechanism for the<br />

resolution of legal disputes<br />

arising within the system.<br />

(3-60) Although the<br />

management authority or fishery<br />

may be subject to continuing<br />

court challenges, it is not<br />

indicating a disrespect or<br />

defiance of the law by<br />

repeatedly violating the same<br />

law or<br />

(1-80) The management<br />

system incorporates or is<br />

subject by law to a transparent<br />

mechanism for the resolution of<br />

legal disputes which is<br />

considered to be effective in<br />

dealing with most issues and<br />

that is appropriate to the<br />

context of the fishery.<br />

(2-80) The management<br />

system or fishery is<br />

attempting to comply in a<br />

timely fashion with binding<br />

judicial decisions arising from<br />

any legal challenges.<br />

(1-100) The management<br />

system incorporates or is<br />

subject by law to a transparent<br />

mechanism for the resolution<br />

of legal disputes that is<br />

appropriate to the context of<br />

the fishery and has been<br />

tested and proven to be<br />

effective.<br />

(2-100) The management<br />

system or fishery acts<br />

proactively to avoid legal<br />

disputes or rapidly implements<br />

binding judicial decisions<br />

arising from legal challenges.<br />

Page 95 of 151


livelihood; and<br />

- Incorporates an<br />

appropriate dispute<br />

resolution framework.<br />

regulation necessary for the<br />

sustainability for the fishery.<br />

(4-60) The management system<br />

has a mechanism to generally<br />

respect the legal rights created<br />

explicitly or established by<br />

custom of people dependent on<br />

fishing for food or livelihood in a<br />

manner consistent with the<br />

objectives of MSC Principles 1<br />

and 2.<br />

(3-80) The management<br />

system has a mechanism to<br />

observe the legal rights created<br />

explicitly or established by<br />

custom of people dependent<br />

on fishing for food or livelihood<br />

in a manner consistent with the<br />

objectives of MSC<br />

Principles 1 and 2.<br />

(3-100) The management<br />

system has a mechanism to<br />

formally commit to the legal<br />

rights created explicitly or<br />

established by custom on<br />

people dependent on fishing<br />

for food and livelihood in a<br />

manner consistent with the<br />

objectives of MSC Principles 1<br />

and 2.<br />

Scoring comments<br />

At EU level, fisheries are managed through the CFP in accordance with the basic fisheries regulation (EC. 2371/2002).<br />

Article 2.2 of this regulation states, ―The Common Fisheries Policy shall be guided by the following principles of good governance:<br />

(a) clear definition of responsibilities at the Community, national and local levels;<br />

(b) a decision-making process based on sound scientific advice which delivers timely results;<br />

(c) broad involvement of stakeholders at all stages of the policy from conception to implementation;<br />

(d) consistent with other Community policies, in particular with environmental, social, regional, development, health and consumer protection<br />

policies.<br />

At National Level, the Dutch Government‘s Fisheries Act (Visserijwet, 1963) forms the basis for the implementation of the reformed EU<br />

CFP. (2371/2002). The act established an institutional framework, licensing procedures and control and enforcement responsibilities. The<br />

management system – both at EU and national level – is consistent with local, national or international laws or standards that are aimed at<br />

achieving sustainable fisheries in accordance with MSC Principles 1 and 2 (1-60).<br />

A clear legal framework also exists for judicial decisions to be appealed against both at national, and if necessary EU level. The Dutch legal<br />

system is known to be effective and has transparent mechanisms (court actions, appeal) for the resolution of legal disputes. The Dutch<br />

fisheries management system is subject by law to a transparent mechanism for the resolution of legal disputes that is appropriate to the<br />

Page 96 of 151


context of the fishery and has been tested and proven to be effective.(1-100)<br />

Dutch fisheries are conducted on the basis of fishing licences. The Dutch legal system and the fisheries management system has a<br />

mechanism to observe the legal rights created explicitly or established by custom of people dependent on fishing for food or livelihood in a<br />

manner consistent with the objectives of MSC Principles 1 and 2 (3-80).<br />

The system of consultation and industry representation through a local fishing organization enables the authorities to work in a proactive<br />

manner. The management system or fishery is attempting to comply in a timely fashion with binding judicial decisions arising from any legal<br />

challenges(2-80).<br />

Score:<br />

85<br />

Audit trace references<br />

COUNCIL REGULATION (EC) No 2371/2002 of 20 December 2002 on the conservation and sustainable exploitation of fisheries resources<br />

under the Common Fisheries Policy<br />

Page 97 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

3.1.2 Consultation, roles<br />

and<br />

responsibilities:<br />

The management<br />

system<br />

has effective<br />

consultation<br />

processes that are<br />

open to<br />

interested and<br />

affected<br />

parties. The roles and<br />

responsibilities of<br />

organisations and<br />

individuals who are<br />

involved in the<br />

management process<br />

are clear and<br />

understood by all<br />

relevant parties.<br />

(1-60) Organisations and<br />

individuals involved in the<br />

management process have<br />

been identified. Functions, roles<br />

and responsibilities are<br />

generally understood.<br />

(2-60) The management system<br />

includes consultation processes<br />

that obtain relevant information<br />

from the main affected parties,<br />

including local knowledge, to<br />

inform the management system.<br />

(1-80) Organisations and<br />

individuals involved in the<br />

management process have<br />

been identified. Functions,<br />

roles and responsibilities are<br />

explicitly defined and well<br />

understood for key areas of<br />

responsibility and interaction.<br />

(2-80) The management<br />

system includes consultation<br />

processes that regularly seek<br />

and accept relevant<br />

information, including local<br />

knowledge. The management<br />

system demonstrates<br />

consideration of the information<br />

obtained.<br />

(3-80) The consultation<br />

process provides opportunity<br />

for all interested and affected<br />

parties to be involved.<br />

(1-100) Organisations and<br />

individuals involved in the<br />

management process have<br />

been identified. Functions,<br />

roles and responsibilities are<br />

explicitly defined and well<br />

understood for all areas of<br />

responsibility and interaction.<br />

(2-100) The management<br />

system includes consultation<br />

processes that regularly seek<br />

and accept relevant<br />

information, including local<br />

knowledge. The management<br />

system demonstrates<br />

consideration of the<br />

information<br />

and explains how it is used or<br />

not used.<br />

(3-100) The consultation<br />

process provides opportunity<br />

and encouragement for all<br />

interested and affected parties<br />

to be involved, and facilitates<br />

their effective engagement.<br />

Scoring comments<br />

There is clear and evident division of responsibility between EU and national institutions and authorities. At the national level, national<br />

fisheries administrations and industry bodies (Ministerie van EconomischeZaken, Landbouw en Innovatie (EL&I), AlgemeneInspectiedienst,<br />

IMARES) are responsible for a range of management and regulatory duties, including management of fleet activity, management of national<br />

quota, monitoring and control of all fisheries occurring within national jurisdiction, collection, collation and transmitting of key fishery data,<br />

and undertaking at least a base range of scientific monitoring and development work. Organizations and individuals involved in the<br />

Page 98 of 151


management process have been identified. Functions, roles and responsibilities are explicitly defined and well understood for all areas of<br />

responsibility and interaction (1-100).<br />

Representatives of the Dutch fishing industry are represented at the North Sea Demersal RAC, which has contributed to improved industry /<br />

management / science communication and consultation since the 2002 revision of the CFP. The Fisheries Directorate regularly invites<br />

industry representatives to discuss new policy measures and other management issues (2-80).<br />

Through regular consultation of stakeholders and formalised and regular consultations with the fishing industry the relevant authorities<br />

regularly seek input from industry representatives. The consultation processes provides opportunity for all interested and affected parties to<br />

be involved (3-80).<br />

However for the UoC fishery, the industry representation through the VBHL is not particularly strong.<br />

Recommendation: the VBHL seeks a more professional representation possibly through a national fishery organisation.<br />

Score:<br />

85<br />

Audit trace references<br />

COUNCIL REGULATION (EC) No 2371/2002 of 20 December 2002 on the conservation and sustainable exploitation of fisheries resources<br />

under the Common Fisheries Policy<br />

Page 99 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

3.1.3 Long term<br />

objectives:<br />

The management<br />

policy has clear longterm<br />

objectives to<br />

guide decision-making<br />

that are consistent with<br />

MSC Principles and<br />

Criteria, and<br />

incorporates the<br />

precautionary<br />

approach.<br />

(1-60) Long-term objectives to<br />

guide decision-making,<br />

consistent with MSC Principles<br />

and Criteria and the<br />

precautionary approach, are<br />

implicit within management<br />

policy.<br />

(1-80) Clear long-term<br />

objectives that guide decisionmaking,<br />

consistent with MSC<br />

Principles and Criteria and the<br />

precautionary approach, are<br />

explicit within management<br />

policy.<br />

(1-100) Clear long-term<br />

objectives that guide decisionmaking,<br />

consistent with MSC<br />

Principles and Criteria and the<br />

precautionary approach, are<br />

explicit within and required by<br />

management<br />

policy.<br />

Scoring comments<br />

At the EU level, the reformed CFP has clearly defined long-term objectives aimed at improving the basis of the decision-making process<br />

through sound and transparent scientific advice and increased participation of stakeholders. The CFP is designed to ensure sustainable<br />

exploitation through the application of a precautionary approach, to protect and conserve living aquatic resources and to minimise the impact<br />

of fishing activities on marine eco-systems. One current aim is a progressive implementation of an eco-system-based approach to fisheries<br />

management. It also aims to contribute to efficient fishing activities within an economically viable and competitive fisheries and aquaculture<br />

industry, provide fair standard of living for those who depend on fishing activities and take into account the interests of consumers.<br />

The long-term objectives of the fisheries policy of the Minister of LNV were published in the 1992 Policy Document on Sea and Coastal<br />

Fisheries (Structuurnota Zee– en Kustvisserij), which is aimed at an integration of fishing activities and conserving natural values where<br />

possible and a separation of these two activities where necessary.<br />

In recent years the objectives of the national fisheries policy of the Netherlands have been regularly noted in letters from the Minister of LNV to<br />

the Parliament.<br />

Clear long-term objectives that guide decision making, consistent with MSC Principles and Criteria and the precautionary approach, are<br />

explicit within management policy (1-80).There are some requirements within the management system that long-term objectives are pursued<br />

(1-100 partly met)..<br />

Score:<br />

90<br />

Page 100 of 151


Audit trace references<br />

Page 101 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

3.1.4 Incentives for<br />

sustainable<br />

fishing:<br />

The management<br />

system<br />

provides economic<br />

and<br />

social incentives for<br />

sustainable fishing<br />

and<br />

does not operate with<br />

subsidies that<br />

contribute to<br />

unsustainable fishing.<br />

(1-60) The management system<br />

provides for incentives that are<br />

consistent with achieving the<br />

outcomes expressed by MSC<br />

Principles 1 and 2.<br />

(1-80) The management<br />

system provides for incentives<br />

that are consistent with<br />

achieving the outcomes<br />

expressed by MSC Principles 1<br />

and 2, and seeks to ensure<br />

that negative incentives do not<br />

arise.<br />

(1-100) The management<br />

system provides for incentives<br />

that are consistent with<br />

achieving the outcomes<br />

expressed by MSC Principles 1<br />

and 2, and explicitly considers<br />

incentives in a regular review<br />

of management policy or<br />

procedures to ensure that they<br />

do not contribute to<br />

unsustainable fishing practices.<br />

Scoring comments<br />

The system has no direct subsidies or incentives that contribute to unsustainable fishing or ecosystem degradation by the UoC. Subsidies<br />

for innovations in the fishery are available through the European Fisheries Fund (EuropeesVisserijFonds, EVF), which work as incentives to<br />

develop more environmentally friendly fishing techniques.<br />

The management system provides for incentives that are consistent with achieving the outcomes expressed by MSC Principles 1 and 2, and<br />

seeks to ensure that negative incentives do not arise (1-80). Occasional reviews of management policy or procedures ensure that they do<br />

not contribute to unsustainable fishing practices.<br />

Every vessel that fishes on a commercial basis needs to be registered in the register of fishing vessels and has to have sufficient HP and<br />

