SGS Product & Process Certification - Marine Stewardship Council

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where the data are presented. These results came from the analytical assessment using commercial catch-at-age data over the period 1985 - 2004, not the surveys. 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 geographically to the certification area and the client fishery and the ports from which the clients operate? Agreed, and now provided. 3.2 Stock status. The most extensive bass studies have been carried out by CEFAS in the UK. Consequently the assessment results presented have 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. There are several references to results that mention dates as ―since 1995‖, ―1989 onwards‖, ―stable since 2004‖, ―since 2004‖, and give the possible 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 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 used the FAD-only model and included data for 2007-2009 which, although more uncertain than previous assessments (to 2004), shows the same trends in the SSB in the North Sea and eastern Channel, i.e. a continued increase. Text amended to clarify. Some results are presented for the southern North Sea (IVc), but more emphasis could have been placed on the most recent ICES deliberations briefly mentioned in the last paragraph of 3.2. There were no ICES deliberations on these results, and no advice was given. 3.3.2 Management advice. Quote ―From a management viewpoint, assessment results (Pawson et al., 2007b; Kupschus et al. 2008; Kupschus, 2010) 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 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 this conclusion (see above comment) and place it in the context of declining landings and stakeholder concerns about decreasing catches of larger mature bass. OK, now provided. 3.3.3 Biological reference points. See 3.1 Recruitment (above) re common recruitment patterns. Quote ―There is, therefore, no stock-recruit relationship for bass……‖. Can you say there is no stock-recruit relationship? Surely there could be one, 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 modelled, either to explain past or to predict future recruitment patterns. The relative strength of recruitment bears no relationship to the size of the spawning stock over the period for which data are available (1984 – 2008), though SSB does reflect strength of recruitment. Text amended to clarify. 3.3.4 Scientific background to management advice for sea bass. This section is all about England again – what about the Netherlands and France? 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 the EC) and from UK sources. Text amended to clarify. 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 species.‖ This is a rather emphatic statement. Are there no undersized bass, cod or saithe caught and discarded (these are retained species, by the 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 client, any numbers will be very limited anyhow. See comment against 2.2 in the scoring table which draws attention to several inconsistencies regarding discarding. 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 verifiable information on the discarding behaviour of the clients at sea? No? There are no audit trace references given in the Scoring Table. Jan Willem Wijnstroom, Sportvisserij Nederland in Appendix D states ‖VBHL fishermen apply a bigger mls which is the right step in the direction.‖ This 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 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 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 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 the RBF under PSA Susceptibility attributes and scores. 5.1 Legislation and regulation. Quote ―In France, a national regulation limiting bass landings by French pelagic trawlers fishing in the English Channel 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 this does not apply in the southern North Sea where French landings (Table 1) have increased in recent years. Yes it does. 5.2 Roles & Responsibilities. Quote ―The North Sea Demersal RAC has greatly improved effective communication links between industry, NGO‘s, 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 species only for small boats and a by catch species for larger vessels, and there are no stock, TAC, or quota concerns. Quote ―The most important working group when considering sea bass is WGNEW, which ICES established in 2005 to provide the EC with advice on stock status and management of so called MoU (Memory of Understanding) species.‖ Yet there has been little output referred to in this report. Have 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 should be more ICES input in this report. 5.4 Monitoring, Control and Surveillance. Quote ―After entering a port, fishing vessels have to deliver a logsheet with all landed quantities and 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 (Table 2). AID information is not made public Page 126 of 151
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Public comment draft report Marine
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Glossary of acronyms and terms used
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9.2.3 PSA .........................
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Condition 1: P1, 1.2.2 Harvest cont
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Current members of VBHL are the fol
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1.4 References Castilho, R., and Mc
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Pawson, M.G., G. D. Pickett and P.
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Figure 2.Main migration routes of a
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This hypothesis was tested in 2000
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also comprised a substantial part o
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3.1 Analytical assessments The firs
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Figure 3.Indices of the abundance o
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short-term forecasts and setting TA
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The landings of cod by the UoC are
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monitoring, landing recording, etc.
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and use only of rod-and-line, with
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7. STANDARD USED The MSC Principles
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a) setting catch levels that will m
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8.2 Public consultation Public anno
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certified as sustainable on 3 rd De
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9.2.2 SICA A SICA proceeds in sever
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Table 4.SICA tables from the MSC Fi
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Table 6. PSA Productivity attribute
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Table 9. FAM Workbook Table with sc
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10.1 Performance 10. ASSESSMENT RES
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controls) that seek to maximise Y/R
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management system responded to find
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Recommendation 4 - Governance and p
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13.1 Logo use 13. MSC LOGO LICENSIN
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APPENDICES APPENDIX A: SCORING TABL
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Scoring criteria Scoring guidepost
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metrics are more appropriate to a s
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This is regarded as an implicit har
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emovals are apparent in the range o
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Audit trace references Insert refs
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Page 97 and 98: livelihood; and - Incorporates an a
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Page 123 and 124: ass. If the scores I have questione
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Page 131 and 132: Appendix A: Scoring Table. (Comment
Page 133 and 134: 2.3.2. Management Strategy. Quote
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Page 145 and 146: Performance Indicator 1.1.1 2.1.1 2
Page 147 and 148: C4 P3 Fishery Specific Manage ment
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Page 151: APPENDIX E: OBJECTION TO DETERMINAT
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