Intertek Fisheries Certification (IFC) 10A Victory Park Victory Road Derby DE24 8ZF UK www.intertek.com/food/msc-certification INTERTEK FISHERIES CERTIFICATION February 2015 Ref: 82007 South African Hake Trawl Fishery Public Comment Draft Report Authors J. Andrews, J. Groeneveld, M. Pawson Client name and address Johann Augustyn South African Deep Sea Trawling Industry Association - SADSTIA Pearl House Heerengracht PO Box 2066 Cape Town 8000 South Africa Tel: +27 (0) 21 425 2727 Fax: +27 (0) 21 419 0785
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Intertek Fisheries Certification (IFC)
10A Victory Park
Victory Road
Derby
DE24 8ZF
UK
www.intertek.com/food/msc-certification
INTERTEK FISHERIES CERTIFICATION
February 2015
Ref: 82007
South African Hake Trawl Fishery
Public Comment Draft Report
Authors
J. Andrews, J. Groeneveld, M. Pawson
Client name and address
Johann Augustyn
South African Deep Sea Trawling Industry Association - SADSTIA
This species is classified as Vulnerable by the IUCN because of suspected rapid declines, although
almost no reliable estimates of historical populations exist. Very high rates of incidental mortality in
longline fisheries have been recorded in recent years; the probability that these circumstances will
continue and its susceptibility to predation and the degradation of breeding habitat indicate that a
rapid and on-going population decline is likely.
The earlier studies of the hake trawl fishery found that 10% of the birds killed in the hake trawl
fishery were white-chinned petrels (Watkins et al, 2007). The more recent study by Maree et al
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(2014) recorded just 3 white-chinned petrel deaths (though nocturnal interactions were not studied).
6.3.1.5 Cape gannet, Morus capensis
This species is listed as Vulnerable by BirdLife International since it has a very small breeding range
on just six islands, and over-exploitation of its prey (epipelagic fish) by human fisheries -
compounded by pollution - is causing a continuous decline in the quality of surrounding waters for
foraging. Other threats include guano collection, displacement by Cape fur seals, predation by great
white pelicans, bycatch in longline fisheries, exploitation of gannets for food in Angola, and flooding
of nests in storms.
The hake fishery is not listed as a threat to this species.
6.3.1.6 Shy albatross, Thalassarche cauta
This species breeds on just three islands. It may be susceptible to stochastic events and human
activities, although one nesting site is moderately widely separated from the other two. For this reason
it is treated as Near Threatened by the IUCN.
Evidence from the South African trawl fishery (Maree et al, 2014) has concluded that the impacts of
the UoCs under assessment on this species were once significant but are now negligible.
6.3.1.7 Pintado petrel, Daption capense
This species has an extremely large range, and hence does not approach the thresholds for Vulnerable
under the range size criterion (Extent of Occurrence <20,000km2 combined with a declining or
fluctuating range size, habitat extent/quality, or population size and a small number of locations or
severe fragmentation). The population trend appears to be stable, and hence the species does not
approach the thresholds for Vulnerable under the population trend criterion (>30% decline over ten
years or three generations). The population size is extremely large, and hence does not approach the
thresholds for Vulnerable under the population size criterion (<10,000 mature individuals with a
continuing decline estimated to be >10% in ten years or three generations, or with a specified
population structure). For these reasons the species is evaluated as Least Concern by IUCN.
Maree et al (2014) record 21 mortalities and 612 heavy interactions with pintado petrels. This is the
highest level of interaction recorded with any bird species. The information about population status
provides reassurance that this level of interaction is not adversely affecting this species.
6.3.1.8 Great shearwater, Ardenna gravis
This species has an extremely large range, and hence does not approach the thresholds for Vulnerable
under the range–size criterion (Extent of Occurrence <20,000km2 combined with a declining or
fluctuating range size, habitat extent/quality, or population size and a small number of locations or
severe fragmentation). The population trend appears to be stable, and hence the species does not
approach the thresholds for Vulnerable under the population trend criterion (>30% decline over ten
years or three generations). The population size is extremely large, and hence does not approach the
thresholds for Vulnerable under the population size criterion (<10,000 mature individuals with a
continuing decline estimated to be >10% in ten years or three generations, or with a specified
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population structure). For these reasons the species is evaluated as Least Concern by the IUCN.
6.3.1.9 Sub-Antarctic skua, Catharacta antarctica
This species has an extremely large range, and hence does not approach the thresholds for Vulnerable
under the range size criterion (Extent of Occurrence <20,000km2 combined with a declining or
fluctuating range size, habitat extent/quality, or population size and a small number of locations or
severe fragmentation). The population trend appears to be stable, and hence the species does not
approach the thresholds for Vulnerable under the population trend criterion (>30% decline over ten
years or three generations). The population size may be moderately small to large, but it is not
believed to approach the thresholds for Vulnerable under the population size criterion (<10,000
mature individuals with a continuing decline estimated to be >10% in ten years or three generations,
or with a specified population structure). For these reasons the species is evaluated as Least Concern
by the IUCN.
6.3.1.10 Sooty shearwater Puffinus griseus
This species is classified as Near Threatened because although it has a very large global population it
is thought by BirdLife to have undergone a moderately rapid decline owing to the impact of longline
fisheries, the harvesting of its young (unconnected with the fishery under assessment) and possibly
climate change.
The global population of this species is estimated at around 20,000,000 individuals. Observations of
the hake trawl fishery suggest that the level of interaction is now very low (Maree et al, 2014).
6.3.1.11 Cory’s shearwater, Calonectris borealis
This species has an extremely large range, and hence does not approach the thresholds for Vulnerable
under the range size criterion (Extent of Occurrence <20,000km2 combined with a declining or
fluctuating range size, habitat extent/quality, or population size and a small number of locations or
severe fragmentation). Despite the fact that the population trend appears to be decreasing, the decline
is not believed to be sufficiently rapid to approach the thresholds for Vulnerable under the population
trend criterion (>30% decline over ten years or three generations). The population size is very large,
and hence does not approach the thresholds for Vulnerable under the population size criterion
(<10,000 mature individuals with a continuing decline estimated to be >10% in ten years or three
generations, or with a specified population structure). For these reasons the species is evaluated as
Least Concern by the IUCN.
6.4 Habitat Interactions
A detailed review of the interactions between the South African trawl fishery and marine habitats is
set out in Sink et al (2012). This document also set out spatial analyses of the interactions and
proposes potential management actions. The main findings of this comprehensive review are briefly
summarised below.
The area of seabed in South African waters that has been trawled has increased from the start of the
inshore trawl fishery in the late 1880s to the current extent of the fishery. Over this time the trawl
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footprint has increased in size in both the inshore and offshore areas. In 2007 the fishing industry
developed a map of the trawl footprint and made a commitment that no further expansion of the
fishing grounds would take place. This footprint covers an area of around 70,160km² (see Figure 31).
All trawl fishing vessels are required, as a statutory fishing licence condition, to fish only within this
trawl footprint. Compliance with the trawl footprint is monitored by DAFF using vessel VMS data.
South Africa recently classified and mapped 136 marine and coastal habitats as part of the National
Biodiversity Assessment 2011. Benthic habitat types were characterised on the basis of the seabed
substratum (such as mud, sand, gravel and rock); depth; topography (such as shelf, canyon, or mound)
and information on marine benthos (such as cold water corals, gorgonians, sponges and soft corals)
where this was available.
Sink et al (2012) examined information from a wide range of sources to identify the spatial extent of
the interaction between the trawl fishery and benthic habitat types. A total of 27 different habitat
types occur within the trawl footprint area (see Figure 32). The dominant habitat types are the
Southern Benguela Sandy Outer Shelf (21% of the footprint) and the Southern Benguela Sandy Shelf
Edge (14%).
Information about the location of these habitats and their vulnerability (based on the structural
complexity of the benthos and Vulnerable Marine Ecosystem (VME) indicator species) was related by
Sink et al (2012) to data describing trawling intensity to allow “habitats of concern” to be identified
(these being those that are vulnerable to trawling; occur largely within the trawl footprint; and that are
subject to significant trawling activity).
Following this analysis a total of 17 habitat types of concern were identified based on one criterion,
and 9 habitat types based on multiple selection criteria. Only one habitat type met all of the criteria
(the Southern Benguela Canyon).The location of these “priority habitats” is shown in Figure 33 &
Figure 34, and they are listed below:-
Southern Benguela Canyon
Southern Benguela Muddy Shelf Edge
Southern Benguela Hard Shelf Edge
Agulhas Canyon
Southern Benguela Gravel Shelf Edge
Agulhas Gravel Outer Shelf
Southern Benguela Gravel Outer Shelf
Southern Benguela Submarine Bank
Southern Benguela Sandy Shelf Edge
These habitats of concern were recommended for management actions: proposals for mitigation
included the review and strengthening of trawl licence conditions; spatial management measures
including experimental closures; seabed protection zones and offshore Marine Protected Areas.
Research recommendations have also been identified to improve the understanding of trawl impacts
on hard grounds and muds; assess recovery of the dominant habitat types on the trawl grounds; and to
identify and protect examples of sensitive habitats that have not been trawled.
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In February 2014 work began on a benthic trawl experiment near to Childs Bank on the outer shelf of
the west coast where the Southern Benguela Sandy Shelf Edge habitat is prevalent (over 70% of this
habitat type is within the trawl footprint, and it also makes up around 14% of the total trawl footprint
area). This work was a response to a condition of certification raised at the last assessment of this
fishery in 2010. It has taken several years to agree a research programme that would address this
condition, and to secure the funding, equipment and staff resources required. This experiment is
being conducted with industry (SADSTIA) funding, and all of their member vessels (i.e. all of the
hake trawl fleet operating in this area) have been directed by SADSTIA to comply with the
experimental restrictions (on a non-statutory basis).
In 2014 a towed camera and van Veen grab were deployed from the research vessel Ellen Khuzwayo
and used to take samples from a 6 x 15km experimental area within the trawl footprint. This area has
been divided into “lanes” and fishing vessels operating in the area are now trawling in some lanes
while leaving others unfished, in order to observe how the seabed recovers after a period of trawling.
The location of the experimental area and the trawl lanes is shown in Figure 36.
From a management perspective, marine habitats in South Africa can be protected by Marine
Protected Areas established under the Marine and Living Resources Act (1998). There are currently
20 MPAs in the South African EEZ (see Figure 35). Inshore trawl licences prohibit trawling within
these MPAs. The South African National Biodiversity Act (2004) and the Protected Areas
Amendment Act (2004) call for the creation of a “representative” network of protected areas in the
sea. Proposals for developing this network of MPAs have been set out in several reports and papers
(such as Sink & Attwood, 2008; Solano-Fernandez et al, 2012).
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Figure 31: Boundary of “ring fenced” hake trawl footprint (mapped by Wilkinson & Japp, 2008; figure reproduced from Sink et al, 2012).
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Figure 32: The habitat composition within the 70,160km² South African hake trawl footprint. (Note
that the percentages indicate the relative proportion of each habitat type within the
footprint, but not how much of the total extent each habitat type is trawled). [Source:
Sink et al, 2012].
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Figure 33: Priority habitats (based on extent & vulnerability of habitats and intensity of fishing) on the west coast within the trawl footprint area. [Source:
Sink et al, 2012].
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Figure 34: Priority habitats (based on extent & vulnerability of habitats and intensity of fishing) on the south coast within the trawl footprint area. [Source:
Sink et al, 2012].