GRT and sufficient quota for quota species caught.<br />

Score:<br />

80<br />

Audit trace references<br />

Page 102 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

3.2 Fishery- specific management system<br />

3.2.1 Fishery- specific<br />

objectives:<br />

The fishery has clear,<br />

specific objectives<br />

designed to achieve<br />

the outcomes<br />

expressed by MSC‘s<br />

Principles 1 and 2.<br />

(1-60) Objectives, which are<br />

broadly consistent with<br />

achieving the outcomes<br />

expressed by MSC‘s Principles<br />

1 and 2, are implicit within the<br />

fishery‘s management system.<br />

(1-80) Short and long term<br />

objectives, which are<br />

consistent with achieving the<br />

outcomes expressed by MSC‘s<br />

Principles 1 and 2, are explicit<br />

within the fishery‘s<br />

management<br />

system.<br />

(1-100) Well defined and<br />

measurable short and long<br />

term objectives, which are<br />

demonstrably consistent with<br />

achieving the outcomes<br />

expressed by MSC‘s Principles<br />

1 and 2, are explicit within the<br />

fishery‘s management<br />

system.<br />

Scoring comments<br />

Management objectives for the Dutch fishing industry are formulated at national level by the Ministry for Agriculture, Nature and Food<br />

Quality. Each year, the Director of Fisheries sends a letter with objectives and strategies to all stakeholders involved. The objective for the<br />

North Sea fish stocks is clearly defined as the sustainable harvest and the reduction of impacts on the ecosystem. These apply to fisheries<br />

targeting sea bass as to any other fishery, but are not explicit in this sense.<br />

As sea bass are not a quota species, and there are no biological reference points, no specific objectives relating to stock management have<br />

been formulated. However, the total fishing effort is controlled by regulations limiting the access to the fishery (vessels need to be registered<br />

and have HP and GRT allocations) and by control regulations. Objectives that are broadly consistent with achieving the outcomes<br />

expressed by MSC‘s Principles 1 and 2 are, therefore, implicit within the fishery‘s management system (1-60,1-80 partly met).<br />

CONDITION: The establishment of a more formal decision-making process for the UoC, including research evaluation, consultation and<br />

evaluation against management objectives, has been formulated as a condition.<br />

Score:<br />

70<br />

Audit trace references<br />

Page 103 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

3.2.2 Decision-making<br />

processes:<br />

The fishery-specific<br />

management system<br />

includes effective<br />

decision-making<br />

processes that result<br />

in measures and<br />

strategies to achieve<br />

the objectives.<br />

Scoring comments<br />

(1-60) There are informal<br />

decision-making processes that<br />

result in measures and<br />

strategies to achieve the<br />

fishery-specific objectives.<br />

(2-60) Decision-making<br />

processes respond to serious<br />

issues identified in relevant<br />

research, monitoring, evaluation<br />

and consultation, in a<br />

transparent, timely and adaptive<br />

manner and take some account<br />

of the wider implications of<br />

decisions.<br />

(1-80) There are established<br />

decision-making processes<br />

that result in measures and<br />

strategies to achieve the<br />

fishery-specific objectives.<br />

(2-80) Decision-making<br />

processes respond to serious<br />

and other important issues<br />

identified in relevant research,<br />

monitoring, evaluation and<br />

consultation, in a transparent,<br />

timely and adaptive manner<br />

and take account of the wider<br />

implications of decisions.<br />

(3-80) Decision-making<br />

processes use the<br />

precautionary approach and<br />

are based on best available<br />

information.<br />

(4-80) Explanations are<br />

provided for any actions or lack<br />

of action associated with<br />

findings and relevant<br />

recommendations emerging<br />

from research, monitoring,<br />

evaluation and review activity.<br />

(1-100) There are established<br />

decision-making processes<br />

that result in measures and<br />

strategies to achieve the<br />

fishery-specific objectives.<br />

(2-100) Decision-making<br />

processes respond to all<br />

issues identified in relevant<br />

research, monitoring,<br />

evaluation and consultation, in<br />

a transparent, timely and<br />

adaptive manner and take<br />

account of the wider<br />

implications of decisions.<br />

(3-100) Decision-making<br />

processes use the<br />

precautionary approach and<br />

are based on best available<br />

information.<br />

(4-100) Formal reporting to all<br />

interested stakeholders<br />

describes how the<br />

management system<br />

responded to findings and<br />

relevant recommendations<br />

emerging from research,<br />

monitoring, evaluation and<br />

review activity.<br />

Page 104 of 151


Although few measures and strategies are specifically developed for the sea bass fishery at the national level, the decision-making process<br />

is quite capable of producing such measures and strategies when deemed necessary. There are established decision-making processes<br />

that result in measures and strategies to achieve fishery-specific objectives(1-80).<br />

Consultation processes exist between the national authorities, the fishing industry and NGO‘s. Decision making processes respond to serious<br />

and other important issues identified in relevant research, monitoring, evaluation and consultation, in a transparent, timely and adaptive<br />

manner and take account of the wider implications of decisions (2-80).<br />

A specific policy for the UoC has not been developed. Since the landings of this fishery are relatively low compared to other fishing sectors in<br />

the Netherlands, the fishery has not attracted much attention from fishery managers or NGO‘s.<br />

CONDITION: The establishment of a more formal decision making process for the sea bass fishery, including research and consultation and<br />

evaluation against management objectives, has been formulated as a condition.<br />

Score:<br />

70<br />

Audit trace references<br />

Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

3.2.3 Compliance and<br />

enforcement:<br />

Monitoring, control<br />

and surveillance<br />

mechanisms ensure<br />

the fishery‘s<br />

management<br />

measures are<br />

enforced and<br />

complied with.<br />

(1-60) Monitoring, control and<br />

surveillance mechanisms exist,<br />

are implemented in the fishery<br />

under assessment and there is<br />

a reasonable expectation that<br />

they are effective.<br />

(1-80) A monitoring, control<br />

and surveillance system has<br />

been implemented in the<br />

fishery under assessment and<br />

has demonstrated an ability to<br />

enforce relevant management<br />

measures, strategies and/or<br />

rules.<br />

(1-100) A comprehensive<br />

monitoring, control and<br />

surveillance system has been<br />

implemented in the fishery<br />

under assessment and has<br />

demonstrated a consistent<br />

ability to enforce relevant<br />

management measures,<br />

strategies<br />

and/or rules.<br />

Page 105 of 151


(2-60) Sanctions to deal with<br />

non-compliance exist and there<br />

is some evidence that they are<br />

applied.<br />

(3-60) Fishers are generally<br />

thought to comply with the<br />

management system for the<br />

fishery under assessment,<br />

including, when required,<br />

providing information of<br />

importance to the effective<br />

management of the fishery.<br />

(2-80) Sanctions to deal with<br />

non-compliance exist, are<br />

consistently applied and<br />

thought to provide effective<br />

deterrence.<br />

(3-80) Some evidence exists to<br />

demonstrate fishers comply<br />

with the management system<br />

under assessment, including,<br />

when required, providing<br />

information of importance to<br />

the effective management of<br />

the fishery.<br />

(4-80) There is no evidence of<br />

systematic noncompliance.<br />

(2-100) Sanctions to deal with<br />

non-compliance exist, are<br />

consistently applied and<br />

demonstrably provide effective<br />

deterrence.<br />

(3-100) There is a high degree<br />

of confidence that fishers<br />

comply with the management<br />

system under assessment,<br />

including, providing information<br />

of importance to the effective<br />

management of the fishery.<br />

(4-100) There is no evidence of<br />

systematic noncompliance.<br />

Scoring comments<br />

National Authorities enforce EU Fisheries Regulation and report on their activities to the European Commission.<br />

There is a full system of monitoring, control and surveillance that covers this fishery, with log books and at sea and on land inspections. Both<br />

administrative and criminal sanctions exist to deal with non-compliance with regulations. Licenses can be revoked administratively in case of<br />

severe violations, which result in high monetary penalties (1-80).<br />

Sanctions to deal with non-compliance exist. Sanctions are high and are consistently applied when violations are noticed and thought to<br />

provide effective deterrence (2-80).<br />

The reports of the national enforcement agency (AID) demonstrate that inspections are carried out and that the fishers generally comply with<br />

the management measures under assessment. The AID reports provide information of importance to the effective management of the<br />

fishery (3-80). And show that there is no evidence of systematic noncompliance (4-80).<br />

However, the level of actual control of landings by the UoC is considered quite low.<br />

Recommendation: Develop measures in the fisheries management plan to prevent high grading or underreporting.<br />

Page 106 of 151


Score:<br />

80<br />

Audit trace references<br />

Page 107 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

3.2.4<br />

Research plan:<br />

The fishery has a<br />

research<br />

plan that addresses<br />

the<br />

information needs of<br />

management.<br />

(1-60) Research is undertaken,<br />

as required, to achieve the<br />

objectives consistent with<br />

MSC‘s Principles 1 and 2.<br />

(2-60) Research results are<br />

available to interested parties.<br />

(1-80) A research plan<br />

provides the management<br />

system with a strategic<br />

approach to research and<br />

reliable and timely information<br />

sufficient to achieve the<br />

objectives consistent with<br />

MSC‘s Principles 1 and 2.<br />

(2-80) Research results are<br />

disseminated to all interested<br />

parties in a timely fashion.<br />

(1-100) A comprehensive<br />

research plan provides the<br />

management system with a<br />

coherent and strategic<br />

approach to research across<br />

P1, P2 and P3, and reliable<br />

and timely information<br />

sufficient to achieve the<br />

objectives consistent with<br />

MSC‘s Principles 1 and 2.<br />

(2-100) Research plan and<br />

results are disseminated to all<br />

interested parties in a timely<br />

fashion and are widely and<br />

publicly available.<br />

Scoring comments<br />

ICES establishes terms of references for Working Groups based on information requirements identified by national delegates, including<br />

through industry representations, and by the EC, and has established a Working Group (WGNEW) on (largely non-quota) species for which<br />

scientific advice may be sought under a MoU between the EC and ICES. These new MOU species include sea bass. There is some informal<br />

research planning coordination via the North Sea Demersal RAC, though this has not included sea bass.<br />

The EU research is coordinated by the EC and through the ERA nets and framework projects.<br />

Under the <strong>Marine</strong> Strategy Framework, Member States are required to develop strategies for their marine waters. The marine strategies<br />

must contain a detailed assessment of the state of the environment, a definition of "good environmental status" at regional level and the<br />

establishment of clear environmental targets and monitoring programmes.<br />

At national level, the Dutch government fund national (fisheries) research institutes to conduct projects that automatically involve planning<br />

and selecting research areas that require further information (1-80).<br />

Fundamental research, for example on environmental influences on stock dynamics or ecosystem impact studies, seems to be left to<br />

individual scientists and the priorities and financial constraints of their parent organisations. Such work is undertaken on sea bass by British,<br />

Dutch and French institutes and universities.<br />

Page 108 of 151


Research conducted on sea bass in the Netherlands includes a tagging experiment in which IMARES is currently involved. Data on<br />

recreational catches have been collected by the national organisation of recreational fishermen. The results of this research are<br />

disseminated (through publication and ICES reports) and available to all parties (2-80).<br />

Recommendation: Client should encourage IMARES to develop a research plan for sea bass in Dutch waters and to invite the client to be<br />

involved in this work.<br />

Score:<br />

80<br />

Audit trace references<br />

Page 109 of 151


Scoring criteria Scoring guidepost 60 Scoring guidepost 80 Scoring guidepost 100<br />

3.2.5 Monitoring and<br />

management<br />

performance<br />

evaluation: There is a<br />

system for monitoring<br />

and evaluating the<br />

performance of the<br />

fishery-specific<br />

management system<br />

against its objectives.<br />

There is effective and<br />

timely review of the<br />

fishery-specific<br />

management system.<br />

(1-60) The fishery has in place<br />

mechanisms to evaluate some<br />

parts of the management<br />

system and is subject to<br />

occasional internal review.<br />

(1-80) The fishery has in place<br />

mechanisms to evaluate key<br />

parts of the management<br />

system and is subject to<br />

regular internal and occasional<br />

external review.<br />

(1-100) The fishery has in<br />

place mechanisms to evaluate<br />

all parts of the management<br />

system and is subject to<br />

regular internal and external<br />

review.<br />

Scoring comments<br />

The CFP was reviewed thoroughly prior to its reform in 2002. An obligation to review the basic regulation for the CFP before the end of 2012<br />

is built into the regulation. Resulting policies, operational plans and practices are subject to wide consultation before ratification, and<br />

prescribed monitoring and evaluation processes after ratification. Since 2004, RACs have been established that allow stakeholders to have<br />

an input in the CFP management process. This includes the possibility to critically comment on the CFP management system.<br />

Consideration of the recommendations of reviews is demonstrated.<br />

Each member state must report to the EC annually on control matters. EC fishery inspectors monitor national enforcement activity. EC data<br />

collection requirements, carried out by member states, are reviewed each year.<br />

Within ICES, a Methods Working Group keeps methods for fish stock assessment under regular review.<br />

Management measures (regulations) for the sea bass fishery will be evaluated by the Fisheries Directorate and are subject to internal<br />

review. The management system as operated within the VBHL will be evaluated by the client organization. The VBHL will also review the<br />

national management measures for the Dutch sea bass fishery and its effectiveness and can communicate its findings to the Fisheries<br />

Directorate and control agencies (1-80 partly met). There is no independent review.<br />

CONDITION: The establishment of a more formal decision making process for this fishery including research evaluation and consultation<br />

and evaluation against management objectives with external review has been formulated as a condition.<br />

Page 110 of 151


Score:<br />

75<br />

Audit trace references<br />

Page 111 of 151


APPENDIX B: PEER REVIEW REPORTS<br />

Peer reviewer 1<br />

Overall Opinion<br />

Has the assessment team arrived at an<br />

appropriate conclusion based on the evidence<br />

presented in the assessment report?<br />

Justification:<br />

Not a lot of information is available on sea bass in the<br />

North Sea, but, all information that is available has been<br />

used in the assessment.<br />

Do you think the condition(s) raised are<br />

appropriately written to achieve the SG80<br />

outcome within the specified timeframe?<br />

Justification:<br />

The conditions are described quite precise. It should be<br />

clear what needs to be done and when this should be<br />

achieved.<br />

Yes <strong>Certification</strong> Body Response<br />

This reviewer is chair of ICES WGNEW<br />

and, therefore, understands what is<br />

known about sea bass.<br />

Yes <strong>Certification</strong> Body Response<br />

No comment<br />

Do you think the client action plan is sufficient<br />

to close the conditions raised?<br />

Yes <strong>Certification</strong> Body Response<br />

Justification:<br />

Point noted, and the client will be asked<br />

Yes but: The action described for Condition 1 (1.2.2) “to to amended its action plan to<br />

set out a MSY for North Sea bass” goes much further than correspond to the amended conditions<br />

the Condition mentioned in the Scoring comments: “to (following comments from the other peer<br />

determine what part can be played in the development of<br />

an appropriate harvest control rule”. The action as<br />

phrased in the Action Plan it might be difficult to achieve.<br />

reviewer).<br />

If included:


General Comments on the Assessment Report (optional)<br />

1. In the North Sea two species of the genus Pollachius occur: Pollachius virens or saithe and Pollachius pollachius or pollack. In the<br />

southern North Sea only adult specimens of pollack occur. The species shown in Figure 4 is a clear example of a pollack. Saithe in the<br />

North Sea has a much more northerly distribution. All references throughout the report to saithe should be changed in pollack. Agreed, text<br />

etc amended as required.<br />

Also there is no quota for pollack in the North Sea (ICES area IV) and the text below figure 4 on TAC and management should therefore be<br />

deleted. Done<br />

2. Our knowledge of sea bass, life history, stocks, and also fishery, is largely based on what is known for English waters. About the<br />

situation in the Netherlands not a lot is known, but what is known has been used in the report.<br />

3. A number of times the remark is made that there are no discards in this fishery. But at the same time it is said that small cod, below the<br />

legal minimum size, are thrown back into the sea (paragraph 4.1 on page 28). So there are discards, and survival of these discards is<br />

probably quite high, and no threat to the recovery of the North Sea cod stock. Remarks that there are no discards should be rephrased. The<br />

text has been amended to clarify that the only discards are of species that are retained and landed, and that there is no non-retained by<br />

catch (a difficulty with the MSC definitions).<br />

4. Page 48, line 5 under Table 8: it is not clear to me where the score of 2.7 comers from.<br />

In the footer of the same page it is said that weightings are given in Table 10 above: there is no table 10. The text above Table 8 explains<br />

how the selectivity values for each of the hook and line, gill net and trawl fisheries were scored, but the aggregate score (2.7) was obtained<br />

by weighting these scores (2,2,3) by the proportional landings taken by the 3 metiers in the North Sea (Table 10 is immediately below). The<br />

foot note has now been incorporated in the text for clarification.<br />

5. Under Recommendation 1 (page 56) it is said that the Client should encourage IMARES to extend the collection of biological information<br />

on sea bass landed in the Netherlands. As long as this is not a ―legal task‖, or as long as this data-collection is not specifically paid for it is<br />

highly unlikely that this will be done by IMARES. Point noted<br />

6. In the scoring comments for 2.3.1 (page 84) spurdog (Squalus acanthias) is being mentioned as incidentally being caught. It does not<br />

seem very likely to catch spurdog in this area. More likely the ―shark‖ that is being caught are smooth hound (Mustelus sp.). We have to<br />

take information from the client who, incidentally, fish widely across the southern North Sea where spurdog do occur.<br />

Page 113 of 151


Performance Indicator Review<br />

Please complete the table below for each Performance Indicator which are listed in the <strong>Certification</strong> Body‘s Public <strong>Certification</strong> Draft Report.<br />