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Figure 35: Map showing current Marine Protected areas in South Africa. [Source: SANBI, 2014].
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Figure 36: Map showing the location of the experimental trawl exclusion area on the west coast.
[Source: SADSTIA, 2012].
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6.5 Ecosystem Interactions
The key feature of the ecosystem in which the hake fishery takes place in is the influence of the cold
Benguela current that flows from the south. The upwelling of this cold, nutrient rich water fuels
phytoplankton growth which in turn nourishes a highly productive ecosystem. The Benguela current
is driven by the South Atlantic gyre.
The role of hake in the Benguela ecosystem and the effects of fishery removals on this ecosystem
have been modelled, including the potential combined effects of climate change and fishing activity
(Gasche et al, 2012; Shannon et al, 2000; Travers-Trolet et al, 2014). The outcome of this work
demonstrates that there is a good understanding of the main components and elements of the Benguela
current ecosystem, as well as an understanding of how these different components and elements may
interact with one another.
The study of the potential effects of increased hake trawling on the ecosystem suggested that the
effect of heavy fishing for hake (for example, a four-fold increase in fishing mortality for a period of 5
years) would reduce hake biomass and increase the abundance of hake prey species (mesopelagic fish
and cephalopods). Such a change was considered likely to adversely affect horse mackerel, which
compete with the hake prey species for food. The model also suggested that within a period of 10-20
years after such a period of intense fishing, all groups are likely to return to their original levels
(Shannon et al, 2000).
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7 PRINCIPLE THREE: MANAGEMENT SYSTEM BACKGROUND
7.1 Management framework
South Africa’s natural environment is governed by a wide range of national legislative acts, including
the Constitution of the Republic of South Africa (1996), National Environmental Management Act
(No. 107 of 1998), the Environmental Conservation Act (No. 73 of 1989) and the Marine Living
Resources Act (MLRA; No. 18 of 1998). All fisheries in South Africa are managed in terms of the
MLRA and the regulations promulgated in terms of this Act. The regulations are amended on a
regular basis to facilitate the incorporation of updated management measures, or implement
management strategies based on best scientific advice. These amendments are published in the
Government Gazette.
The Department of Agriculture Forestry and Fisheries (DAFF) is the Management Authority
responsible for implementing the MLRA, and it is committed to international law (UNCLOS; UN
Convention on the Law of the Sea;) and a precautionary approach is prescribed when uncertainty
prevails. The Republic of South Africa is a signatory to the Convention on Biodiversity, MARPOL
(International Convention for the Prevention of Pollution from Ships), the London Convention
(regulating the dumping of waste at sea), Bonn Convention (conservation of migratory species, incl.
seabirds), CITES (the Convention on International Trade in Endangered Species), SEAFO (SE
Atlantic Fisheries Organization) and is member of ICCAT. The management framework is
demonstrably compliant with all relevant international conventions and agreements. National
legislation and the systems that support it are binding, both within the Management Authority and
relative to the fisheries that they manage.
The management framework incorporates a transparent mechanism for legal dispute resolution, which
has been tested and proven to be effective. Disputes within the system are first discussed directly with
DAFF resource managers but can proceed to ministerial level. Beyond ministerial level, disputes may
be resolved in court, within the national judicial system. In recent years, major disputes have regularly
been resolved through legal challenges – for instance disputes regarding the allocations of fishing
rights. The opportunity to mount a legal challenge to the system is seen as a positive aspect,
demonstrating a well-developed and fully tested process of dispute resolution, the outcomes of which
reflects legislative compliance.
7.2 Management and research institutions
The DAFF houses Chief Directorates for:
a) Monitoring Control and Compliance - to ensure that fish resources are protected through
effective and efficient utilisation of the Fisheries Protection Vessels and other relevant
equipment and systems; and to ensure compliance with the provisions of the Marine Living
Resources Act of 1998.
b) Marine Resources Management - to ensure the sustainable utilization and equitable and
orderly access to nearshore, offshore and High Seas fisheries resources through improved
management and regulation.
c) Fisheries Research and Development - to provide scientific research and advice on fisheries
resources.
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The DAFF structure is supplemented by other national organs. Monitoring Control and Compliance
is assisted by customs, police/navy and provincial authorities, but the process is coordinated by
DAFF. Fisheries Research and Development is likewise supplemented by the Department of
Environmental Affairs (DEA), which undertakes research on ecosystems and environmental impacts
of fisheries.
At least two formally constituted working groups within DAFF deal with all aspects of the hake trawl
fishery, namely a Scientific Working Group, and a Resource Management Working Group. These
working groups guide the science underlying management strategies (i.e. research direction and data
production; development of mathematical models; Operational Management Procedures) and
implement management strategy through official interaction between DAFF fisheries managers and
representatives of the fishing industry. The functions, roles and responsibilities of the scientific and
management working groups are clearly defined.
7.3 Recognized interest groups
Several interest groups that may influence decisions through direct or indirect means have developed
over the 10 years of MSC certification. The primary interest groups are the two industry associations,
SADSTIA and SECIFA, which represent all rights holders (fishing units) in the deep-sea hake trawl
fishery. Eligible vessels of SADSTIA and SECIFA members are listed in Table 1. SADSTIA and
SECIFA are active in the DAFF Scientific and Resource Management Working Groups, as members
or observers, where they participate by imparting up-to-date operational information, assist with
decision-making by explaining economic and logistical matters affecting fleets, operations, and
markets, and also contribute to the development of mathematical models and the OMP through
retaining the services of consultants at OLRAC. SADSTIA and SECIFA manage the operational
aspects of the fishing fleet, including a supporting role to DAFF in ensuring that permit conditions are
adhered to. The associations fund an independent fisheries observer programme, and additional
research projects on recovery of environmental impacts of the trawl fishery, and bycatch mitigation.
Other recognized interest groups are as follows:
a) World Wide Fund for Nature South Africa (WWFSA) – an environmental NGO; pressure
group with influence on perceptions of stock status, environmental impacts and management
of the fishery;
b) Birdlife South Africa (BLSA) - an environmental NGO and the largest bird conservation
organization in South Africa. BLSA is the local partner of BirdLife International and a
member of the Responsible Fisheries Alliance. BLSA initiated an Albatross Task Force team
in 2006, and is responsible for drawing up the Bird Mitigation Plans required by fishing
vessels in South Africa, in collaboration with the fishing industry;
c) South African National Biodiversity Institute (SANBI) - responsible for implementing the
National Environmental Management: Biodiversity Act 10 of 2004. SANBI coordinates
research, and monitors the state of biodiversity in South Africa. It provides planning and
policy advice and pilots best-practice management models in partnership with stakeholders, in
the present case, SADSTIA. SANBI engages in ecosystem restoration and rehabilitation.
d) The South African Environmental Observation Network (SAEON) - a business unit of the
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National Research Foundation, and accountable to the Department of Science and
Technology. SAEON is mandated to detect, predict and react to environmental change within
South Africa through long-term observation. SAEONs vision is to deliver long term, reliable
data for scientific research and to inform decision making.
e) Marine Resource Assessment and Management Group, University of Cape Town (MARAM)
– mathematical modelling unit that developed the resource assessment models and the OMP
for the management of the deep-sea hake trawl fishery. Funded by DAFF.
f) University of Cape Town, Zoology Department – Dr Colin Attwood provides scientific
advice to SADSTIA on bycatch species and its management, and on a benthic trawl
experiment to assess recovery / rehabilitation potential.
g) CapFish – Independent provider of fisheries observers to SADSTIA, to collect information on
hake species and size composition and biology, and of bycatch of the hake trawl fishery.
Provides data capture and reporting services, and ad hoc consulting.
h) The Responsible Fisheries Alliance (RFA), which provides a forum for environmental NGOs
and responsible fishing companies to work together to secure the health of the ecosystems
which underpin the business purpose of both sectors.
7.4 Management objectives
Clear long-term management objectives guide decision-making, and are consistent with MSC
Principles and Criteria and the precautionary approach. These include objectives relative to Principle
1 (the hake stocks under reassessment), Principle 2 (important bycatch species and the environment)
and Principle 3 (the management system). Some objectives have performance indicators (limit and
target reference points), notably those applied to the target species (TAC) and some bycatch species
(i.e. PUCLs).
Management objectives relative to the hake stocks are to increase the weaker M. paradoxus biomass
level to close to the MSY level over 20 years; to improve catch rates in the short to medium term; and
to maintain a stable TAC over time. These objectives are implicit in the OMP, which responds to
measures of stock changes on an annual basis, and is geared to achieve stock rebuilding to a pre-
agreed level over the long-term. A specific OMP formulation is revisited every 4 years, when
improvements are made. The OMP incorporates the precautionary principle, in that it will output a
more conservative TAC in the event of higher risk scenarios.
Long-term objectives are also in place for important by-catch species (i.e. monkfish; kingklip; sole),
and where these are identified as being depleted, appropriate management strategies are being
developed and implemented to promote/assist rebuilding of affected populations to specified levels
within specified timeframes. These include bycatch management areas and PUCLs.
Long-term environmental objectives relative to the hake fishery include the establishment of Marine
Protected Areas, where the objective is to protect and preserve examples of representative habitat
types. The policy basis for the MPA programme lies in the Convention of Biological Diversity, which
aims for the protection of 10% of representative and vulnerable habitats, and the draft South African
Ocean Policy which refers to representative MPAs. Biodiversity targets are being developed based on
species-area relationships. A major objective is maintenance of the trawl footprint, which restricts
trawl operations to a limited depth range and area – thus spatially limiting impacts on benthic habitats.
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Only 2 habitats (southern Benguela gravel habitat and southern Benguela muddy shelf) are not also
present elsewhere, outside of the footprint or in existing MPA’s.
Another objective, the reduction of seabird mortalities caused by fishing operations, has been
achieved to a large degree by successful introduction of tori lines. Although none of the affected
seabirds are ETP species, some of them are listed on the IUCN red list. A trawl recovery experiment
has been initiated to assess whether, and how fast historically trawled areas can recover – the
completion of this experiment is considered to be a short to medium term objective, and potentially its
outcome can be incorporated into fishery management over a longer term.
Social and economic objectives include equitable redistribution of fishing rights. Theoretically, a
system of long-term fishing rights will provide participants in the fishery with a sense of “ownership”
of the resource. Maintaining Marine Stewardship Council certification is an important economic
objective related to marketing strategy.
7.5 Decision-making process
In most cases decision-making processes respond to important issues identified in relevant research,
monitoring, evaluation and consultation, in a transparent and adaptive manner. A formal Scientific
Working Group, constituted by DAFF and comprising scientists from DAFF, MARAM and those
retained by SADSTIA, decide on a TAC level for the fishery after interpreting the outcome of an
OMP. The OMP is an agreed formulation set for a 4-year period, and cannot be over-ridden unless in
“exceptional circumstances” (under Section 61 of the MLRA). The decision-making process uses the
precautionary approach; this is demonstrated by the long-term stock rebuilding strategy implicit in the
OMP calculations, where the TAC is set to protect the weaker of the two stocks (presently M.
paradoxus). The best available information is used, including logbook information, survey data, and
data collected by fisheries observers at sea.
The TAC recommendation is considered by the DAFF Chief Directorate: Marine Resource
Management, taking into account factors such as legislation, socio-economics, the ecosystem
approach to fisheries management (EAF), and stock advice. It is then submitted to the decision maker
(normally the Minister) in line with Departmental protocols. After signature by the Minister, the TAC
is allocated to rights holders, proportionally, according to their share of the rights allocated. A DAFF
fisheries manager dedicated to the hake fishery then meets with industry to prepare annual fishing
plans, and prepare permit conditions.