Performanc<br />

e Indicator<br />

Has all the<br />

relevant<br />

information<br />

available<br />

been used to<br />

score this<br />

Indicator?<br />

(Yes/No)<br />

Does the<br />

information<br />

and/or rationale<br />

used to score<br />

this Indicator<br />

support the<br />

given score?<br />

(Yes/No)<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance<br />

to the SG80<br />

level?<br />

(Yes/No/NA)<br />

1.1.1 yes yes NA RBF assessment used<br />

1.1.2 yes yes NA RBF default score<br />

Justification<br />

Please support your answers by referring<br />

to specific scoring issues and any<br />

relevant documentation where possible.<br />

Please attach additional pages if<br />

necessary.<br />

1.1.3 yes yes NA Sea bass in the North Sea is not depleted. No<br />

score has been given.<br />

1.2.1 yes yes NA Based on experience in UK fisheries the harvest<br />

strategy is likely to work<br />

1.2.2 yes yes yes As it is phrased here the condition is likely to<br />

improve the performance of the fishery<br />

1.2.3 yes yes NA Monitoring is well organised on the EU<br />

scale<br />

1.2.4 yes yes NA RBF default score<br />

<strong>Certification</strong> Body Response


Performanc<br />

e Indicator<br />

Has all the<br />

relevant<br />

information<br />

available<br />

been used to<br />

score this<br />

Indicator?<br />

(Yes/No)<br />

Does the<br />

information<br />

and/or rationale<br />

used to score<br />

this Indicator<br />

support the<br />

given score?<br />

(Yes/No)<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance<br />

to the SG80<br />

level?<br />

(Yes/No/NA)<br />

Justification<br />

Please support your answers by referring<br />

to specific scoring issues and any<br />

relevant documentation where possible.<br />

Please attach additional pages if<br />

necessary.<br />

2.1.1 yes yes NA Cod is the main bycatch, but the amount is<br />

negligible. There is a recovery plan for this<br />

species.<br />

2.1.2 yes yes NA There is an EU recovery plan for cod. There are<br />

quota for the cod catches.<br />

2.1.3 yes yes NA The amount of cod landed is monitored in<br />

logbooks, but is marginal.<br />

2.2.1 yes no NA There is discarding, although amounts will be<br />

small and survival is likely to be high<br />

2.2.2 yes yes NA Impact on cod will remain marginal<br />

2.2.3 yes yes NA The main bycatch species is cod, and cod catches<br />

are monitored through logbooks<br />

2.3.1 yes yes NA Mention is made of spurdog, this should probably<br />

be smoothhound (Mustelus sp.) a species that is<br />

not endangered.<br />

<strong>Certification</strong> Body Response<br />

Note that all discarding is claimed to be<br />

undersized individuals of otherwise retained<br />

species, not of ―by catch‖ species (MSC<br />

definition).<br />

See comments above.<br />

Page 115 of 151


Performanc<br />

e Indicator<br />

Has all the<br />

relevant<br />

information<br />

available<br />

been used to<br />

score this<br />

Indicator?<br />

(Yes/No)<br />

Does the<br />

information<br />

and/or rationale<br />

used to score<br />

this Indicator<br />

support the<br />

given score?<br />

(Yes/No)<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance<br />

to the SG80<br />

level?<br />

(Yes/No/NA)<br />

Justification<br />

Please support your answers by referring<br />

to specific scoring issues and any<br />

relevant documentation where possible.<br />

Please attach additional pages if<br />

necessary.<br />

2.3.2 yes yes NA Fishing with rod and line in this area is a good<br />

strategy to avoid catching of ETP species<br />

2.3.3 yes yes NA Catches of ETP fish species are unlikely, and of<br />

ETP marine mamals non-existent.<br />

2.4.1 yes yes NA Light anchors will have no influence whatsoever<br />

on habitat structure in the area<br />

2.4.2 yes yes NA Fishing with rod and line is THE strategy to avoid<br />

irreversible harm tot the habitat<br />

2.4.3 yes yes NA VHBL monitors the activities of its members,<br />

moreover the fishing techniques used is unlikely<br />

to influence the habitat<br />

2.5.1 yes yes NA The fishery removes a small amount of predatory<br />

fish, but irreversible harm to the ecosystem is very<br />

unlikely<br />

2.5.2 yes yes NA Fishing with rod and line is a strategy to avoid<br />

irreversible ecosystem impact<br />

<strong>Certification</strong> Body Response<br />

Page 116 of 151


Performanc<br />

e Indicator<br />

Has all the<br />

relevant<br />

information<br />

available<br />

been used to<br />

score this<br />

Indicator?<br />

(Yes/No)<br />

Does the<br />

information<br />

and/or rationale<br />

used to score<br />

this Indicator<br />

support the<br />

given score?<br />

(Yes/No)<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance<br />

to the SG80<br />

level?<br />

(Yes/No/NA)<br />

Justification<br />

Please support your answers by referring<br />

to specific scoring issues and any<br />

relevant documentation where possible.<br />

Please attach additional pages if<br />

necessary.<br />

2.5.3 yes yes NA There is adequate knowledge to know that the<br />

impact of this fishery on the ecosystem will be<br />

insignificant<br />

3.1.1 yes yes NA A legal framework exists at a national and at the<br />

EU level<br />

3.1.2 yes yes NA Consultation processes, roles and responsibilities<br />

are clear. The recommendation to VHBL to seek<br />

better professional representation would further<br />

improve their involvement.<br />

3.1.3 yes yes NA The CFP has clear long term objectives. Dutch<br />

policy supports the EU objectives.<br />

3.1.4 yes yes NA There are incentives to support environmental<br />

friendly fisheries.<br />

3.2.1 yes yes yes National management objectives are in place. The<br />

condition as formulated will make the decision<br />

making process explicit.<br />

3.2.2 yes yes yes The condition will help to use the available<br />

information in the decision making processes<br />

<strong>Certification</strong> Body Response<br />

Page 117 of 151


Performanc<br />

e Indicator<br />

Has all the<br />

relevant<br />

information<br />

available<br />

been used to<br />

score this<br />

Indicator?<br />

(Yes/No)<br />

Does the<br />

information<br />

and/or rationale<br />

used to score<br />

this Indicator<br />

support the<br />

given score?<br />

(Yes/No)<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance<br />

to the SG80<br />

level?<br />

(Yes/No/NA)<br />

Justification<br />

Please support your answers by referring<br />

to specific scoring issues and any<br />

relevant documentation where possible.<br />

Please attach additional pages if<br />

necessary.<br />

3.2.3 yes yes NA A monitoring system is in place, sanctions are<br />

applied when necessary, for non-compliance<br />

there is no evidence<br />

3.2.4 yes yes NA Research needs are formulated by the relevant<br />

ICES WG. Results of research are dissiminated<br />

through ICES and publications.<br />

3.2.5 yes yes yes The sea bass fishery is evaluated through ICES<br />

and the EC. The condition will make the<br />

evaluation of the monitoring and management<br />

performance more formal.<br />

Any Other Comments<br />

Comments <strong>Certification</strong> Body Response<br />

<strong>Certification</strong> Body Response<br />

Page 118 of 151


For reports using the Risk-Based Framework:<br />

Performance<br />

Indicator<br />

1.1.1<br />

2.1.1<br />

2.2.1<br />

2.4.1<br />

2.5.1<br />

Does the report<br />

clearly explain<br />

how the process<br />

used to<br />

determine risk<br />

using the RBF<br />

led to the stated<br />

outcome?<br />

Yes/No<br />

Are the RBF risk<br />

scores wellreferenced?<br />

Yes/No<br />

Justification:<br />

Please support your answers by referring to specific<br />

scoring issues and any relevant documentation where<br />

possible. Please attach additional pages if necessary.<br />

yes no The PSA score is 2.38 (see page 48). This is fed in<br />

form in 4.4.2 of the FAM. But the score of 2.7 from<br />

which the PSA score resulted can not be traced.<br />

For reports assessing enhanced fisheries:<br />

Does the report clearly evaluate any additional impacts that might arise<br />

from enhancement activities?<br />

Justification:<br />

Yes/No <strong>Certification</strong> Body Response:<br />

<strong>Certification</strong> Body Response:<br />

The aggregate score (2.7) was obtained by<br />

weighting the individual scores of the hook<br />

and line, gill net and trawl fisheries (2,2,3) by<br />

the proportional landings of sea bass taken<br />

by these 3 metiers in the North Sea (in Table<br />

10).<br />

Page 119 of 151


Page 120 of 151


Peer Reviewer 2<br />

Overall Opinion<br />

Has the assessment team arrived at an<br />

appropriate conclusion based on the<br />

evidence presented in the assessment<br />

report?<br />

Justification: I have serious concerns about the scoring<br />

of P1. There are issues with the definition of unit stock,<br />

the assessment of stock status, the impact of trawling on<br />

the stock in terms of the level of exploitation and the<br />

probable undesirable exploitation pattern, and the<br />

application and outcome of the RBF approach. The rod<br />

and line fishery is clearly selective, has a relatively small<br />

impact on the bass stock, and minimal environmental<br />

impact. However, MSC guidelines determine that all<br />

fisheries exploiting the stock have to be taken account<br />

of, and the report fails to convince that the trawl<br />

fisheries, in particular, are not adversely exploiting bass.<br />

Relying upon the assumption that favourable<br />

environmental conditions will prevail and continue to<br />

allow bass to extend their range and increase<br />

abundance is a high risk strategy.<br />

Do you think the condition(s) raised are<br />

appropriately written to achieve the SG80<br />

outcome within the specified timeframe?<br />

Justification: I have made a suggestion for improvement<br />

to Condition 1, and a minor change to Condition 4.<br />

Condition 1 does not place sufficient emphasis on the<br />

need to address the fisheries having the major impact on<br />

No <strong>Certification</strong> Body Response<br />

This reviewer‘s concerns are chiefly<br />

about the evidence on the status of<br />

the sea bass stock in the North Sea<br />

and whether our scoring is too high.<br />

The relevant issues are dealt with in<br />

the overall comments, and those<br />

against the scoring table, and will be<br />

dealt with there. Note that the other<br />

reviewer, being chair of ICES<br />

WGNEW, understands what is<br />

known about sea bass and does not<br />

have a problem with our scoring<br />

under Principle 1.<br />

No <strong>Certification</strong> Body Response<br />

The team has concluded that the P1<br />

scores should stand (supported by<br />

additional and clarifying text in the<br />

report, thanks to this reviewer), and<br />

Page 121 of 151


ass. If the scores I have questioned are revised<br />

downwards, and the P1 score declines to


This is, in the main, a competent and comprehensive assessment of the Dutch rod and line fishery for Sea Bass against the MSC Principles and Criteria<br />

for Sustainable Fisheries. The Report provides an authoritative overview of the fishery and the issues that relate to the three MSC Principles. I concur<br />

with the majority of comments and scoring in the Report, though I have serious concerns about the overall score for Principle 1 and the use of the Risk<br />

Based Framework (RBF).<br />

Inevitably the majority of my comments relate to P1. This is not a reflection on the competence of the P1 assessor, but a consequence of dealing on<br />

the one hand with a relatively data-poor fishery, and on the other hand, one which has very little environmental impact and takes place within a welldeveloped<br />

fishery management regime.<br />

The client rod and line fishery is relatively small scale and has a desirable exploitation pattern. It is the type of fishery that should be encouraged and<br />

would be expected to meet the MSC Principles and Criteria for Sustainable Fisheries. However, this assessment has to look at the total exploitation on<br />

bass within the unit of certification. It is clear that there are extensive landings from other commercial fisheries (French mid-water trawling (not in the<br />

North Sea), and Dutch beam-trawl, fly-seine and twin-rig trawl gears) and from the large Dutch recreational fishery. There appear to be warning signs of<br />

declining landings and mean size (these are anecdotal and from recreational anglers, who have a well declared vested interest in sea bass fisheries)<br />

that raise serious concerns about the impact of trawling with its undesirable exploitation pattern. In my view this assessment has failed to evaluate the<br />

impact of these other fisheries at a level sufficient to convince that the southern North Sea bass stock is being exploited in a medium-term sustainable<br />

manner. On that basis, unfortunately, I have concluded that this fishery should not be certified at this time. The assessment team has amended the<br />

report to better substantiate the case for certification, see below.<br />

2.1 Biology of the target species. There is a need to be a bit more definite about the current biological stock identity in the certification area. Do<br />

we have a ―biologically distinct unit‖? Are there links with the English Channel? If yes, then has the exploitation in the Channel been taken into account<br />

when assessing the state of the ―stock‖ in the southern North Sea?<br />

What is known about the sea bass population in the North Sea and its connections with other areas is clearly spelt out in the report (and is the subject of<br />

more refereed publications than for most other species‘ ―stocks‖ in NW European waters), and exploitation of the North Sea-English Channel stock unit<br />

outside the area fished by the UoC is implicitly taken into account in the assessments.<br />

2.2.1 History of the fishery. Can the landings data by country in Table 1 be split into IVc and VIId? No, and exploitation in VIId is relevant to stock<br />

dynamics in the North Sea, see above. The French and Dutch exploitation by trawl in IVc has potentially serious implications for the southern North Sea<br />

―stock‖. Are the landings excluding or including recreational fishing? Quote ―Dutch recreational landings of sea bass in 2006 were estimated at 195 t<br />

(Kroon, 2007).‖ Are these included in Table 1? Table 1 presents commercial landings only. It is acknowledged that recreational catches of sea bass<br />

must have some impact on exploitation levels, but overall mortality is reflected in the catch-at-age data series that have been used in assessments.<br />

Page 123 of 151


3. Target Stock Status and Harvest Controls (P1). Should there be a heading here ―Stakeholder perceptions of the current state of the stock‖? This<br />

could then refer to the quote ―General perception amongst recreational anglers as well as members of VBHL is that mature and bigger bass are getting<br />

scarcer. There is a steady decline in the stamp [as quoted] of bass available to recreational anglers and other metiers like commercial rod and line<br />

fishermen.‖ made by Jan Willem Wijnstroom, Sportvisserij Nederland in Appendix D. Are there any data to back up this assertion? Commercial catch at<br />

age data do not indicate any population decline, though any inferences would be confounded by the year class strength pattern (e.g. the very abundant<br />

1989 year class supported a strong fishery for larger fish in the late 1990s and early 2000s, but has now all but departed). All assessments have<br />

indicated a continued increase in abundance of bass in the North Sea since the early 1990s, which has been accompanied by an extension in the<br />

species‘ distribution range into the northern North Sea, as far as Norway. This has been accompanied by increased spawning success and recruitment<br />

in the North Sea (Thames and Westscheldt estuary surveys show this), which has resulted in the average size of fish declining (previously mainly adult<br />

bass in North Sea, few in winter).<br />

I have not seen any reference to the suggestion by Jan Willem Wijnstroom, Sportvisserij Nederland in Appendix D for an increase in MLS in the Dutch<br />

fishery. Quote: ―The mls for sea bass (36 cm) is considered to be too low. Sportvisserij Nederland advocates an mls increase to 42 cm , to give bass the<br />

opportunity to grow and to spawn. Although occasionally mature bass are found at 36 cm, we advocate that the whole fishery is subject to measures<br />

that protect undersized bass. VBHL fishermen apply a bigger mls which is the right step in the direction.‖ This issue was discussed in section 3.1 in<br />

relation to UK fisheries, but not the Dutch fishery. It is only a suggestion, which has also come from UK sport anglers and was investigated by<br />

management authorities in the mid 2000s (and rejected). The analyses and simulations behind the UK outcome apply equally to bass in any fishery<br />

(since growth rates, behaviour and year class patterns are similar).<br />

3.1 Analytical assessments.<br />

Catch and fishing effort data. Were the clients not able to provide landings, discards, and effort information? Only annual landings – few discards. To<br />

show their conservation credentials I would have expected to see more Dutch information. There is a strong bias towards the presentation of English<br />

data. See comment (below) at 5.4 Monitoring, control and surveillance regarding AID records. Unfortunately, only the UK has carried out stock<br />

―assessments‖, but ICES WGNEW has accepted that these provide a proxy for sea bass generally in the North Sea.<br />

Size and Age data. Were there any size/age data for the North Sea? Specifically, were there any Dutch or French data, and if not, why not? None<br />

collected, as far as we know (ICES and IMARES were approached). Bass were not included in DCR until recently.<br />

Recruitment. Has the Solent recruitment survey continued, and was there any correlation between the Solent and Thames surveys? Is there any<br />

correlation between the Westscheldt survey data (Figure 4) and the Thames or Solent surveys (Figure 3)? Both surveys were discontinued in 2010 (see<br />

report). The survey-derived year class strength patterns are not strongly correlated (the Westscheldt survey and Thames/Solent surveys are quite<br />

different, though strong and weak year classes show clearly everywhere). See also 3.3.3 Biological reference points. Quote ―The common patterns<br />

in the recruitment time-series for sea bass ―stocks‖ in the North Sea, English Channel……‖. If this is correct then justify it in the recruitment section<br />

Page 124 of 151


where the data are presented. These results came from the analytical assessment using commercial catch-at-age data over the period 1985 - 2004, not<br />

the surveys.<br />

Figure 4. There is a need for a map showing the main geographical areas mentioned in the report. For example, how does the area in Figure 4 relate<br />

geographically to the certification area and the client fishery and the ports from which the clients operate? Agreed, and now provided.<br />

3.2 Stock status. The most extensive bass studies have been carried out by CEFAS in the UK. Consequently the assessment results presented have<br />

a bias towards work done in England and covering the English Channel, and are not as up-to-date as I would have liked to see for current stock status.<br />

There are several references to results that mention dates as ―since 1995‖, ―1989 onwards‖, ―stable since 2004‖, ―since 2004‖, and give the possible<br />

false impression that such trends or status are applicable now. The text also mentions increasing trends, and yet the landings (Table 1) show a peak in<br />

2005 and a decline since (2006-2008, with no more recent data). The text clearly states that the most recent assessment update for WGNEW 2010<br />

used the FAD-only model and included data for 2007-2009 which, although more uncertain than previous assessments (to 2004), shows the same<br />

trends in the SSB in the North Sea and eastern Channel, i.e. a continued increase. Text amended to clarify.<br />

Some results are presented for the southern North Sea (IVc), but more emphasis could have been placed on the most recent ICES deliberations briefly<br />

mentioned in the last paragraph of 3.2. There were no ICES deliberations on these results, and no advice was given.<br />

3.3.2 Management advice. Quote ―From a management viewpoint, assessment results (Pawson et al., 2007b; Kupschus et al. 2008; Kupschus, 2010)<br />

suggest that sea bass in ICES Divisions IVb,c are being exploited sustainably, at a moderate level of F and with an exploitation pattern that gives a near<br />

maximum yield per recruit, and that this has led to an increase in exploitable biomass since the early 1990s.‖ Let us see some of the results justifying<br />

this conclusion (see above comment) and place it in the context of declining landings and stakeholder concerns about decreasing catches of larger<br />

mature bass. OK, now provided.<br />

3.3.3 Biological reference points. See 3.1 Recruitment (above) re common recruitment patterns.<br />

Quote ―There is, therefore, no stock-recruit relationship for bass……‖. Can you say there is no stock-recruit relationship? Surely there could be one,<br />

but it appears to be strongly modulated by temperature related 0-group survival. What is meant here is that there is no S-R relationship that could be<br />

modelled, either to explain past or to predict future recruitment patterns. The relative strength of recruitment bears no relationship to the size of the<br />

spawning stock over the period for which data are available (1984 – 2008), though SSB does reflect strength of recruitment. Text amended to clarify.<br />

3.3.4 Scientific background to management advice for sea bass. This section is all about England again – what about the Netherlands and France?<br />

No scientific advice has been given for management of sea bass fisheries in the North Sea other than from ICES (2004, in response to a request from<br />

the EC) and from UK sources. Text amended to clarify.<br />

Page 125 of 151


4.2 Discarding. Quote ―The client fishery is a very clean fishery, and all species caught are retained species. There is no discarding of non-retained<br />

species.‖ This is a rather emphatic statement. Are there no undersized bass, cod or saithe caught and discarded (these are retained species, by the<br />

MSC definition)? Are all gurnards retained? 1)We will ask the client, but seem to remember that that was their answer. 2) Which was confirmed by the<br />

client, any numbers will be very limited anyhow.<br />

See comment against 2.2 in the scoring table which draws attention to several inconsistencies regarding discarding.<br />

Scoring comment (below) 2.2.3 implies that there is discarding of undersized bass, cod, and saithe by the client fleet. Is there any independent<br />

verifiable information on the discarding behaviour of the clients at sea? No? There are no audit trace references given in the Scoring Table.<br />

Jan Willem Wijnstroom, Sportvisserij Nederland in Appendix D states ‖VBHL fishermen apply a bigger mls which is the right step in the direction.‖ This<br />

implies that VBHL fishermen are discarding bass which do not meet their self-imposed higher MLS. Actually, it implies that they are fishing in areas<br />

where small bass (which are valuable if >MLS) are infrequent. If this is so then the whole question of discarding target species needs to be revised<br />

throughout the report and scoring table. The report has been amended in response to a similar comment by the other referee. Discarding of the target<br />

species is only important if it results in mortality that is significant in terms of sustainability. Clearly, this is not the case in this fishery and is covered by<br />

the RBF under PSA Susceptibility attributes and scores.<br />

5.1 Legislation and regulation. Quote ―In France, a national regulation limiting bass landings by French pelagic trawlers fishing in the English Channel<br />

was set up in 1996, and sea bass landings by all trawlers have been limited to 5t/boat /week from 1 January to 30 April since 1998.‖ But presumably<br />

this does not apply in the southern North Sea where French landings (Table 1) have increased in recent years. Yes it does.<br />

5.2 Roles & Responsibilities. Quote ―The North Sea Demersal RAC has greatly improved effective communication links between industry, NGO‘s,<br />

managers and scientists.‖ Has bass ever been discussed is the RAC? If yes, what was the outcome? It is doubtful: bass continues to be a target<br />

species only for small boats and a by catch species for larger vessels, and there are no stock, TAC, or quota concerns.<br />

Quote ―The most important working group when considering sea bass is WGNEW, which ICES established in 2005 to provide the EC with advice on<br />

stock status and management of so called MoU (Memory of Understanding) species.‖ Yet there has been little output referred to in this report. Have<br />

they seriously looked at bass? Not since 2004, the last year that the ICES Sea Bass Study Group existed (superseded by WGNEW). If yes, then there<br />

should be more ICES input in this report.<br />

5.4 Monitoring, Control and Surveillance. Quote ―After entering a port, fishing vessels have to deliver a logsheet with all landed quantities and<br />

species to the AID (in a special post box).‖ So why are there no data from this source presented here? Only data given was sourced from the clients<br />

(Table 2). AID information is not made public<br />

Page 126 of 151


5.4 (should be 5.5) Compliance. Quote ―The client considers that there is insufficient control effort directed at vessels under 10 m. They have<br />

mentioned that there are several unregistered vessels using rod and line that land sea bass and cod with the intention of sale, which is prohibited under<br />

the official regulations.‖ Is there any estimate of the landings from unregistered vessels? The only figure available is given by Kroon (2007) who<br />

estimated Dutch recreational landings of sea bass in 2006 at 195 t (see below).<br />

What about the landings from the number of bass anglers in the Netherlands estimated in 2006 as 91.000 (TNS NIPO 2006) [Appendix D]? Surely the<br />

impact on the bass stock of 19 VNHL members pales into insignificance compared to the activities of 91,000 recreational fishers. Dutch recreational<br />

landings of sea bass in 2006 were estimated at 195 t (Kroon, 2007), compared with 33 t by VNHL fishers. That is quite true, and a similar situation has<br />

obtained in the UK since the commercial bass fishery started in the 1970s. Recreational anglers‘ catches should now be sampled under Article 47 of<br />

the EC data Collection Regulation, but we have no information on whether the Netherlands has implemented this. Article 47 is not actively enforced in<br />

the Netherlands<br />

6. Other Fisheries in the Area Affecting the Target Stock. Quote ―In the North Sea, sea bass are taken mainly in commercial fisheries operating<br />

along the English coast, where they are targeted by drifted and fixed gillnets, and by rod and line, and as an important by catch nets set for cod and sea<br />

trout and in trawls (Walmsley & Pawson 2007). The fishing season in this area normally lasts from May until October/November. French and Belgian<br />

trawlers also take substantial quantities of sea bass in this area, chiefly as a by catch in demersal fisheries (see Table 1).‖<br />

In the paragraph before Table 1, page 20 quote ―The landings of sea bass by French vessels in North West European waters were around 2000 t during<br />

the period 1986–1995 and have increased to around 4000–5000 t in the most recent years, due mainly to the catch in the southern North Sea (ICES<br />

Divisions IVc) and eastern English Channel (VIId).‖<br />

Is it true to say here ―In the North Sea, sea bass are taken mainly in commercial fisheries operating along the English coast,…..‖? There is no<br />

quantitative and disaggregated information (landings or effort) presented here for the French or Dutch fisheries in the southern North Sea (IVc) - does<br />

any exist? Table 1 presents what information is available. The text has been amended to clarify.<br />

The directed effort from Dutch beam-trawl, fly-seine and twin-rig trawl fisher is a significant fishery, dwarfing that by the rod and line clients, yet there is<br />

little or no reference to the distribution of the fishing effort or to the probable adverse exploitation pattern exerted by these net fisheries. Landings of sea<br />

bass from this fishery (seldom due to fishing directed at sea bass) are included in Table 1, but we do not know where they are taken. The poor<br />

selectivity of these gears is reflected in the scores given by the RBF under PSA Susceptibility attributes.<br />

8.3 Stakeholder consultation. Stakeholder issues. A list of the main points raised would be useful to identify stakeholder‘s concerns. They may be<br />

covered in the scoring process, but are not identifiable as stakeholder‘s concerns. Text amended accordingly.<br />

Page 127 of 151


8.4 Other certification evaluations and harmonization. Quote ―……the fisheries and the scientific basis for assessment of stock status are similar,<br />

and therefore of relevance.‖ Why, therefore, are they not quoted here and comparisons made? The draft report for the Bristol Channel Bass trawl<br />

Fishery (http://www.msc.org/track-a-fishery/in-assessment/north-east-atlantic/Bristol-Channel-sea-bass/assessment-downloads-1/17.02.2011-<br />

Bass_Assessment_PCDR_140211_FINAL.pdf) has not recommended certification, mainly due to similar factors identified here (unclear stock status,<br />

poor trawl exploitation pattern, and lack of management strategy and harvest control rules). The stock situation and impacts of exploitation are different<br />

in the North Sea and Bristol Channel: the text has been amended to clarify.<br />

9.2.1 Introduction to RBF. This section needs to be expanded to justify more clearly that there is indeed a need to use RBF. The correct (Figure 3<br />

from the FAM Version 2, Release date: 31 July 2009, which covers P1.1.1.) decision tree should be given (Figure 6 is incorrect, correct version added)<br />

and the reader led through the decisions taken to conclude that the RBF should be used. Account should be taken of the ICES work and conclusions. I<br />

have seen far less stock status information, than appears to be available for bass, being used in a standard FAM assessment. Note that the criteria for<br />

using RBF have changed considerably over the last 2 years. The assessment team considers that the correct approach was taken.<br />

9.2.2 SICA. In the text table on page 45, under the ―bycatch‖ column, ―Na‖ has been entered for the rows ―gear loss‖, ―unobserved mortality‖, and<br />

―discarding‖ - would an * (= little effect) be more appropriate? If gear loss, unobserved mortality, and mortality have little effect on bass, then could the<br />

same not be said for cod and saithe? The problem here is the confusion between target, retained and by catch species due to MSC definitions. To<br />

clarify, cod etc are now identified as by catch and the indicators amended accordingly.<br />

Under habitat / bait collection an * (= little effect) has been given. Is there any evidence to support this assessment? Artificial lures are used most of the<br />

time, and there is relatively little gear loss or interaction with habitats.<br />

3. SICA scoring. A consequence score of 3 has been given for age/size/sex structure in Table 5, and in the paragraph below, but a score of 2 is given<br />

in the paragraph above the table and in the rationale text at the bottom of the table. As a SICA MSC score of 60 has been given I assume that the<br />

consequence score was 3. The scores throughout the report, and not just here (see comments against Page 48 last paragraph, Figure 7, and Table 10<br />

below), need to be checked as changes appear to have been made, but not implemented in all parts of the report. At the time of the site visit and<br />

scoring meeting, the assessment team were undecided whether to award a score of 2 or 3 for the SICA consequence, which is reflected in the<br />

inconsistencies noted. This has now been corrected and scores amended accordingly.<br />

9.2.3 PSA. PSA step 2. Score susceptibility attributes; Page 48. Quote ―…since bass fishing predominantly takes place in coastal areas…‖. The<br />

clients fish up to 70 miles offshore. Is that coastal? Are the bass caught by trawls inshore or offshore? Amended to clarify.<br />

Quote ―The team and the stakeholders agreed that there are large parts of the North Sea where no fishing for bass takes place, since bass fishing<br />

predominantly takes place in coastal areas and sea bass is mainly a by-catch in trawl fishery.‖ What about the spatial distribution of French targeted<br />

mid-water trawling (not in North Sea) and Dutch by catch trawling and netting which catch the majority of the bass (85% of the Dutch bass landings)? If<br />

the distribution of bass is understood by fishers, hence they target certain areas, then the fact that ―large parts of the North Sea where no fishing for<br />

Page 128 of 151


ass‖ is irrelevant - there are probably no bass there. Within the known distribution of bass surely the availability is high risk = 3 (not 2 as in Table 8),<br />

which equates to the FAM guidance of >30% overlap. Although the commercial bass fishery around England and Wales and in French waters has<br />

developed over the last 30 years to exploit the population over most of its seasonal distribution, the development of bass fishing in the North Sea has<br />

lagged behind the stock‘s production and range extension. Many gears used for commercial fishing there are unsuited to catch bass (other than as an<br />

incidental by catch), and the level of overlap with the species‘ distribution (both across the ground and in the water column) is much less than for<br />

fisheries for e.g. cod, plaice, herring etc.<br />

Quote ―For the rod and line fishery it was considered that the rod and line fishery directly targets the bass on the spots where they are most abundant.<br />