7.6 Incentives to fish sustainably
There is a high degree of confidence that fishers comply with the management system under
assessment, and this is supported by very few transgressions observed over the past year. All of these
were minor administrative issues. Sanctions to deal with non-compliance exist, and are effective in
the fishery being assessed. The reason for this is that non-compliance can potentially result in the
suspension or loss of fishing rights under Section 28 of the MLRA. An example of a successful
Section 28 ruling, followed by the closure and prosecution of a major fishing company, is the case of
Hout Bay Fishing. Although not for hake, it was a similar industrial scale fishery targeting deep-water
lobsters. Whereas a Section 28 sanction is a major deterrent for capital-intensive industrial fisheries
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with good long-term prospects (such as the hake fishery), it is less so for small scale (subsistence)
fishers preying on nearshore resources such as abalone and rock lobsters in South Africa.
7.7 Monitoring, control and surveillance (MCS)
Monitoring, control and surveillance is the responsibility of DAFF, supplemented by the police, navy
and customs offices. All catches are inspected and weighed at off-loading points by monitors and/or
fisheries inspectors, to ensure that rights-holders remain within their hake quotas, that bycatch species
do not exceed PUCLs, and that no gear or other restrictions had been exceeded. All fishing vessels
are tracked in real time through a VMS system, operated from an operations room at the DAFF
offices. Fishing vessel tracks showed that vessels have been fishing exclusively within the trawl
footprint. Four ocean-going patrol vessels do inspections of vessels at sea – these patrols are logged,
together with records of inspections, infractions and boarding data.
DAFF has a compliance auditing plan for all sectors of the fishing industry. The hake sector is one of
the 4 compliance priorities in South Africa. Over the course of the past year they aimed to audit 8 of
the deep sea trawl fishery rights holders (SADSTIA), and 16 of the inshore trawl fishery rights
holders (SECIFA). As well as remote surveillance (VMS) and monitoring at sea by patrol vessels,
DAFF inspects landings when catches are discharged, and audits the catch, landings and processing
records for the fishery to ensure compliance with effort (TAC) controls. DAFF enforcement activity
directed at the hake fishery detected only 7 minor administrative errors over the past year, which had
been well documented. The vessels were fined for these transgressions.
Mobile scanners are used to inspect the contents of containers. Fisheries observers accompany fishing
vessels to sea at request (permit condition), although the task of observers is data collection (catch of
target and non-target species, and interactions with ETP species) instead of compliance monitoring.
Skippers return logbooks of each trip, detailing fishing effort and catches. They also report the
numbers of sea-bird fatalities.
About 70% of cases brought by DAFF are successful; as part of its work, DAFF officials provide
training to the judiciary and prosecuting counsel about fisheries legislation and regulation.
Some weak points in MCS enforcement do still exist, and these include too few staff and that one of
the four fishery patrol vessels is presently out of action. The conclusion is that the MCS system is well
established, and works well for the fishery under assessment (a large commercial fishery that offloads
in ports in major centres), especially in a co-management setup with SADSTIA, but that some
attention should be given to its consistency (i.e. all vessels active, etc.).
7.8 Illegal, Unreported Unlicensed (IUU) fishing
DAFF has recently had significant enforcement successes (all outside of the hake fishery) including
detecting, apprehending and seizure of 10 IUU vessels, and intercepting, seizing and repatriating
consignments of illegally shipped fish products (no hake involved). No IUU fishing activities have
been reported for the deep-sea hake trawl fishery.
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7.9 Research Planning
A research plan is in place for the fishery which identifies priorities so that resources can be targeted
appropriately. Research priorities are reviewed by DAFF scientists annually. The research plan
includes aspects that relate to P1 (i.e. biomass surveys; ageing; length composition; diet of hake;
genetic population structure of M. capensis and M. paradoxus), P2 (status and biology of retained
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13 RISK BASED FRAMEWORK (RBF) OUTPUTS
The Risk Based Framework (RBF) has not been used in this report.
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14 CONDITIONS OF CERTIFICATION
The two units of certification returned a score of less than 80 for 5 performance indicators. One of
these conditions applies to just the M. paradoxus UoC (UoC1). The other four conditions are
associated with the same scoring issues and aspects of the fishery for each UoC.
The conditions are listed below.
14.1 Conditions for UoC1, M. paradoxus
14.1.1 Condition 1: stock status
Performance
Indicator 1.1.1
Score 70
Scoring Issue(s) scoring less than 80
SIb SG60 SG80 SG100
The stock is at or
fluctuating around its target
reference point.
There is a high degree of
certainty that the stock has
been fluctuating around its
target reference point, or
has been above its target
reference point, over recent
years.
N N
Rationale
The best estimates of the current (2013) M. paradoxus SSB is 147 kt, which is about
about 98% of the spawning biomass at MSY (153 kt). Whilst it is apparent that there
has been a recovery of paradoxus since the low point in 2007, and the reference set of
operating models indicate that the stock is close to its target reference point (SG80), the
stock has not been fluctuating around its target reference point (the SG80 requirement),
nor has it been above its target reference point, over recent years (SG100 not met).
Condition
The scoring of this PI at less than 80 triggers PI 1.1.3 (stock rebuilding). Stock
rebuilding is the response required to achieve the SG80 score for PI 1.1.1.
The assessment team has found that there is a stock rebuilding strategy in place, and that
it is working (PI 1.1.3 scores 90).
The condition of certification is therefore continued implementation of the rebuilding
strategy already in place.
Relationship to
previous conditions
This condition builds on the previous condition relating to the stock status of M.
paradoxus, which required than an appropriate rebuilding programme was put in place.
Though that condition was met; the rate of stock recovery has been longer than the
duration of the previous period of certification, so it is appropriate to generate a new
condition with respect to stock status.
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Milestones
The OMP has projected the likely recovery for the M. paradoxus stock over the period
2010-2020. The recovery of the stock relative to the OMP projections is monitored
annually by MARAM and provides an independent basis for evaluating progress.
The current rate of recovery indicates that the stock will reach its target reference point
before 2020 (i.e. within the five year period of certification).
The SG80 requirement will be met when stock assessments indicate that the TRP has
been met.
14.1.2 Condition 2: ETP species information
Performance
Indicator 2.3.3
Score
70
Scoring Issue(s) scoring less than 80
SIa SG60 SG80 SG100
Information is sufficient to
qualitatively estimate the
fishery related mortality of
ETP species.
Sufficient information is
available to allow fishery
related mortality and the
impact of fishing to be
quantitatively estimated for
ETP species.
Information is sufficient to
quantitatively estimate
outcome status of ETP
species with a high degree
of certainty.
Y N N
Rationale
The information available for impacts on ETP bird species in offshore areas is sufficient
to estimate the overall impact of the fishery on these species to be estimated
quantitatively, which would meet the SG100 requirements. For the inshore areas there
is much less information available. This is sufficient to allow a qualitative estimate of
fishery-related mortality on these species, but not to quantify impacts.
Overall, the SG60 requirements are met for the hake trawl fishery, and this score is
appropriate. With better information about the mortality of birds in inshore areas, the
SG80 requirements could be met. A condition has been generated to address this issue.
Condition
Information should be gathered to allow fishery related mortality of bird species and the
impact of fishing on these species to be quantitatively estimated for the hake trawl
fishery in inshore areas (waters shallower than 110m).
This could be achieved by continued implementation of the recently established bird
observer programme for inshore areas and analysis of observer data so that bird
mortality and trends in mortality can be quantified.
Relationship to
previous conditions
Milestones
There is already a SADSTIA-funded bird observer programme in place. Meeting this
condition will require ongoing implementation of this programme and analysis of
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findings. The anticipated milestones are set out below:-
Year 1: Evidence of continued implementation of bird observer programme and
preliminary analysis of findings.
Likely resulting SI Score: 60
Year 2: Evidence of continued implementation of bird observer programme and further
analysis of findings.
Likely resulting SI Score: 60
Year 3-4: Evidence of continued implementation of bird observer programme and
reporting of findings to show that bird mortality and impact on bird species can be
quantitatively estimated.
Likely resulting SI Score: 80
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14.1.3 Condition 3: Habitat impact management
Performance
Indicator 2.4.2
Score
70
Scoring Issue(s) scoring less than 80
SIb SG60 SG80 SG100
The measures are
considered likely to work,
based on plausible
argument (e.g. general
experience, theory or
comparison with similar
fisheries/habitats).
There is some objective
basis for confidence that
the partial strategy will
work, based on information
directly about the fishery
and/or habitats involved.
Testing supports high
confidence that the strategy
will work, based on
information directly about
the fishery and/or habitats
involved.
Y N N
Rationale
Information about the fishery shows that the type of fishing gear that can be used is
constrained by fishing licence conditions; fishing effort is limited by quotas and days at
sea; and the areas that can be fished are fixed (by the fishing industry) to the boundary
of the trawl footprint established in 2007. Thus there is a partial strategy in place that
constrains potential fishery impacts on marine habitats.
Information is available about the extent, distribution and sensitivities of marine
habitats. This information from the fishery shows that there has been fishing activity in
and around these habitat types for several decades. Independent information has also
been presented by DAFF to confirm that compliance with both the statutory controls
(gear type and effort) and also the trawl footprint by the trawl fishery has been very
good. There is thus a plausible argument that these management measures will work
(based on past experience and the “freezing” of habitat impacts). This meets the
requirements of SG60.
Although there is some objective basis for confidence that these measures will constrain
fishing impacts, there are concerns that the extent of the existing MPA network is not
adequate to provide targeted protection to specific offshore habitats that are within the
existing trawl footprint area. The limitations in the management regime in this respect
means that the SG80 requirements for this SI are not presently met.
This shortcoming in the management regime could be addressed by investigating and
confirming the need for establishing further measures to manage trawl fishery impacts
on benthic marine habitats within the existing trawl footprint area (and indeed whether
there is evidence that these would be effective – which will be demonstrated by the
trawl impact study already underway). A condition has been generated to address this
issue.
Condition
There should be further investigation of the options for protecting benthic habitats from
hake trawl fishery impacts. This investigation could consider, inter alia, the relative
merits of both statutory measures and self regulation and also the areas that may require
or might benefit from such measures (for instance the South Benguela Canyon). It is
noted that much of the groundwork for this aspect of the condition has been done.
Having identified appropriate measures and areas for action, evidence of progress with
the implementation of the favoured management measures would be required.
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It is anticipated that the information derived from the trawl experiment will provide
information from the hake trawl fishery on the type of management measures that may
be appropriate.
Relationship to
previous conditions
This condition builds on the previous condition of certification that required information
on trawl fishery impacts to be gathered. The information from the ongoing work on that
condition will be vital to inform work on this condition.
Milestones
A considerable amount of work has been carried out to establish a procedure to identify
“habitats of concern” based on their vulnerability to impacts from the trawl fishery (see
Sink et al, 2012).
The milestones set out below seek to build on that work to improve the performance of
the fishery against this SI.
The anticipated milestones are set out below:-
Year 1: Further evaluation of management options for “habitats of concern” within the
trawl footprint area.
Likely resulting SI Score: 60
Years 2-4: Evidence of implementation of appropriate management measures designed
to protect “habitats of concern” within the trawl footprint area, and evidence of fleet
compliance with the management regime.
Likely resulting SI Score: 80
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14.2 Conditions for UoC2, M. capensis.
14.2.1 Condition 4: ETP species information
Performance
Indicator 2.3.3
Score
70
Scoring Issue(s) scoring less than 80
SIa SG60 SG80 SG100
Information is sufficient to
qualitatively estimate the
fishery related mortality of
ETP species.
Sufficient information is
available to allow fishery
related mortality and the
impact of fishing to be
quantitatively estimated for
ETP species.
Information is sufficient to
quantitatively estimate
outcome status of ETP
species with a high degree
of certainty.
Y N N
Rationale
The information available for impacts on ETP bird species in offshore areas is sufficient
to estimate the overall impact of the fishery on these species to be estimated
quantitatively, which would meet the SG100 requirements. For the inshore areas there
is much less information available. This is sufficient to allow a qualitative estimate of
fishery-related mortality on these species, but not to quantify impacts.
Overall, the SG60 requirements are met for the hake trawl fishery, and this score is
appropriate. With better information about the mortality of birds in inshore areas, the
SG80 requirements could be met. A condition has been generated to address this issue.
Condition
Information should be gathered to allow fishery related mortality of bird species and the
impact of fishing on these species to be quantitatively estimated for the hake trawl
fishery in inshore areas (waters shallower than 110m).
This could be achieved by continued implementation of the recently established bird
observer programme for inshore areas and analysis of observer data so that bird
mortality and trends in mortality can be quantified.
Relationship to
previous conditions
Milestones
There is already a SADSTIA-funded bird observer programme in place. Meeting this
condition will require ongoing implementation of this programme and analysis of
findings. The anticipated milestones are set out below:-
Year 1: Evidence of continued implementation of bird observer programme and
preliminary analysis of findings.
Likely resulting SI Score: 60
Year 2: Evidence of continued implementation of bird observer programme and further
analysis of findings.
Likely resulting SI Score: 60
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Year 3-4: Evidence of continued implementation of bird observer programme and
reporting of findings to show that bird mortality and impact on bird species can be
quantitatively estimated.
Likely resulting SI Score: 80
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14.2.2 Condition 5: Habitat impact management
Performance
Indicator 2.3.2
Score
70
Scoring Issue(s) scoring less than 80
SIb SG60 SG80 SG100
The measures are
considered likely to work,
based on plausible
argument (e.g. general
experience, theory or
comparison with similar
fisheries/habitats).
There is some objective
basis for confidence that
the partial strategy will
work, based on information
directly about the fishery
and/or habitats involved.
Testing supports high
confidence that the strategy
will work, based on
information directly about
the fishery and/or habitats
involved.
Y N N
Rationale
Information about the fishery shows that the type of fishing gear that can be used is
constrained by fishing licence conditions; fishing effort is limited by quotas and days at
sea; and the areas that can be fished are fixed (by the fishing industry) to the boundary
of the trawl footprint established in 2007. Thus there is a partial strategy in place that
constrains potential fishery impacts on marine habitats.
Information is available about the extent, distribution and sensitivities of marine
habitats. This information from the fishery shows that there has been fishing activity in
and around these habitat types for several decades. Independent information has also
been presented by DAFF to confirm that compliance with both the statutory controls
(gear type and effort) and also the trawl footprint by the trawl fishery has been very
good. There is thus a plausible argument that these management measures will work
(based on past experience and the “freezing” of habitat impacts). This meets the
requirements of SG60.
Although there is some objective basis for confidence that these measures will constrain
fishing impacts, there are concerns that the extent of the existing MPA network is not
adequate to provide targeted protection to specific offshore habitats that are within the
existing trawl footprint area. The limitations in the management regime in this respect
means that the SG80 requirements for this SI are not presently met.
This shortcoming in the management regime could be addressed by investigating and
confirming the need for establishing further measures to manage trawl fishery impacts
on benthic marine habitats within the existing trawl footprint area (and indeed whether
there is evidence that these would be effective – which will be demonstrated by the
trawl impact study already underway). A condition has been generated to address this
issue.
Condition
There should be further investigation of the options for protecting benthic habitats from
hake trawl fishery impacts. This investigation could consider, inter alia, the relative
merits of both statutory measures and self regulation and also the areas that may require
or might benefit from such measures (for instance the South Benguela Canyon). It is
noted that much of the groundwork for this aspect of the condition has been done.
Having identified appropriate measures and areas for action, evidence of progress with
the implementation of the favoured management measures would be required.
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It is anticipated that the information derived from the trawl experiment will provide
information from the hake trawl fishery on the type of management measures that may
be appropriate.
Relationship to
previous conditions
This condition builds on the previous condition of certification that required information
on trawl fishery impacts to be gathered. The information from the ongoing work on that
condition will be vital to inform work on this condition.
Milestones
A considerable amount of work has been carried out to establish a procedure to identify
“habitats of concern” based on their vulnerability to impacts from the trawl fishery (see
Sink et al, 2012).
The milestones set out below seek to build on that work to improve the performance of
the fishery against this SI.
The anticipated milestones are set out below:-
Year 1: Further evaluation of management options for “habitats of concern” within the
trawl footprint area.
Likely resulting SI Score: 60
Years 2-4: Evidence of implementation of appropriate management measures designed
to protect “habitats of concern” within the trawl footprint area, and evidence of fleet
compliance with the management regime.
Likely resulting SI Score: 80
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15 CLIENT ACTION PLAN
Client Action Plan
Action Plan for Meeting Conditions for Continued Certification of the South African Hake
Trawl Fisheries
The South African Demersal Trawling Industry submits this Action Plan for meeting the
Conditions for continued certification of the two Units of Certification (UoC) of the South
African Hake Trawl Fisheries, M. paradoxus (UoC1) and M. capensis (UoC2). The
Recognised Industrial Bodies involved, the South African Deep-Sea Trawling Industry
Association (SADSTIA) and the South-East Coast Inshore Fishing Association (SECIFA),
undertake to implement the spirit and intent of the Conditions as set out in the Certifiers Final
Report determining that South African hake trawl fisheries are being sustainably managed
under the MSC Principles and Criteria.
SADSTIA and SECIFA accept the conditions and will work with both its partners and with
recognised stakeholders to fulfil them. Some Conditions call on SADSTIA and SECIFA to
take on responsibilities that fall outside their full control. SADSTIA and SECIFA have
sought and been given assurances of cooperation and support from their partners. The Clients
will use the resources at their command to ensure that all Actions undertaken in connection
with these Conditions are fully met. We trust that surveillance agencies will take account of
our limitations regarding actions that require a level of commitment from autonomous
partners.
Some of the Conditions and Actions are quite closely interlinked. The Actions we propose
under one heading may go some way in meeting the obligations attached to another
Condition or Action, particularly when the required actions are the same when applied across
the two species (UoC) for two of the Conditions below (i.e. Condition 2 and 4 and Condition
3 and 5 require the same actions for the two species. It should be noted also that limited
resources, both financial and human, may sometimes prevent the Trawling Industry, and/or
government, from directly addressing a Condition, thereby necessitating the parties to seek
the most appropriate alternative approach to fulfilling a requirement. We trust that both these
factors will be recognised in the course of this certification period.
Below we comment broadly on the five Conditions in order to position our proposed Actions
within a framework of our experience and the many lessons learnt during the previous
certification periods. The Trawling Industry continues to take, or has been an active co-
management party to, a number of pre-emptive measures that favourably inform the new
Conditions. We think this fact is eloquent testimony to the enlightening and galvanizing
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effect of MSC Certification. These processes have raised the client’s level of understanding
regarding the benefits of pursuing pre-emptive conservation action. They have also increased
the trawling industry’s preparedness to undertake voluntary measures to maintain the
sustainable use of fishery resources into the future.
UoC1: M. paradoxus
Condition 1. Stock Status
Action required: Evidence of ongoing implementation of the stock rebuilding strategy is
required.
Timescale: The OMP2014 has projected the likely recovery of the stock over the period
2015-2030.
Indices for rebuilding should show improvement of M paradoxus stock status within the
bounds of the current rebuilding projection as identified during annual and bi-annual reviews
of the stock status. Overall rebuilding should progress in line with the overall timeframe for
stock recovery as currently defined.
COMMENT:
The current Hake Operational Management Procedure (OMP2014) deals directly with
matters addressed in Condition 1. An OMP typically lasts for four years implying that the
expected life of the next OMP will coincide with Certification itself. The stock assessment
model for the resource comprises a reference set of 11 specific stock assessments which
reflect a range of assumptions and uncertainty about the dynamics of the resource. The figure
below is an uncertainty envelope for those 11 assessment models with respect to the target
level quantity Bsp
/ MSYLsp
for Merluccius paradoxus. The colours denote the 80, 90 and
95% confidence intervals for this quantity. The solid dark line is the median estimate. This
figure demonstrates that by 2012/2013 the resource had achieved its target level in median
terms (the mean would have reached the target), and that the 90% uncertainty envelope at
that time ranged between about 65% of the target and 164% of the target. The resource
dynamics therefore entered the definition of a resource fluctuating around its target level.
This figure shows that there are some recruitment variability effects which are predicted to
cause a downward fluctuation in the dynamics of the resource, reaching a nadir of between
51% and 106% of the target by 2017. Thereafter the resource continues to grow along a
recovery pathway and achieves a median level of 6% above the MSYL target again by 2024
with a 90% confidence range of between 64% and 196% of target. Although not shown here,
the long term strategy translates to M. paradoxus achieving a median level of 119% of
MSYL target by 2034.
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In summary therefore, the resource attained the MSYL target in median terms in 2012/2013,
thereafter it fluctuates about its target, with a long-term strategy of reaching 19% above
target by 2034.
CONDITION 1 - ACTION 1
Stock assessment modelling:
The reference case stock assessment model will be updated annually with the inclusion of the
most recent CPUE and survey data. As part of this process, the spawning biomass trend will
be updated annually using the current stock assessment model which integrates all indices of
resource abundance. Each year a check will be carried out to determine whether the most
recent CPUE and survey based abundance indices lie within the range of the October 2014
rebuilding projections. This determination will be made both for M. paradoxus and for M.
capensis. If abundance indices are outside the 95% probability range, then exceptional
circumstances will be triggered in terms of the OMP rules and the management procedure for
the resource will be reconsidered to ensure continued long-term sustainable use. If the risk is
to the resource, then in the short term management action will involve a more conservative
TAC than would have arisen from the application of the OMP formula. In the medium term
the OMP may have to be revised as recommended by the Demersal Scientific Working
Group of DAFF. Action in short and medium term is to ensure that the resource status levels
are reached on the timeframe specified in 2014 when the current OMP was adopted. This
procedure, which was Appendix D of the attached document
FISHERIES/2010/OCTOBER/SWG-DEM/59 in the context of the 2011 – 2014 OMP has
been adopted for the 2015 – 2018 OMP. (The current version will be sent to the Certifiers as
soon as it has been officially approved by DAFF.)
Safeguard Rule: A “Safeguard Rule” has been enacted for the hake resource. This allows
for more severe reductions in the TAC than are possible under “normal conditions”. Under
normal conditions, TAC reductions may not exceed 5%. However, should the composite
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index of resource abundance, J, fall below 75% of its 2011 level, then TAC reductions
greater than 5% are permissible. The permissible percentage increases on a sliding scale from
5% at the 75% J level (of the composite abundance index relative to 2011) to 25% at the 65%
J level. The maximum permissible TAC reduction that is contemplated in any one year is
25%.