Therefore like for trawl and gill net fishery a score of 2 was given.‖ If they target spots where they are most abundant then surely for encounterability<br />

there is a ―high overlap with fishing gear‖ (FAM, Table B4.3) resulting in ―high susceptibility‖ and justifying an encounterability high risk score of 3, not a<br />

score of 2 (Table 8). Text amended to clarify<br />

Quote for selectivity ―Strict application of the attributes in this table would result in a high risk score (bait used is attractive to bass and the fish cannot<br />

break the line) which does not seem appropriate for this metier since the hook and line fishery is highly selective in catching larger fish. The choice of<br />

fishing spots (wrecks) were larger fish aggregate contributes highly to this high selectivity. Undersized fish are rarely caught and always released alive.<br />

The team therefore awarded medium risk score of 2.‖ Table B4.4 (FAM) states that if there are conflicting answers, then the higher risk score should be<br />

used, i.e. in this case a score of 3. Selectivity attribute scores tend to be contentious (MSC guidelines are not always helpful), but adult bass are known<br />

to be less vulnerable to fishing gears than most other main commercial species. The evidence for this is the relatively low F values in assessments<br />

(consistently around 0.3) and the decline in modelled selectivity-at-age after ages 6-7. Text amended to clarify.<br />

If these suggested changes to the scores are implemented then the overall PSA score will need to be revised. After considering the reviewer‘s<br />

comments, and reviewing the evidence presented (with a number of important amendments to the text for clarification), the assessment team has<br />

concluded that no score needs changing (other than where there are inconsistencies in the report).<br />

Page 48, last paragraph. The scores in the text do not agree with those in Table 9. This leaves the reviewer very uncertain as to what was the correct<br />

overall MSC score (given as 87 for P1.1.1. [text bottom of page 48, and in Table 10]). The scores given in the text have been corrected, and the foot<br />

note has now been incorporated in the text for clarification.<br />

Figure 7. Explain the significance of this plot, assuming the scores plotted are correct. Text amended accordingly.<br />

Table 10. 1.2.2 scores 75 in the Scoring Table, but 70 in Table 10 and Summary. There is a need to check all the scores allocated, especially where<br />

changes have been made, to ensure that they are all consistent, and more importantly, that the final overall scores for P1-3 are correct. I have NOT<br />

checked them all, only ones that my attention was drawn to in evaluating scores and comments. This has been checked and scores amended where<br />

necessary.<br />

Page 129 of 151


Appendix A: Scoring Table.<br />

(Comments additional to those given in the Performance Indicator Review (below).)<br />

1.1.3. Stock rebuilding. Scoring comments. Quote ―There is no evidence of depletion of the North Sea bass stock. Although the available<br />

assessments do not allow the abundance of sea bass to be determined on an absolute basis, stock abundance indicators suggest that the sea bass<br />

population in the North Sea has become more productive since 1990, with increased levels of recruitment, a higher SSB and an extension of its<br />

geographical range to the North.‖ What happens if the stock is depleted through adverse climatic changes (reduced seawater temperatures)? Are we<br />

sure about the current stock status such that it can be emphatically determined that there are no signs of stock depletion? Is there a stock rebuilding<br />

strategy should it be needed? Is one possible? It depends on what is meant by ―stock depletion‖. In most fisheries, the current state of the stock is<br />

compared either with the known history (where population data are available for 20-40 years, say) or with a putative unexploited estimated by modelling.<br />

For sea bass in the North Sea, we know that the stock (even if larger fish are now less abundant than 10 years ago following the demise of the 1989<br />

year class) is much more abundant than it was in the 1970s and 1980s, when bass catches in trawls or gill nets were relatively small (see Table 1).<br />

1.2.1. Harvest Strategy. Scoring comments.<br />

The second paragraph starting ―There are no target or limit reference points…..‖ should, with some editing, be included in the 1.1.2 scoring comments.<br />

Amended accordingly.<br />

Third paragraph starting ―The harvest strategy is….‖. The UK initiated harvest strategy, in particular protected nursery areas, is not applied (I assume,<br />

as there is no mention of any.) on the eastern side (Netherlands, etc.) of the southern North Sea. Thus, they cannot be shown to work despite any<br />

monitoring that may be taking place. The harvest strategy implicitly adopted by the EU is to protect bass below 36 cm, which is achieved by the tactical<br />

combination of MLS, gill net mesh size controls and nursery areas (UK only), and the first two measures are implemented throughout the North Sea.<br />

Third paragraph quote ―Moreover, though ICES advised (ACOM, 2004) that effort should not be increased for sea bass in any area, it is apparent that<br />

trawl fisheries in particular have been increasingly directed at sea bass as catch quotas on other species have been reduced .‖<br />

The potential for (apparently) uncontrolled fishing effort by mid-water and beam trawlers with an undesirable exploitation pattern (relatively small mesh)<br />

is a potential high risk to bass sustainability in the southern North Sea. Not enough emphasis has been placed on this risk in the assessment. Agreed,<br />

but decommissioning, fleet restructuring and effort controls (e.g. days-at-sea) have clearly led to a reduction in F in all North Sea towed-gear fisheries,<br />

with a consequent constraint on effort that might take bass. The relatively poor selectivity of trawls for bass is accounted for in the weighted score for<br />

selectivity in the PSA.<br />

ICES (2008) said ―Predicted selectivity in the IVbc trawl fleet has changed to younger ages compared to previous assessments, suggesting that the<br />

fleet would now be more heavily impacted by the MLS than would have been the case in the past‖. I am not aware of the mesh regulations applicable in<br />

Page 130 of 151


the bass trawl fishery and the possibilities for improving their exploitation pattern as part of the harvest strategy. The only reference I could find to trawl<br />

meshes was in 9.2.3 – the PSA step 2 – susceptibility, where a high risk score of 3 was correctly given. Perhaps the P1 assessor could add any relevant<br />

trawl mesh information to the appropriate section of the report and discuss the implications for bass stock status. Mesh size controls for towed gears in<br />

which bass is a target species are included in <strong>Council</strong> Regulation 850/1998, but most bass are taken as a by catch in gears for which mesh size<br />

controls depend on other target species. Text amended to clarify.<br />

The current harvest strategy has no mechanism to control fishing effort in the event of a need to reduce fishing effort to combat a fall in stock abundance<br />

resulting from excessive fishing effort or natural climatic changes. It would be wrong to assume that the bass stock will continue to expand its range<br />

and abundance in response to the favourable changes in sea temperature that have taken place in the recent past. Agreed, but the harvest strategy is<br />

designed to achieve management objectives in terms of yield per recruit and MSY, since growth overfishing rather than recruit overfishing has been<br />

identified as the principle cause of loss of production in sea bass stocks (in which a wide variability in recruitment is related to environmental factors<br />

rather than SSB). In this way the harvest strategy is responsive to the state of the stock (protecting year classes for up to 5 years before they recruit to<br />

the fishery and spawning population), and we consider that the SG 80 are met (since analysis and simulations have demonstrated the elements of the<br />

harvest strategy have been work together to achieving the management objectives: see Pawson et al., 2005; Pawson et al, 2007 and ICES 2010).<br />

Based on the above comments SG 1-80 is not met as the harvest strategy does not have explicit mechanisms to respond appropriately to a change in<br />

the state of the stock using effort control and/or mesh size increases. This score should be


2.3.2. Management Strategy. Quote ―The fact that the client fishes with rod and line and specifically and very selectively targets sea bass and cod can<br />

be considered an effective strategy to prevent the catch or mortality of ETP species (1-80).‖ Cod is not a target species - see 2.1.1. - it is a retained<br />

non-target species. Yes, sea bass is the target species in the MSC sense, for this assessment, but the fishery is directed at cod as well as bass.<br />

2.5.2. Management Strategy. Quote from Section 4.5 of the report ―The artificial baits used in this fishery are generally made of lead which is known<br />

to be a toxic metal when it is accumulated in animal tissue in high concentrations. Sometimes a bait will get stuck on structures on the seafloor like rocks<br />

or wrecks and consequently lost. Although this can be considered a minor issue, the VBHL is currently looking into possibilities to replace the lead in the<br />

baits with another metal (steel).‖ Add this point to the recommendation given in 2.5.2 of the Scoring Table. OK, done<br />

3.2.4. Research Plan. Quote ―Research conducted on sea bass in the Netherlands includes a tagging experiment in which IMARES is currently<br />

involved. Data on recreational catches have been collected by the national organisation of recreational fishermen. The results of this research are<br />

disseminated (through publication and ICES reports) and available to all parties (2-80).‖ Have the results been incorporated into the report and scoring<br />

table? The only example I can recollect seeing is the Westscheldt recruit series (Figure 4). All the results that are available and relevant to this<br />

assessment have been included in the report.<br />

Page 132 of 151


Performance Indicator Review<br />

Please complete the table below for each Performance Indicator which are listed in the <strong>Certification</strong> Body‘s Public<br />