TIMING – This Action will be an ongoing process under regular annual review, and the
responsibility lies with DAFF and the DSWG.
CONDITION 1 - ACTION 2
Estimating Inter- and Intra-specific Predation:
Estimation of the current level of depletion of the M. paradoxus resource remains an area of
active research. In 2012 SADSTIA submitted the results of a study attached hereto,
“Updating the baseline hake stock assessment which incorporates inter- and intra-specific
hake predation into hake stock assessments” authored by OLRAC SPS. At the time that
work was seen as closing out a client action plan related to research into the stock assessment
implications of inter- and intra-specific hake predation. A recent international review panel
(held UCT, December 2014) has recommended as follows in relation to ongoing work in this
regard by a PhD student at UCT:
“The Panel was impressed with the progress made on developing an assessment method that
can take into account both cannibalism between the two hake species and inter-specific
predation. This line of work holds as much if not even more promise than the movement
model in terms of representing hake dynamics, because its results may change perceptions of
stock trajectories for the two hake species - in particular that for M. paradoxus, which is
subject to predation by M. capensis as well as cannibalism. The Panel looks forward to
completion of this work.”
Both OLRAC SPS’s earlier work as well as that submitted to the December 2014
international review workshop by UCT indicates a more optimistic appraisal of the depletion
status of M. paradoxus. SADSTIA will therefore sponsor OLRAC SPS to carry out a further
research project aimed at verifying and improving the methodology for determining the
pristine biomass of M. paradoxus relative to K and MSYL in the context of assessment
methodologies that explicitly incorporate inter- and intra-specific hake predation into hake
stock assessments. The duration for this work will be three years, and this work should be
seen as complementary to the work done by other researchers at UCT. OLRAC SPS’s work
will focus more directly and immediately on the management implications of this new breed
of stock assessment models. This work will build on the earlier work by OLRAC, and will
incorporate new dietary and daily ration information, as well as looking into the
disaggregation of dietary characteristics between the south and west coasts.
TIMING – SADSTIA will submit three research progress reports, in November 2015 (data
and methodological summary), November 2016 (preliminary results) and November 2017
(final report). The project will be completed by November 2017.
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CONDITION 1 - ACTION 3
Species splitting for hake in demersal trawl:
The formula used to split hake catches into the two species Merluccius paradoxus and
Merluccius capensis in the commercial trawl fishery was further developed by OLRAC SPS
in 2004 using scientific survey trawl data. The methodology has undergone successive
revisions over the years and forms the backbone of the species disaggregated stock
assessment methodology employed in the management of the fishery. In 2006, SADSTIA
commissioned an observer programme with the objective of, inter alia, collecting hake
species split information. Since then OLRAC SPS has been engaged on an ongoing basis to
compare the models based on survey and observer data, and to refine and improve the species
splitting models.
TIMING - This work will continue on an annual basis and results will be reported according
to the following milestones:
2015 (November): Submission of model refinements, options and preliminary results.
2016 (November): Submission of preferred feasible models and results.
2017 (November): Submission of comprehensive results.
UoC1 – M. paradoxus
Condition 2. ETP Species information
Action required: Information should be gathered to allow fishery related mortality of bird
species and the impact of fishing on these species to be quantitatively estimated for the hake
trawl fishery in inshore areas (waters shallower than 110m). This could be achieved by
continued implementation of the recently established bird observer programme for inshore
areas and analysis of observer data so that bird mortality and trends in mortality can be
quantified.
Timescale:
Year 1: Evidence of continued implementation of bird observer programme and preliminary
analysis of findings.
Year 2: Evidence of continued implementation of bird observer programme and further
analysis of findings.
Year 3-4: Evidence of continued implementation of bird observer programme and reporting
of findings to show that bird mortality and impact on bird species can be quantitatively
estimated
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.
COMMENT:
We believe that this condition primarily applies to M. capensis (UoC2) in inshore areas, since
very little M. paradoxus is caught in waters shallower than 110m. We agree that, especially
in the case of M. capensis, it is necessary to gather further information on bird mortality and
impact on bird species.
CONDITION 2 – ACTION 1
Determine the extent of bird mortality in the inshore fleet:
We will be able to determine the extent of bird mortality and impacts on birds in the inshore
sector by i) Doing a desktop study of all available data on bird mortality in the inshore fleet
and ii) implementation of an on-board observer programme on those inshore vessels
equipped to carry an observer.
TIMING – Year 1: The desktop study to be completed and on-board observer programme
commenced.
Year 2: An assessment will be made of existing bird mortality in the inshore fleet using data
collected in year 1 and ongoing observer programme if sufficient data is available; if not, the
observer programme will be continued until sufficient data has been collected to make a
proper assessment of bird mortalities.
CONDITION 2 – ACTION 2
Deployment of bird scaring devices in the inshore fleet:
We should be able to reduce bird mortality and impacts on birds in the inshore sector by
implementation of suitable bird scaring devices similar to those deployed in the offshore
sector, adapted to allow for the smaller-sized vessels
TIMING – Year 1- modifications to be made to bird scaring devices used in the offshore
sector to make them suitable for use on the smaller vessels and testing these.
Year 2-3: As soon as the assessment referred to in Action has been completed all vessels to
be equipped with bird scaring devices and inshore observer programme established on
vessels suitably equipped to carry observers in the inshore trawling sector.
CONDITION 2 – ACTION 3
Assessment of the impact of bird-scaring devices:
Analysis of observer data to quantitatively determine whether the bird-scaring devices
utilized in the inshore sector are having a mitigating impact in terms of reducing bird
mortality and to allow trends in bird mortality to be tracked and monitored.
TIMING – Year 2-4: Annual data analysis and summaries published and communicated.
CONDITION 2 – ACTION 4
Monitoring and review of impact of bird mitigation measures:
Interaction and discussion on the implementation of mitigation of impacts on birds and trends
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in bird mortality with all relevant ETP stakeholders, including Capfish and Birdlife
TIMING – Annual review meeting will be held with stakeholders to discuss issues.
Corrective measures will be applied if agreed to be necessary.
UoC1: M. paradoxus
Condition 3. Benthic Habitat impact management
Action Required: There should be further investigation of the options for protecting benthic
habitats from hake trawl fishery impacts. This investigation could consider, inter alia, the
relative merits of both statutory measures and self-regulation and also the areas that may
require or might benefit from such measures.
It is noted that much of the groundwork for this aspect of the condition has been done.
Having identified appropriate measures and areas for action, evidence of progress with the
implementation of the favoured management measures would be required.
It is anticipated that the information derived from the trawl experiment will provide
information from the hake trawl fishery on the type of management measures that may be
appropriate.
Timescale:
Year 1: Further evaluation of management options for ‘habitats of concern’ within the trawl
footprint area, and evidence of fleet compliance with the management regime.
Year 2-4: Evidence of implementation of appropriate management measures designed to
protect “habitats of concern” within the trawl footprint area, and evidence of fleet compliance
with the management regime.
COMMENT:
We understand that notwithstanding the work conducted during the current Certification
there remain gaps in knowledge about the intensity of disturbance and potential recovery
rates to pristine level of habitually trawled bottom.
In the previous certification period, this very expensive work was sporadically and
opportunistically carried out via academic programmes, and a PhD was completed on the
subject by Lara Atkinson. A trawl experiment to determine benthic impacts, using a
sophisticated camera monitoring system is now well underway, using DAFF’s 45m research
vessel Ellen Kuzwayo in the Child’s Bank grid area designated for the experiment. In the
experimental grid there are trawled lanes and untrawled sections for comparison and
monitoring of recovery of benthic organisms over a period of 5 years. DAFF has fortunately
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committed the vessel for the full period of 5 years. One full survey was carried out during
2014 and the data from the survey has been analysed. The next survey is scheduled for March
2015. Role players in this project include DAFF, SADSTIA, SANBI, UCT and SAEON.
With previous resource limitations in mind and with the realisation that environmental
impacts need to be limited in the interests of an ecosystem approach to fisheries (EAF) the
South African Trawling Industry has since 2009 implemented a “ring fencing” initiative
which has fixed the footprint of the South African Trawling Industry for some time to come,
thus addressing the issue of future trawl areas. This has been maintained throughout the
current recertification period. The activities of all trawlers inside and outside the trawl
footprint are monitored and transgressions reported to SADSTIA for action, so that
compliance is enforced.
SADSTIA has been engaging in the process of development of a system of offshore MPAs
since its inception, since it has always been likely that some ecologically sensitive areas
would overlap with the currently designated trawl footprint. The key roleplayers and
stakeholders are DEA, DAFF, DMR, SANBI, UCT and SAEON, SADSTIA and the oil and
gas industry. A recent presidential initiative to develop South Africa’s maritime economic
potential (Operation Phakisa) has spurred the formalization of this process. Stakeholders are
expected to rapidly find consensus on the location and size of MPAs designed to protect
critical marine benthic habitats.
CONDITION 3 - ACTION 1
Benthic impacts trawl experiment:
SADSTIA will continue to participate in and support research related to the benthic impacts
trawl experiment. This includes support for UCT and other researchers to participate in the
annual RV Ellen Kuzwayo research survey and to analyse the camera data from the survey, as
well as possible direct participation in the surveys. Note that this work is dependent on
continued availability of the research vessel and of the SAEON camera sled equipment.
TIMING – Annual surveys to be continued from 2015-2018. Data to be analysed annually to
determine the nature and extent of any damage to the benthic environment caused by trawling
and any recovery thereafter, collated and summarised and outcomes to be reported by mid-
2019.
CONDITION 3 - ACTION 2
Incorporation of trawl ring-fenced trawl grounds in permit conditions:
The existing industry programme to monitor compliance with Ring Fencing will be
continued. A formal request has been made to the DAFF’s Demersal Scientific Working
Group to include in its annual TAC recommendations to the Minister that the area designated
as the trawl footprint be incorporated in the 2015 Permit Conditions. SADSTIA undertakes to
further monitor compliance with the new permit conditions via the Ring-fencing initiative.
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TIMING –
Year 1: Implementation of permit conditions to prohibit trawling outside of the designated
footprint and ring-fenced area by 1 January 2015.
Year 1-4: Monitoring of compliance with permit conditions throughout the period of
certification.
CONDITION 3 – ACTION 3
Development of management actions to address critical marine benthic habitats:
Action 3 has strong links with Actions 1 (the trawl experiment) and 2 (Ring-fencing the trawl
grounds). SADSTIA will continue to engage with all role players on the development and
implementation of a system of offshore MPAs that protects critical marine habitats. We know
that identifying such areas and agreeing on these among stakeholders present many
challenges. We will endeavour to address these challenges by engaging with all parties
constructively to find mutually acceptable solutions that satisfy the need for protection of
critical marine benthic habitats while ensuring that the trawling industry is not heavily
impacted economically. Implementation of these offshore MPAs is, however, ultimately in
the hands of the Department of Environmental Affairs (DEA) and the Department of
Agriculture Forestry and Fisheries (DAFF).
TIMING - Progress with this action depends very much on the other role players in
Operation Phakisa, and SADSTIA is therefore not in control of it. The ultimate objectives,
outcomes and impacts of oil and gas industry developments and the Department of Mineral
Resources remain uncertain. We would, however, hope that the process can proceed as
follows:
Year 1: Engagement with all role players to finalise the proposed offshore MPAs.
Year 2-4: Proclamation and implementation of offshore MPAs to protect and conserve
critical habitats (DEA and DAFF).