<strong>Certification</strong> Draft Report.<br />

Performance<br />

Indicator<br />

Example:1.1.<br />

2<br />

Has all the<br />

relevant<br />

information<br />

available been<br />

used to score<br />

this Indicator?<br />

(Yes/No)<br />

Does the<br />

information<br />

and/or rationale<br />

used to score this<br />

Indicator support<br />

the given score?<br />

(Yes/No)<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance to<br />

the SG80 level?<br />

(Yes/No/NA)<br />

Justification<br />

Please support your answers by referring<br />

to specific scoring issues and any<br />

relevant documentation where possible.<br />

Please attach additional pages if<br />

necessary.<br />

No No NA The certifier gave a score of 80 for this PI.<br />

The 80 scoring guidepost asks for a<br />

target reference point that is consistent<br />

with maintaining the stock at Bmsy or<br />

above, however the target reference point<br />

given for this fishery is Bpa, with no<br />

indication of how this is consistent with a<br />

Bmsy level.<br />

<strong>Certification</strong> Body Response


Performance<br />

Indicator<br />

Has all the<br />

relevant<br />

information<br />

available been<br />

used to score<br />

this Indicator?<br />

(Yes/No)<br />

1.1.1 The RBF was<br />

used – see<br />

comments<br />

below.<br />

Probably.<br />

Does the<br />

information<br />

and/or rationale<br />

used to score this<br />

Indicator support<br />

the given score?<br />

(Yes/No)<br />

Yes, while<br />

following the RBF<br />

scoring.<br />

No, when you<br />

take account of<br />

the lack of very<br />

recent<br />

assessments and<br />

the uncertainties<br />

expressed by<br />

ICES.<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance to<br />

the SG80 level?<br />

(Yes/No/NA)<br />

NA with the<br />

current score<br />

1.1.2 Yes No NA with the<br />

current score<br />

Justification<br />

Please support your answers by referring<br />

to specific scoring issues and any<br />

relevant documentation where possible.<br />

Please attach additional pages if<br />

necessary.<br />

There is clearly a dearth of information<br />

for bass in IVc. It is not clear if there is<br />

more available data for French & Dutch<br />

fisheries that has not been used.<br />

I still find that the scores from the RBF<br />

appear to be overly optimistic. The most<br />

recent ICES advice for bass (ICES,<br />

2008) was ―Given the fact that no<br />

assessments have been undertaken for<br />

other areas and stock status is unknown,<br />

the WG suggests that again effort should<br />

not be allowed to increase and that<br />

additional data that could be used for<br />

assessments should be collected.‖ This<br />

hardly endorses a MSC PSA score of 87!<br />

Another strange bit of RBF logic. If there<br />

are no reference points then the score<br />

should be 60 or less and generate a<br />

Condition. I find it strange that where a<br />

fishery is deemed not to meet the criteria<br />

for FAM, because biologically-based<br />

limits for sustainability (e.g. reference<br />

points) cannot be estimated, that 1.1.2<br />

then gets a favourable default score of<br />

80. This default score contributes to<br />

raising the overall P1 score to 80.5 – a<br />

pass (just)!<br />

<strong>Certification</strong> Body Response<br />

The team used the best availabl<br />

information to apply the RBF to t<br />

assessment, and we are confide<br />

the outcome reflects the stock si<br />

in the North Sea. Despite a lack<br />

classical reference points, all ind<br />

are that recruitment has shown a<br />

increasing trend since the early 1<br />

with a consequent increase in SS<br />

that exploitation levels are mode<br />

(though the most recent assessm<br />

presented to ICES are thought to<br />

robust than those carried out pre<br />

.<br />

Conditions have been generated<br />

that the Client should liaise with<br />

management and research bodie<br />

help develop a harvest control ru<br />

explicitly related to limit referenc<br />

and also specific management o<br />

for the sea bass fishery.<br />

Page 134 of 151


Performance<br />

Indicator<br />

Has all the<br />

relevant<br />

information<br />

available been<br />

used to score<br />

this Indicator?<br />

(Yes/No)<br />

Does the<br />

information<br />

and/or rationale<br />

used to score this<br />

Indicator support<br />

the given score?<br />

(Yes/No)<br />

1.1.3 Yes Yes, but it is<br />

limited and not<br />

up-to-date.<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance to<br />

the SG80 level?<br />

(Yes/No/NA)<br />

Justification<br />

Please support your answers by referring<br />

to specific scoring issues and any<br />

relevant documentation where possible.<br />

Please attach additional pages if<br />

necessary.<br />

NA Do the reduced landings in the French<br />

trawl fishery indicate a recent fall is<br />

abundance? What happens if the stock<br />

is depleted through adverse climatic<br />

changes (reduced seawater<br />

temperatures)? Is there a stock<br />

rebuilding strategy. Is one possible?<br />

<strong>Certification</strong> Body Response<br />

Stock rebuilding is not required (<br />

1.1.1)<br />

Page 135 of 151


Performance<br />

Indicator<br />

Has all the<br />

relevant<br />

information<br />

available been<br />

used to score<br />

this Indicator?<br />

(Yes/No)<br />

Does the<br />

information<br />

and/or rationale<br />

used to score this<br />

Indicator support<br />

the given score?<br />

(Yes/No)<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance to<br />

the SG80 level?<br />

(Yes/No/NA)<br />

1.2.1 Yes No NA with the<br />

current score<br />

Justification<br />

Please support your answers by referring<br />

to specific scoring issues and any<br />

relevant documentation where possible.<br />

Please attach additional pages if<br />

necessary.<br />

There is a supposition that the harvest<br />

strategy developed in the UK, and<br />

partially implemented in the EU, is fully<br />

applied in IVc, and particularly in the<br />

Netherlands.<br />

SG 1-80 is not met as the harvest<br />

strategy does not have explicit<br />

mechanisms to respond appropriately to<br />

a change in the state of the stock by<br />

effort control and/or mesh size<br />

increases. This score should be


Performance<br />

Indicator<br />

Has all the<br />

relevant<br />

information<br />

available been<br />

used to score<br />

this Indicator?<br />

(Yes/No)<br />

Does the<br />

information<br />

and/or rationale<br />

used to score this<br />

Indicator support<br />

the given score?<br />

(Yes/No)<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance to<br />

the SG80 level?<br />

(Yes/No/NA)<br />

Justification<br />

Please support your answers by referring<br />

to specific scoring issues and any<br />

relevant documentation where possible.<br />

Please attach additional pages if<br />

necessary.<br />

1.2.2 Yes No No ―….effort directed at bass is<br />

uncontrolled.‖ This is the major gap in<br />

the harvest strategy and control rules<br />

and tools. To imply that ―technical<br />

harvest control measures are in place<br />

and could be extended when considered<br />

necessary‖ and to declare that ―…<br />

regarded as an implicit harvest control<br />

rule‖ to address this omission is to place<br />

insufficient attention to the risk of over<br />

exploitation due to un-controlled fishing<br />

effort in the trawl fisheries. On this basis<br />

a score of 75 seems generous.<br />

The development of a harvest control<br />

rule that better ensures that the<br />

exploitation rate on North Sea bass is<br />

reduced as limit reference points are<br />

approached needs to target trawling, and<br />

so the client rod and line fishers are<br />

unlikely to be able to have much<br />

influence on the authorities.<br />

<strong>Certification</strong> Body Response<br />

As explained above, quantitative<br />

on effort or catch have not been<br />

implemented in the sea bass fish<br />

much of which is of a small-boat<br />

recreational) nature. The strateg<br />

use technical mesasures to ensu<br />

as possible that recruitment is<br />

maximised, both to the fishery an<br />

spawning stock, has been demo<br />

to work.<br />

Other elements of a harvest stra<br />

relevance to the towed gear fish<br />

include decommissioning, fleet<br />

restructuring and effort controls (<br />

days-at-sea), which have clearly<br />

reduction in F in all North Sea to<br />

gear fisheries, with a consequen<br />

constraint on effort that might tak<br />

Nevertherless, we agree that this<br />

strengthening, see Condition 1.<br />

Page 137 of 151


Performance<br />

Indicator<br />

Has all the<br />

relevant<br />

information<br />

available been<br />

used to score<br />

this Indicator?<br />

(Yes/No)<br />

Does the<br />

information<br />

and/or rationale<br />

used to score this<br />

Indicator support<br />

the given score?<br />

(Yes/No)<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance to<br />

the SG80 level?<br />

(Yes/No/NA)<br />

Justification<br />

Please support your answers by referring<br />

to specific scoring issues and any<br />

relevant documentation where possible.<br />

Please attach additional pages if<br />

necessary.<br />

1.2.3 Yes No NA The question arises here as to what is<br />

the stock definition appropriate to this<br />

fishery (Figure 2)? In Table 1 the bass<br />

landings are aggregated into ICES<br />

Divisions IVb, c, and VIId (southern<br />

North Sea and eastern Channel), and I<br />

have assumed that the data are not<br />

available in a disaggregated form. The<br />

assessors should question whether the<br />

data collected is at a spatial level<br />

consistent with the stock definition. If it<br />

is not, then the score of 80 needs to be<br />

re-considered as SG 1-80 may not have<br />

been met.<br />

1.2.4 Yes No NA Quote ―The assessment team notes,<br />

however that the most recent<br />

assessments of this stock (Kupschus et<br />

al., 2007, Kupschus 2010) are thought to<br />

be increasingly uncertain, other than in<br />

terms of trends in SSB. Consequently,<br />

the stock status at present is uncertain.‖<br />

On that basis the default score of 80<br />

from the RBF seems inappropriate.<br />

<strong>Certification</strong> Body Response<br />

The report clearly states that the<br />

bass stock exploited by assesse<br />

occupies the North Sea and part<br />

English Channel (seasonally), w<br />

why landings data are presented<br />

ICES Divisions IVb,c and VIId. I<br />

the bass population has spread<br />

early 1990s into the central and<br />

North Sea and Norwegian coast<br />

waters, where there is now an<br />

enthusiastis recreational angling<br />

but little or no commercial exploi<br />

the species.<br />

The stock status has been score<br />

RBF for this reason. Other indic<br />

suggest that the stock‘s status h<br />

improving (due to improved recru<br />

protected by specific manageme<br />

measures) and a climate-induce<br />

change in distribution (proportion<br />

fewer bass now more south-wes<br />

the North Sea in winter to spawn<br />

Page 138 of 151


Performance<br />

Indicator<br />

P1 as a<br />

whole<br />

Has all the<br />

relevant<br />

information<br />

available been<br />

used to score<br />

this Indicator?<br />

(Yes/No)<br />

Does the<br />

information<br />

and/or rationale<br />

used to score this<br />

Indicator support<br />

the given score?<br />

(Yes/No)<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance to<br />

the SG80 level?<br />

(Yes/No/NA)<br />

Yes No Where I have<br />

questioned the<br />

scores and<br />

suggested they<br />

should be


Performance<br />

Indicator<br />

Has all the<br />

relevant<br />

information<br />

available been<br />

used to score<br />

this Indicator?<br />

(Yes/No)<br />

Does the<br />

information<br />

and/or rationale<br />

used to score this<br />

Indicator support<br />

the given score?<br />

(Yes/No)<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance to<br />

the SG80 level?<br />

(Yes/No/NA)<br />

Justification<br />

Please support your answers by referring<br />

to specific scoring issues and any<br />

relevant documentation where possible.<br />

Please attach additional pages if<br />

necessary.<br />

2.2.1 No Maybe NA Reconsider the 100 score when you<br />

have decided if discarding is zero or<br />

small and insignificant. See 4.2 &<br />

Scoring Table 2.2 in the General<br />

Comments text above.<br />

2.2.2 No Yes NA All the information on discarding within<br />

the report and scorong table needs<br />

clarification.<br />

2.2.3 No Yes NA All the information on discarding within<br />

the report and scorong table needs<br />

clarification.<br />

2.3.1 Yes Yes NA<br />

2.3.2 Yes Yes NA<br />

2.3.3 Yes Yes NA<br />

2.4.1 Yes Yes NA<br />

2.4.2 Yes Yes NA<br />

2.4.3 Yes Yes NA<br />

<strong>Certification</strong> Body Response<br />

There is confusion caused by the<br />

reained species (2.1) and by<br />

catch/discard species 2.2), which<br />

have tried to clarify in the text. 1<br />

remains.<br />

ditto<br />

ditto<br />

Page 140 of 151


Performance<br />

Indicator<br />

Has all the<br />

relevant<br />

information<br />

available been<br />

used to score<br />

this Indicator?<br />

(Yes/No)<br />

Does the<br />

information<br />

and/or rationale<br />

used to score this<br />

Indicator support<br />

the given score?<br />

(Yes/No)<br />

2.5.1 Yes Yes NA<br />

2.5.2 Yes Yes NA<br />

2.5.3 Yes Yes NA<br />

3.1.1 Yes Yes NA<br />

3.1.2 Yes Yes NA<br />

3.1.3 Yes Yes NA<br />

3.1.4 Yes Yes NA<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance to<br />

the SG80 level?<br />

(Yes/No/NA)<br />

Justification<br />

Please support your answers by referring<br />

to specific scoring issues and any<br />

relevant documentation where possible.<br />

Please attach additional pages if<br />

necessary.<br />

<strong>Certification</strong> Body Response<br />

Page 141 of 151


Performance<br />

Indicator<br />

Has all the<br />

relevant<br />

information<br />

available been<br />

used to score<br />

this Indicator?<br />

(Yes/No)<br />

Does the<br />

information<br />

and/or rationale<br />

used to score this<br />

Indicator support<br />

the given score?<br />

(Yes/No)<br />

Will the<br />

condition(s)<br />

raised improve<br />

the fishery‘s<br />

performance to<br />

the SG80 level?<br />

(Yes/No/NA)<br />

Justification<br />

Please support your answers by referring<br />

to specific scoring issues and any<br />

relevant documentation where possible.<br />

Please attach additional pages if<br />

necessary.<br />

3.2.1 Yes Yes Yes Objectives are only expressed in very<br />

general terms and not implicitly or<br />

explicitly for bass. This is an example of<br />

trying to make a distinction between the<br />

―fishery‖ (i.e. Dutch rod and line) and the<br />

―stock‖ (?southern North Sea?). Clearly<br />

there are no Dutch fishery-specific<br />

objectives for bass. Are there any<br />

objectives for the stock, which are<br />

applicable here? The score of 70 and<br />

Condition are appropriate. The<br />

Condition also covers other fishing<br />

metiers targeting sea bass, such as<br />

trawling and gill net fishing. This<br />

emphasis is missing from Condition 1<br />

dealing with P1.2.2.<br />

3.2.2 Yes Yes Yes<br />

3.2.3 Yes Yes NA<br />

3.2.4 Yes Yes NA<br />

3.2.5 Yes Yes No External peer review should be part of<br />

the condition.<br />

Any Other Comments<br />

<strong>Certification</strong> Body Response<br />

Point noted, and text amended t<br />

Added to Condition 3.<br />

Page 142 of 151


Comments <strong>Certification</strong> Body Response<br />

The section below for RBF is totally inadequate to allow the peer reviewer to<br />