UoC2 – M. capensis
Condition 4: ETP species information
Action required: Information should be gathered to allow fishery related mortality of bird
species and the impact of fishing on these species to be quantitatively estimated for the hake
trawl fishery in inshore areas (waters shallower than 110m). This could be achieved by
continued implementation of the recently established bird observer programme for inshore
areas and analysis of observer data so that bird mortality and trends in mortality can be
quantified.
Timescale:
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Year 1: Evidence of continued implementation of bird observer programme and preliminary
analysis of findings.
Year 2: Evidence of continued implementation of bird observer programme and further
analysis of findings.
Year 3-4: Evidence of continued implementation of bird observer programme and reporting
of findings to show that bird mortality and impact on bird species can be quantitatively
estimated
COMMENT:
We agree that it is necessary to gather further information on bird mortality and impacts on
bird species in the inshore area where mostly M. capensis is caught.
CONDITION 4 – ACTION 1
Determine the extent of bird mortality in the inshore fleet:
We will be able to determine the extent of bird mortality and impacts on birds in the inshore
sector by i) Doing a desktop study of all available data on bird mortality in the inshore fleet
and ii) implementation of an on-board observer programme on those inshore vessels
equipped to carry an observer.
TIMING – Year 1: The desktop study to be completed and on-board observer programme
commenced.
Year 2: An assessment will be made of existing bird mortality in the inshore fleet using data
collected in year 1 and ongoing observer programme if sufficient data is available; if not, the
observer programme will be continued until sufficient data has been collected to make a
proper assessment of bird mortalities.
CONDITION 4 – ACTION 2
Deployment of bird scaring devices in the inshore fleet:
We should be able to reduce bird mortality and impacts on birds in the inshore sector by
implementation of suitable bird scaring devices similar to those deployed in the offshore
sector, adapted to allow for the smaller-sized vessels.
TIMING – Year 1- modifications to be made to bird scaring devices used in the offshore
sector to make them suitable for use on the smaller vessels and testing same.
Year 2-3: As soon as the assessment referred to in Action has been completed all vessels to
be equipped with bird scaring devices and inshore observer programme established on
vessels suitably equipped to carry observers in the inshore trawling sector.
CONDITION 4 – ACTION 3
Assessment of the impact of bird-scaring devices:
Analysis of observer data to quantitatively determine whether the bird-scaring devices
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utilized in the inshore sector are having a mitigating impact in terms of reducing bird
mortality and to allow trends in bird mortality to be tracked and monitored.
TIMING – Year 2-4: Annual data analysis and summaries published and communicated.
CONDITION 4 – ACTION 4
Monitoring and review of impact of bird mitigation measures:
Interaction and discussion on the implementation of mitigation of impacts on birds and trends
in bird mortality with all relevant ETP stakeholders, including Capfish and Birdlife
TIMING – Annual review meeting will be held with stakeholders to discuss issues.
Corrective measures will be applied if agreed to be necessary.
UoC1: M. capensis
Condition 5. Benthic Habitat impact management
Action Required: There should be further investigation of the options for protecting benthic
habitats from hake trawl fishery impacts. This investigation could consider, inter alia, the
relative merits of both statutory measures and self-regulation and also the areas that may
require or might benefit from such measures (for instance the South Benguela Canyon).
It is noted that much of the groundwork for this aspect of the condition has been done.
Having identified appropriate measures and areas for action, evidence of progress with the
implementation of the favoured management measures would be required.
It is anticipated that the information derived from the trawl experiment will provide
information from the hake trawl fishery on the type of management measures that may be
appropriate.
Timescale:
Year 1: Further evaluation of management options for ‘habitats of concern’ within the trawl
footprint area, and evidence of fleet compliance with the management regime.
Year 2-4: Evidence of implementation of appropriate management measures designed to
protect “habitats of concern” within the trawl footprint area, and evidence of fleet compliance
with the management regime.
COMMENT:
We understand that notwithstanding the work conducted during the current Certification
there remain gaps in knowledge about the intensity of disturbance and potential recovery
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rates to pristine level of habitually trawled bottom.
In the previous certification period, this very expensive work was sporadically and
opportunistically carried out via academic programmes, and a PhD was completed on the
subject by Lara Atkinson. A trawl experiment using a sophisticated camera sled monitoring
system is now well underway, using DAFF’s 45m research vessel MV Ellen Kuzwayo in the
Child’s Bank grid area designated for the experiment, which includes trawled lanes and
untrawled sections for comparison and monitoring of recovery of benthic organisms over a
period of 5 years. DAFF has fortunately committed the vessel for the full period of 5 years.
One full survey was carried out during 2014 and the data from the survey has been analysed.
The next survey is scheduled for March 2015. Role players in this project include DAFF,
SADSTIA, SANBI, UCT and SAEON.
With previous resource limitations in mind and with the realisation that environmental
impacts need to be limited in the interests of an ecosystem approach to fisheries (EAF) the
South African Trawling Industry has since 2009 implemented a “ring fencing” initiative
which has fixed the footprint of the South African Trawling Industry for some time to come,
thus addressing the issue of future trawl areas. The activities of all trawlers inside and outside
the trawl footprint are monitored and transgressions reported to SADSTIA for action, so that
compliance is enforced.
SADSTIA has been engaging in the process of development of a system of offshore MPAs
since its inception, since it has always been likely that some ecologically sensitive areas
would overlap with the currently designated trawl footprint. The key stakeholders and role
players are DEA, DAFF, DMR, SANBI, UCT and SAEON, SADSTIA and the oil and gas
industry. A recent presidential initiative to develop South Africa’s maritime economic
potential (Operation Phakisa) has spurred the formalization of this process.
CONDITION 5 - ACTION 1
Benthic impacts trawl experiment:
SADSTIA will continue to participate in and support research related to the benthic impacts
trawl experiment. This includes support for UCT and other researchers to participate in the
annual RV Ellen Kuzwayo research survey and to analyse the camera data from the survey, as
well as possible direct participation in the surveys. Note that this work is dependent on
continued availability of the research vessel and of the SAEON camera sled equipment.
TIMING – Annual surveys to be continued from 2015-2018. Data to be analysed annually to
determine the nature and extent of any damage to the benthic environment caused by trawling
and any recovery thereafter, collated and summarised and outcomes to be reported by mid-
2019.
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CONDITION 5 - ACTION 2
Incorporation of trawl ring-fenced trawl grounds in permit conditions:
The existing industry programme to monitor compliance with Ring Fencing will be
continued. A formal request has been made to the DAFF’s Demersal Scientific Working
Group to include in its annual TAC recommendations to the Minister that the area designated
as the trawl footprint be incorporated in the 2015 Permit Conditions. SADSTIA undertakes to
further monitor compliance with the new permit conditions via the Ring-fencing initiative.
TIMING –
Year 1: Implementation of permit conditions to prohibit trawling outside of the designated
footprint and ring-fenced area by 1 January 2015.
Year 1-4: Monitoring of compliance with permit conditions throughout the period of
certification.
CONDITION 5 – ACTION 3
Development of management actions to address critical marine benthic habitats:
Action 3 has strong links with Actions 1 (the trawl experiment) and 2 (Ring-fencing the trawl
grounds). SADSTIA will continue to engage with all role players on the development and
implementation of a system of offshore MPAs that protects critical marine habitats. We know
that identifying such areas and agreeing among stakeholders present many challenges. We
will endeavour to address these challenges by engaging with all parties constructively to find
mutually acceptable solutions that satisfy the need for protection of critical marine benthic
habitats while ensuring that the trawling industry is not heavily impacted economically.
Implementation of these offshore MPAs is, however, ultimately in the hands of the
Department of Environmental Affairs (DEA) and the Department of Agriculture Forestry and
Fisheries (DAFF).
TIMING - Progress with this action depends very much on the other role players in
Operation Phakisa, and SADSTIA is therefore not in control of it. The ultimate objectives,
outcomes and impacts of oil and gas industry developments and the Department of Mineral
Resources remain uncertain. We would, however, hope that the process can proceed as
follows:
Year 1: Engagement with all role players to finalise the proposed offshore MPAs.
Year 2-4: Proclamation and implementation of offshore MPAs to protect and conserve
critical habitats (DEA and DAFF).
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16 PEER REVIEW REPORTS
16.1 Peer Review Reports
16.1.1 Peer Reviewer A
Overall Opinion
Has the assessment team arrived at an
appropriate conclusion based on the evidence
presented in the assessment report?
Yes Conformity Assessment Body
Response
Justification:
This is a complex fishery, consisting of two species that are
not easily distinguishable and certainly not capable of being
separated out in commercial catch data, two organizations
representing the various operators, and two geographic areas,
although the latter are no longer considered as individual
stocks in the assessment. The background material and its
evidence is presented in a fair manner, but it is still difficult for
a reviewer to get his head around the species and “stock”
differences, even though in this case I do have some (very
dated) background relating to the fishery.
The evidence is presented in voluminous and comprehensive
fashion, and there is sufficient to substantiate the scorings
given. I do have a (presentational) problem with some (not all)
of the justifications in the scoring sections, however, because
a few are presented in too much of a bullet-point fashion, just
throwing the various evidence at the reader rather than
building the justifications in a contiguous manner that leads to
a clear conclusion based on the most important and MSC-
required criteria.
We agree that this is a complex fishery;
we have presented the information in as
clear a manner as possible.
Comment noted; we have responded to
the reviewer’s comments on the scoring
of individual PIs in response to this.
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If included:
Do you think the client action plan is sufficient
to close the conditions raised?
Yes Conformity Assessment Body
Response
Justification:
After ten years of being certified, this fishery and its two client
organizations are used to meeting MSC certification conditions
in an exemplary manner. The Action Plan provided is in my
opinion adequate and, although Condition 1 is aimed at
achieving targeted rebuilding of the M. paradoxus stock so
requires evidence to that end being assimilated (which will be
difficult if the UoC stock does not recover as planned), I am
confident that the will of the clients to close all five conditions
is strong. Hence, I believe that all five conditions will be closed
out within the timeframes specified.
Comment noted, no action required.
General Comments on the Assessment Report (optional)
Do you think the condition(s) raised are
appropriately written to achieve the SG80
outcome within the specified timeframe?
Yes Conformity Assessment Body
Response
Justification:
For such a long-certified fishery (the third time it is being
considered), it is quite surprising to this reviewer that
conditions are still being unearthed that need to be met during
the term of the certification. However, apart from the fact that
MSC criteria are being tightened all the time, it is clear from
the various documentation referred to that scientifically and
administratively, this fishery is one of the best researched and
managed in the world outside the dominant North Atlantic
fisheries, where marine research and good management
practice initially developed. It is also clear that the authorities
and the local (and international) scientists associated with the
various facets of the SA hake trawl fishery are committed to it
remaining at the forefront of good scientific and management
practice, and the assessment team this time (with some
different members from previous assessment teams and
surveillance auditors) have picked this fact up. Hence, the
conditions set now are fair and in my opinion given the
documentation in front of me, they can be met within the
timeframe set. There are actually five listed, but only
Condition 1 is unique to a single UoC (Merluccius paradoxus).
Conditions 2 and 3 are mirror images of Conditions 4 and 5,
each pairing covering one of the UoCs (M. paradoxus and M.
capensis). Therefore, there are realistically only three
conditions needing to be met; the way the two sets of paired
conditions are to be met is similar for each UoC.
Comment noted. No action required.