critically assess the RBF procedure. I have completed the 1.1.1 section<br />

above, and also made references to the RBF scoring in my General<br />

Comments section.<br />

For reports using the Risk-Based Framework:<br />

Page 143 of 151


Performance<br />

Indicator<br />

1.1.1<br />

2.1.1<br />

2.2.1<br />

2.4.1<br />

2.5.1<br />

Does the report<br />

clearly explain<br />

how the<br />

process used<br />

to determine<br />

risk using the<br />

RBF led to the<br />

stated<br />

outcome?<br />

Yes/No<br />

Are the RBF risk<br />

scores wellreferenced?<br />

Yes/No<br />

Justification:<br />

Please support your answers by referring to<br />

specific scoring issues and any relevant<br />

documentation where possible. Please attach<br />

additional pages if necessary.<br />

Yes<br />

NA<br />

Yes I find the positive PSA MSC score of 87<br />

somewhat surprising, given the problems with<br />

evaluating stock status and the lack of reference<br />

points. See comments above at 1.1.1 which<br />

discuss in more detail the RBF scoring of 1.1.1.<br />

NA<br />

NA<br />

NA<br />

For reports assessing enhanced fisheries:<br />

Does the report clearly evaluate any additional impacts that might<br />

arise from enhancement activities?<br />

Justification:<br />

Yes/No <strong>Certification</strong> Body Response:<br />

<strong>Certification</strong> Body Response:<br />

This issue has been dealt with above, se<br />

comments against P1 as a whole.<br />

Page 144 of 151


APPENDIX C: CLIENT ACTION PLAN<br />

Received from the client on 12-04-2011<br />

Vereniging van Beroepsmatige Handlijnvissers Nederland<br />

Client<br />

Action<br />

Plan: Dutch Rod and Line Fishery for Sea bass<br />

MSC: <strong>SGS</strong>-NL-MSC-F-0405<br />

Condition Principle<br />

Compo<br />

nent<br />

C1 P1 Manage<br />

ment<br />

C2 P3 Fishery<br />

Specific<br />

Manage<br />

ment<br />

System<br />

C3 P3 Fishery<br />

Specific<br />

Manage<br />

ment<br />

System<br />

Performanc<br />

PI e Indicator<br />

No.<br />

1.2.2 Harvest<br />

control rule<br />

(PI) Action Deadline<br />

3.2.1 Fisheries<br />

specific<br />

objectives<br />

3.2.3 Decision<br />

making<br />

process<br />

Liaise with fisheries<br />

management and<br />

research bodies to<br />

explore how BVHN<br />

can assist with the<br />

development of a<br />

harvest control rule<br />

that better ensures<br />

that the exploitation<br />

rate by all fishing<br />

metiers taking sea<br />

bass in the North Sea,<br />

is reduced as limit<br />

reference points are<br />

approached.<br />

Liaise with authorities<br />

to help develop<br />

specific fishery<br />

objectives and secure<br />

these objectives in the<br />

VBHL management<br />

plan<br />

Encourage authorities<br />

to develop a fisheryspecific<br />

management<br />

system, including<br />

appropriate decision<br />

making processes<br />

and evaluations<br />

against management<br />

options that are<br />

subject to external<br />

1st<br />

surveillance<br />

audit<br />

1st<br />

surveillance<br />

audit<br />

1st<br />

surveillance<br />

audit


C4 P3 Fishery<br />

Specific<br />

Manage<br />

ment<br />

System<br />

3.2.5 Information<br />

and<br />

monitoring<br />

review.<br />

Secure evidence that<br />

a more fishery-specific<br />

decision makingprocess<br />

has been<br />

established, which<br />

includes monitoring<br />

and evaluations of<br />

performance against<br />

management<br />

objectives.<br />

3rd<br />

surveillance<br />

audit<br />

Page 146 of 151


APPENDIX D: STAKEHOLDER COMMENTS<br />

(includes all written and verbal communication)<br />

Received from: Jan Willem Wijnstroom, Sportvisserij Nederland, Royal Dutch Angling<br />

Association<br />

May 18 th 2010<br />

Bass is a prime target species for recreational anglers in the Netherlands, UK, Belgium and<br />

France. Bassfishing has gained a lot of popularity during the last 20 years. Due to the decline of<br />

flatfish, cod and eel stocks the range of fishing possibilities also declined: the increase in bass<br />

fishing possibilities provides the Dutch recreational angling sector with new opportunities.<br />

Estimated number of bass anglers in the Netherlands in 2006 was 91.000 (TNS NIPO 2006). More<br />

than 50 % of Dutch bass anglers advocate improved bass stock management. Commercial<br />

fishermen need to take part in this management.<br />

Recreational bass angling in Holland has a calculated socio economic value of 15,8 bilj euro on a<br />

yearly basis.<br />

Recreational bass anglers and commercial anglers (VBHL) fish for the same species and thus<br />

there is common interest in a management system that benefits better management of bass and<br />

other marine resources and in which the interests of both stakeholders are being taken care of.<br />

PI Comment<br />

1.1.1 There are very little scientific research data available on<br />

eastern North sea bass populations. General perception<br />

amongst recreational anglers as well as members of VBHL<br />

is that mature and bigger bass are getting scarcer. There is<br />

a steady decline in the stamp of bass available to<br />

recreational anglers and other metiers like commercial rod<br />

and line fishermen.<br />

1.1.2 Explicit (formal) reference points have not yet been defined<br />

for the bass stocks in ICES Area IV. A main assessment<br />

using the default assessment tree would very likely result in<br />

a score below the unconditional level but above the minimal<br />

level. It is likely that this performance indicator will attract a<br />

condition that requires the client to liaise with Research<br />

Bodies (IMARES, CEFAS) and have a part in the further<br />

development of appropriate reference points for the North<br />

Sea stock.<br />

1.2.2 The mls for sea bass (36 cm) is considered to be too low.<br />

Sportvisserij Nederland advocates an mls increase to 42<br />

cm , to give bass the opportunity to grow and to spawn.<br />

Although occasionally mature bass are found at 36 cm, we<br />

advocate that the whole fishery is subject to measures that<br />

protect undersized bass. VBHL fishermen apply a bigger<br />

mls which is the right step in the direction.<br />

Page 147 of 151


1.2.3 Sportvisserij Nederland strongly advocates to fill the gaps<br />

in scientific research regarding non quota species that are<br />

subject to growing fishing pressure. This is the case with<br />

mullet and bass. There is currently a legal requirement of<br />

the Data Collection Framework to provide quarterly<br />

estimates of the amount of bass landed by recreational<br />

fishermen in western waters but not in the North Sea. The<br />

information provided by recreational anglers questionnaires<br />

is not adequate while it provides us with figures that are<br />

largely aggregated.<br />

The current status of the stocks needs to be better<br />

investigated to achieve a firm basis for a future<br />

managementplan for recreational and commercial fisheries.<br />

1.2.4 There are currently no explicit reference points for the bass<br />

stock. These reference points are a starting point for a<br />

sustainable fishery.<br />

3.1.2 Sportvisserij Nederland wants to be involved in a regular<br />

dialogue with VBHL as a starting point to set up a bass<br />

management plan for both fisheries..<br />

3.2.1 The pre-assessment states that the formulation of specific<br />

management objectives for the Dutch sea bass fishery will<br />

be identified as a condition of certification.<br />

3.2.5 Sportvisserij Nederland endorses the need for a system of<br />

monitoring and evaluation of management measures.<br />

Received from: Ruud Vergouwen, fisherman KG 5.<br />

Geacht heer Buijs,<br />

Mijn naam is Ruud Vergouwen.<br />

Ik ben al ca. 17 jaar actief als lijnenvisser op zeebaars met een kleine snelle boot in de Zuidelijke<br />

Noordzee, waarvan de laatste 5 jaren onder het visserijnummer KG 5.<br />

Vanuit deze beroepsmatige achtergrond en ervaring, worstel ik met een aantal vragen betreffende<br />

het MSC-certificeringstraject voor handlijngevangen zeebaars door de VBHL.<br />

1. Elk voorjaar, zodra de watertemperatuur zo'n 9 graden bereikt, trekken er scholen<br />

zeebaars vanuit Het Kanaal de Zuidelijke Noordzee binnen. Gedurende de maanden april,<br />

mei en juni, verzamelen deze scholen zich op enkele paaiplaatsen om zich voort te<br />

planten. Na deze paaiperiode zwermen de scholen uit over diverse plaatsen, waar zij de<br />

verdere zomer verblijven. Gedurende de maanden half september, oktober, november en<br />

half december vind dan de najaarstrek plaats. Gedurende deze tijd scholen ze weer samen<br />

en verlaten ze (grotendeels) de Zuidelijke Noordzee weer om te overwinteren in warmer<br />

water. Gedurende de eerder genoemde paaiperiode zijn de zeebaarzen het<br />

meest kwetsbaar en worden ze het meest gevangen en dus aangevoerd. Er vanuitgaande<br />

dat het MSC-certificaat behaald wordt door de VBHL, luidt mijn onvermijdelijke vraag dan<br />

ook: Mag de in deze kwetsbare periode (april, mei, juni) gevangen zeebaars straks wel of<br />

Page 148 of 151


niet het MSC-label voeren of mag er straks in de paaitijd helemaal niet gericht op gevist<br />

worden cq. aangevoerd worden?<br />

2. Ik neem aan dat een van de allerbelangrijkste voorwaarden voor MSC-certificering moet<br />

zijn dat er niet meer vis uit een bestand weggenomen wordt dan dat er aanwas is in dat<br />

bestand. Ik ga er ook van uit dat er een wetenschappelijke, biologische vaststelling van die<br />

aanwas moet zijn en dat deze niet gebaseerd wordt op basis van aannames of<br />

aanvoergegevens. Bij mijn weten zijn dergelijke gegevens er niet. Volgens mij is bij<br />

niemand bekend hoe groot de aanwas is van het zeebaarsbestand dat jaarlijks terugkeerd<br />

in de Zuidelijke Noordzee. De hoeveelheden vis die uit dat bestand jaarlijks weggenomen<br />

worden zijn wel redelijk vast te stellen aan de hand van aanvoergegevens. Mijn vraag luidt<br />

dus: Hoe kan je vaststellen of een visserij duurzaam is als je niet weet hoe groot de<br />

aanwas is?<br />

Ik hoop dat u of een van uw medewerkers mijn vragen wil en kan beantwoorden.<br />

M. Vr. Gr.,<br />

R. Vergouwen<br />

My name is Ruud Vergouwen.<br />

I've been around 17 years active as a rod and line bass fisher with a small fast boat in the<br />

Southern North Sea, the last 5 years under the Fisheries KG number 5.<br />

From this background and professional experience, I wrestle with a number of questions<br />

concerning the MSC certification process for hand-line caught sea bass by VBHL.<br />

1. Each spring when the water temperature reaches about 9 degrees, schools of bass migrate<br />

from the English Channel into the southern North Sea. During the months April, May and June,<br />

those schools have to gather at some spawning areas to reproduce. After the spawning period the<br />

schools swarms to various places, where remain over summer. During the months of mid-<br />

September, October, November and December they migrate back During this time schools<br />

together again and they leave (mostly) the Southern North Sea weather to spend the winter in<br />

warmer waters. During the aforementioned spawning bass are the most vulnerable and are<br />

therefore the most caught and landed. Assuming that the MSC certificate will be obtained by the<br />

VBHL my inevitable question therefore is: Can bass which has been caught in this vulnerable<br />

period (April, May, June)be granted the MSC label or will there be a closed season?<br />

2. I suppose one of the most important conditions for MSC certification must be that no more fish<br />

from a stock is removed than there is growth in that file. I also assume that there is a scientific,<br />

biological fixing that growth and that should not be based on assumptions and data flow. To my<br />

knowledge, no such data is in place. I think no one knows how many sea bass returns to<br />

Southern North Sea annually. The annual quantity of fish removed from the stock is reasonably<br />

well known based on landings data. My question is this: How can you determine whether a fishery<br />

is sustainable if you do not know how big the increase is?<br />

I hope you or one of your staff will and can answer my questions.<br />

Page 149 of 151


APPENDIX E: OBJECTION TO DETERMINATION<br />

Page 150 of 151

Hooray! Your file is uploaded and ready to be published.

Saved successfully!

Ooh no, something went wrong!