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I strongly urge the assessment team to give serious and dedicated attention to finally submitting a
report of high quality in terms of its continuity (within sections and obviously also within scoring
justifications) and even grammar and spelling. I tired of circling minor errors or of wondering why
comments clearly meant as reminders to the drafter(s) were still contained in this report. Everything
that needs to be in the report is there, but quality needs to be enhanced during the team response
period.
Notwithstanding the above comment, I find the report to be a good one.
IFC Response: these comments are welcomed. We have addressed grammar and spelling mistakes
in the report as part of the review process.
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Performance Indicator Review
Please complete the table below for each Performance Indicator which are listed in the Conformity Assessment Body’s Public Certification Draft
Report.
Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
1.1.1 Yes Yes Maybe for UoC 1, n/a for UoC 2
For UoC 1 (M. paradoxus), the certifying team correctly point out that all scientific evidence points to a high degree of certainty that the stock is not at a point where recruitment can be impaired, but that the stock size has not in recent years been above or fluctuating around the target B reference point. Although the stock is not far beneath that reference point, the inability to score 1.1.1b at all is therefore obvious, and the overall performance score for UoC 1 is therefore correct and a condition has been raised. That condition, however, is merely to provide some evidence of the efficacy of the effectiveness of the rebuilding strategy; in my opinion, proof of the effectiveness of the strategy can only come in a longer time, perhaps even when the target reference point is reached. Perhaps this point can be emphasized?
The assessment team has found that
there is a stock rebuilding strategy in
place for M. paradoxus and that it is
effective (PI 1.1.3 scores 90).
Therefore, the condition is continued
implementation of the rebuilding
strategy within the OMP, which has
projected that the M. paradoxus stock
to will reach its target reference point
before 2020 (i.e. within the five year
period of certification). This will be
monitored annually by MARAM, and
provides an independent basis for
evaluating progress.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
For UoC 2, the scoring is correctly at 100.
1.1.2 Yes Yes n/a The rigour of the assessment model is tested and proven, and I am comfortable that the background information in the report and the scoring reflect correctly on the status of the stock in terms of both UoCs
Comment noted. No action required.
1.1.3 Yes Yes n/a UoC 2 does not require any rebuilding, as shown clearly by the assessment modelling (1.1.1 above), so does not need to be scored here. UoC 1 is hampered by the decision that socio-economic reasoning makes it impracticable to rebuild the stock in the required 2 × generation time. It is notable from the text provided that some of the scientists interviewed during the site visit believe that recovery may be more rapid than predicted, but actual proof is still lacking, so the score of 80 for 1.1.3b is supported, as is the overall score.
We did not intend to imply that there
was a decision not to effect a recovery
of M. paradoxus biomass to BMSY
within a ten year period for socio-
economic reasons, but that this was a
possibility given way that the OMP is
designed to balance the returns to the
fishery (catch) against the perceived
risks to the stock (of fishing). In the
event, the current OMP is expected to
achieve this objective within the 5-
year certification period.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
1.2.1 Yes Yes n/a For both UoCs, evidence and moreover gutfeel is that the harvest strategy (which must be one of the most tested in fisheries assessment history!) is both precautionary and robust. It only “fails” in proving that the stocks will be maintained at the target levels. The assessment team are clearly hedging their bets, but the overall score is supported.
Comment noted. No action required.
1.2.2 Yes Yes n/a The report (and scoring table) provides ample evidence that the harvest control rules in place are both (extremely) well-defined and effective. What is particularly gratifying here is the extent of fishery buy-in and support for those HCRs; they have clearly been fully consulted, understand the rules and what they are trying to achieve for the fishery. Scoring supported.
Comment noted. No action required.
1.2.3 Yes Yes n/a So much is already known (and regularly checked and confirmed) about the two UoCs that it would be impossible to score this PI at anything other than 100%. Careful and robust analysis is the hallmark of this fishery
An appropriate comment has been
added to the justification for 1.2.3a in
relation to age determination.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
and its historical development. I only have one concern here, namely about the information used, but that does not change my perception of the accuracy of the evaluation result – age/length keys are reliant on a single trained otolith reader, who is not consistent throughout the time-series (a dangerous situation for any fishery!) and the material is aggregated over each year, not analysed spatially or temporally. A comment on why such a situation does not affect the efficacy of the harvest strategy being applied would be useful.
1.2.4 Yes Yes n/a Perhaps my inside knowledge of the development of the numerical assessment methodology makes me a bit cynical about the team’s assertion that other assessment approaches (e.g. an age-structured VPA) have not been attempted in the in the OMP. However, given the voluminous information provided in this report and perhaps the slight uncertainty about the stock status of UoC 1, the cautionary scoring is supported.
Comment noted. No action required.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
FROM HERE ON, UoCs 1 AND 2 ARE CONSIDERED TOGETHER
2.1.1 Yes Yes n/a I note the slightly different definitions of retained and bycaught species in South Africa from those generally accepted internationally, and applaud the assessment team for providing that background information in their report. It makes the reviewers’ job much easier. I agree with the way they have drafted their report with this in mind. Given that target reference points have not been set in South Africa for any of the retained species, and that the levels of depletion of those species are not generally known with any degree of accuracy, the scoring of this PI at a and b cannot exceed 80, a score with which I agree.
Comment noted. No action required.
2.1.2 Yes Yes n/a Using MSC definitions for “measures”, “strategy” and “partial strategy”, the South African situation for retained species is in my opinion (and supported by the documentation produced) pretty good. The risk of serious or
Comment noted. No action required.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
irreversible harm accruing to other species does not seem to be very high. However, rigorous testing of the strategy is currently missing, so the overall score of 95 for this PI is fair.
2.1.3 Yes Yes n/a From what is presented, the level of available observations and firm statistics on catches supports the conclusion of the assessment team that the information behind the score for this PI warrants a pass at 80. I do have an issue, as does the team seemingly, with the ongoing level of independent observation effort (manifest in the responsible government agency not contracting this work into the future with any degree of certainty). However, from what is available in terms of observations made to present, I am comfortable with the score assigned – it is only the level of certainty regarding the outcome in terms of retained species that is questioned. Monitoring is good (currently), but it has to be noted that factual knowledge is somewhat lacking for some stocks of
Comment noted, no action required.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
retained species, unsurprising given the number of them caught.
2.2.1 Yes Yes n/a Again, the South African definition of bycatch varies slightly from the international norm, but the assessment team have covered that anomaly adequately in their report. Discarding in the fishery is anyway low, although it was apparentl;y not always so, meaning that adjustments to some catches presumably were made (?), but it is impossible to state from the information and statistics available that there is a high degree of certainty that all bycatch species are within biologically based limits; many species are by-caught! Therefore the score given of 80 is the maximum possible
Comment noted. No action required.
2.2.2 Yes Yes n/a The information provided correctly points out that at best there is a partial strategy in place designed to maintain bycatch species within biologically based limits. Therefore, no
Comment noted. No action required.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
scoring above 80 can be accepted, and I agree with the score given by the assessment team.
2.2.3 Yes Yes n/a Here I must I reiterate my cautionary comment (made also by the assessment team) that commitment to ongoing independent observer programmes is not that obvious locally at the government agency. The client organization is attempting to cover that issue, to good effect, but I am not sure that such action is the right (or moral) way forward for observation programmes. However, for now, the level of monitoring and the data collected and analysed are sufficient to be able to quantify catches, to support a partial strategy for managing main bycatch species and to be able to estimate outcome status for those species. The score of 85 is hence justified.
Comment noted. No action required.
2.3.1 Yes Yes n/a It is easy here to conclude that there are no Comment noted. No action required.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
ETP species related to the fishery, but seabird mortality and interaction has been notable over the years, so the team’s concentration on seabird interactions, including some species of seabird that are under threat globally (IUCN), is warranted. The team also rightly concludes that despite the amount of effort traditionally and recently being devoted to researching the interactions (South Africa has an impressive complement of seabird – and avians in general - research teams), and in mitigating any effects, one cannot with a high degree of confidence state that the fishery is having no detrimental direct or indirect effect on seabird species. A score of 80 is therefore the maximum possible, and is supported.
2.3.2 Yes Yes n/a In terms of the precautionary management strategy currently in place, there is general confidence that it is working and any effects of the fishery on seabirds are being mitigated. Also, the reducing-over-time observations of seabird strikes and
Comment noted. No action required.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
mortalities (with the implementation of amended technologies) demonstrate an improvement in the situation, so a score for this PI above 80 is fair.
2.3.3 Yes Yes Yes The team have concluded that information on ETP seabird interactions inshore is scarce enough to warrant a score for 2.3.3a of just 60. A carefully designed programme of observations will ameliorate this situation, so the condition set is a good one (and it applies to both UoC stocks, although inshore, the UoC 1 component is less relevant). There is an error in the report here. The final line of this PI refers to conditions 2 and 3; it should be 2 and 4, I believe.
Comments on scoring noted. We have
corrected the error concerning the
relevant conditions.
2.4.1 Yes Yes n/a Habitat effects (mainly negative) of bottom trawl fisheries are common and virtually unavoidable worldwide. The client has clearly understood this and invested heavily in improving understanding of the trawl
Comments noted. No action required.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
“footprint” and how it may be impacting on habitat generally. This effort is laudable, but it still does not allow scoring above 80 for this PI, and the (post-site-visit) widely advertised concern of stakeholders and scientists that the South African MPA network might be under threat from operators in other fisheries wishing to gain entrance to areas currently not being exploited generates even more confidence that the maximum score for this PI at the moment can only be 80.
2.4.2 Yes Yes Yes Formal operating license constraints particularly related to gear type mitigate against management totally eliminating the risk of habitat damage by trawling, so any score for this PI above 80 would be impossible for this fishery. The comment above about the recently advertised threat to the South African MPA network is also relevant here. Habitat impacts by trawl gear are virtually guaranteed, so a condition has to be raised to try to improve the situation during the period of certification. I agree with
Comments on scoring noted. We have
corrected the error concerning the
condition numbers that relate to this
PI.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
that requirement. Once again I think there is an error in the draft I have – I believe the final line of PI 2.4.2 should refer to Conditions 3 and 5, not just to 3.
2.4.3 Yes Yes n/a Relevant information is being and has been collected in the past, sufficient to support the score awarded of 85, but no more at this point in time.
Comment noted. No action required.
2.5.1 Yes Yes n/a Information collection and analysis over the years has been excellent, resulting in better-than-normal understanding of structure and function within the SA ecosystem within which the fishery operates. The score of 100 is totally supported by the information provided in the report.
Comment noted. No action required.
2.5.2 Yes Yes n/a With any trawl fishery it is impossible to guarantee that there will be absolutely no impact on ecosystem structure or function, but there are measures and a partial strategy
Comment noted. No action required.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
in place to mitigate any impact; the authors of the report highlight the main ones. The score of 90 is supported.
2.5.3 Yes Yes n/a As stated above, South Africa has been privileged to have been served over the years by some outstanding proponents of ecosystem research. The UoC fishery therefore benefits from this, and the understanding of the benthic and demersal parts of the ecosystem is such that a high score of 95 can be supported.
Comment noted. No action required.
3.1.1 Yes Yes n/a South African legislation has been produced to high international standards, many Acts being comparatively recent so having been able to be built on good international practice, and the report outlines the overall framework within which the legislation takes effect. Within South Africa, however, political questions are still being asked about the access rights of those traditionally dependent
Comment noted. No action required.
We note the comment about access
rights of those traditionally dependent
on fishing for their livelihood. This is
addressed in our comments under SId,
where we note that the nature of the
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
upon the fishery for their livelihood (the second bullet of 3.1.1). Such questions are political and based upon historical national decisions, however, and should not affect the scoring of the team as 100 for this PI.
hake fishery is that it has only been
prosecuted since the advent of
mechanised trawlers capable of fishing
in the deep waters inhabited by the
hake species. There was no traditional
or artisanal hake fishery in the deep
water before this.
3.1.2 Yes Yes n/a This PI is easy to score, and the assessment team found ample proof of the openness of the consultation processes. In particular I note the impressive international manner in which P1 discussions lead to suggestions and potential improvements that are then opened to broad consultation nationally. Few established fisheries enjoy such a broad and transparent airing of methodology and data so regularly.
Comment noted. No action required.
3.1.3 Yes Yes n/a South Africa’s management policy for this fishery (and indeed all its fisheries) has clearly been developed to be consistent with
Comment noted. No action required.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
the MSC’s Principles and Criteria, and the precautionary approach is subsumed in all management decision-making. Hence, with a single scoring issue, this PI scores 100.
3.1.4 Yes Yes n/a It is here that the comments made above in 3.1.1 about political questioning are manifest most strongly. The whole South African fishing rights allocation process can destabilize a fishery by undermining confidence in future access prospects. It will take many years for this problem to work its way through the client fishery, although it is in other South African fisheries that the problem is at its worst. For the client fishery, however, a score of 80 is justified.
Comment noted. No action required.
3.2.1 Yes n/a The assessment team correctly score this PI at 80 for both of MSC Principles 1 and 2, but point out that some of the P2 objectives are too generic to allow them to be evaluated against fixed time-scales. The partial score of
Comment noted. No action required.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
80 for P2 and 100 for P1 MSC principles is therefore correct (overall score 90).
3.2.2 Yes Yes n/a There is an interesting spelling of “hiccough” here! Notwithstanding, the issues raised by the assessment team, such as the inability of the government agency to guarantee the future of the observer programme and its inability to maintain its dedicated sea-based survey programme, on which the assessment is largely based (SI 3.2.2b), do mitigate against a full-house score for this PI. Hopefully, both these important issues can be addressed in the near future.
The spelling has been corrected, but
we have favoured “hiccup” over
“hiccough”.
We note the concerns raised here. Our
findings at the site visit were that AT
PRESENT the observer coverage is
adequate. During the previous period
of certification we generated new
conditions in response to concerns
about the adequacy of observer
coverage and monitoring of the
fishery. We will keep this particular
issue under scrutiny.
We note the endorsement of our
scoring and the caveats we have used
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
in our rationale.
3.2.3 Yes Maybe Perhaps there should be one
Compliance seems to be good, and effective sanctions are available in national legislation. Like the team, however, I do have a problem here. The objective of this MSC PI is to ensure that there is an effective MCS system in place. The government agency “apparently” understands this necessity (for all its fisheries), but its investment in maintaining its system at the high level needed for this fishery (a distant-water one) is seemingly lacking. Two of the patrol vessels (50%) were out of commission during the site visit (and at-sea MCS other than VMS is crucial for this deep-sea fishery), and the trained staff component essential to supporting the whole system is very thin on the ground. Given those limitations, I question whether SG “a” can score 80 – is the system actually operative at the level required by MSC Principles. I have no problems with the other scorings for this PI, but at the very least I believe that a
We note the concerns raised here. We
found that at the time of the site visit
the MCS system was recovering from
a difficult period and that the systems
in place (just) met the SG80
requirements. We now understand
that 3 out of the 4 patrol vessels are
operational.
Whilst noting and largely agreeing
with the reviewer’s comments, we
consider that the SG80 requirements
are fully met.
We have responded to the comments
made here by making a
recommendation that effective
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
recommendation on the compliance capacity needs to be raised by the assessment team, if the decision is still that PI3.2.3a does warrant a score of 80. It possibly does, but I need convincing that the government agency really is providing the MCS system the client fishery needs to meet international best practice.
compliance measures should be
implemented, and noting that evidence
to demonstrate progress with this
particular issue will be sought at future
surveillance audits.
3.2.4 Yes Yes n/a As above, the questionable commitment of the government agency to implementing the comprehensive research plan that is certainly in place mitigates against scoring PI3.2.4a above 80. The plan itself is good and it is reviewed internationally, so it is only in the implementation where this PI fails to score a full-house 100.
Comment noted. No action required.
3.2.5 Yes Yes n/a The full-house score is entirely justified for this PI. The review process in place is better and more effective than for many certified fisheries, and the client and government agency (and its contractors) deserve credit for this.
Comments noted. No action required.
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Any Other Comments
Comments Conformity Assessment Body Response
I said initially that this is a complex fishery, and I stand by that statement. I have
raised a couple of issues in my narrative above, and I hope that they will be
addressed in the consideration phase that follows this. My problem with what I see is
simply that everything seems to be in place for the fishery to sail through this
recertification, but there are several areas where actual implementation, or
commitment to implementation, is lacking. This aspect really does need to be looked
at, and the MSC process offers a fantastic opportunity for that to happen.
These comments are noted. We have noted that the client (SADSTIA &
SECIFA) have been proactive in their response to management issues over
the past 10 years, and our scoring reflects this. The continued commitment
of the RSA government to the management of the fishery will be vital to
secure compliance with MSC standards throughout the next period of
certification.
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For reports using the Risk-Based Framework:
Performance
Indicator
Does the report
clearly explain
how the process
used to
determine risk
using the RBF
led to the stated
outcome?
Yes/No
Are the RBF risk
scores well-
referenced?
Yes/No
Justification:
Please support your answers by referring to specific
scoring issues and any relevant documentation
where possible. Please attach additional pages if
necessary.
Conformity Assessment Body Response:
1.1.1
NA NA NA The RBF has not been used for this fishery.
2.1.1
2.2.1
2.4.1
2.5.1
For reports assessing enhanced fisheries:
Does the report clearly evaluate any additional impacts that might arise
from enhancement activities?
Yes/No Conformity Assessment Body Response:
Justification:
NA
This is not an enhanced fishery.
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16.1.2 Peer Reviewer B
Overall Opinion
Has the assessment team arrived at an
appropriate conclusion based on the evidence
presented in the assessment report?
Yes Conformity Assessment Body
Response
Whilst numerous points for clarification and possible
shortcomings have been identified, I do not anticipate that any
of them will prove show-stoppers. Even where changes in
scores have been suggested, or might be appropriate
following revision of text, I doubt that any of them will be
sufficient to affect to overall results and conclusion. On this
basis, and subject to the report being strengthened were
necessary (principally with respect to habitats), I am happy to
support this report and its recommendation for certification.
Comment noted. No action required.
If included:
Do you think the client action plan is sufficient
to close the conditions raised?
Yes/No Conformity Assessment Body
Response
On balance, the proposed actions plans appear appropriate for Comment noted. No action required.
Do you think the condition(s) raised are
appropriately written to achieve the SG80
outcome within the specified timeframe?
Yes Conformity Assessment Body
Response
Subject to the CAB response to comments relating to 2.4.1
and 2.4.3, the condition set on 2.4.2 made need modifying to
cover 2.4 as a whole.
On balance, the conditions set seem appropriate for the
shortcomings identified but the conditions relating to habitats
and ETP species would benefit from some clarification and
possible minor additions.
1. All observers should be required to record all bird and ETP interactions (i.e. direct strikes and presence below but astern of the headline).
2. It would be helpful if all observers (and ideally skippers in the official logbook) recorded the occurrence of all macrobenthos in the trawl (e.g. coral, sponges, seapens). This would help to build a more detailed picture of the distribution of potentially sensitive and vulnerable species.
The comments relating to PI 2.4.1 have
been addressed in the scoring rationale
for the PI and the text relating to habitat
interactions.
The comments relating to observing
ETP and habitat interactions are noted.
Our understanding is that observers are
being trained to monitor and record bird
interactions, but that it is unlikely that all
observers will be trained (and
questionable whether this is actually
necessary, providing that fishing trips
are adequately sampled to provide a
sufficiently accurate overview of
impacts).
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meeting the conditions set.
General Comments on the Assessment Report (optional)
The main text of the report is clearly written and logical in its presentation, which makes it easy to
follow despite the involvement of two species and, notionally, two fleets. Insofar as there are
significant omissions of information from the report, they concern the description of habitats.
Although a variety of habitat types has been identified and listed, the information is limited to
substrata and topography; there is no information on what biota characterise these habitats, its relative
abundance or distribution. In particular, no indication is given as to where upright fragile species,
species that are most vulnerable to trawl activity, might be found. In view of the condition that has
been set with respect to habitats, it is possible that this information is still not available, in which case
the point should be made clearly and explicitly in the appropriate section of the text report and be
reflected in the scores. Not unrelated to this point is the omission of any description of the trawl gear
used, in particular the ground gear (doors, sweeps and foot rope). This has relevance to the potential
effect that trawling may have on any particular habitat type, including whether or not it is feasible to
trawl in a particular habitat. It is essential that these shortcomings are rectified.
IFC Comment: We have provided more information in the report and scoring rationales about habitat
types and fishing gear to the report to clarify these points.
Other specific points are listed below:
PDF page no. Comment
General Numerous typographic errors and presentational inconsistencies have been drawn to the
assessment team’s attention.
IFC Comment: We have addressed all of the comments provided in an annotated
version of the report submitted by the peer reviewer.
Principle 1
S 5.1; p 23 “They are the dominant predator in the demersal niche.”
Is this an opinion or an established fact? If fact, it would be appropriate to support it with
a reference.
IFC Comment: Reference added.
Legend Fig 5 The nature of the ‘surveys’ is unclear; are they research-vessel surveys and what is the
significance of ‘Africana’? As it happens, I know that it is the principal RSA research
vessel but this should be made explicit for other reviewers who may be less familiar with
such things, not least because it receives many further references throughout the report.
IFC Comment: Caption modified accordingly.
P 32 The paragraph below Fig 5: this might be the place (or better still, earlier when research
surveys are first mentioned) to say a word or two about Africana and Nansen for readers
who are not familiar with the global research –vessel fleet. As far as I am aware, the
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Nansen is a Norwegian RV normally associated with UN/FAO projects in developing
countries. Where does she fit into the RSA scheme of things?
IFC Comment: The Nansen is indeed the Norwegian vessel. The details of how or
why this vessel was used in South African waters is not relevant to the
assessment outcome. The text simply illustrates that there have been
some challenges in the provision of adequate research vessel coverage
over recent years, but that solutions were found.
P 34 ‘While the baseline assessment is now species-species, a species combined---‘ Is this
correct, or should it be species-specific?
IFC Comment: This was a typographic error and has been corrected.
P 35 S5.6 Management plan: a key factor of any management plan that does not come across
clearly is what action, if any, will be taken if the (M. paradoxus) stock goes into (a
sustained) decline. We are told that the current OMP has an inter-year limit on variation
in TAC of 10%, but what if stock decline demands more than this?
IFC Comment: The design of the OMP at each renewal (4-5 years) takes stock status
into account, leaning towards the weaker stock (in this case paradoxus)
in terms of setting TACs that ensure that there is a small probability
that the resource declines any time within that time frame. In the event
of a stock decline, the OMP will respond to this (as it did for paradoxus
over the last 10 years), since a main aim is to ensure profitable catch
rates. Thus, stock sustainability and fishery viability act in harmony.
S 5.7, p 37 “---stock assessment procedures, in which the assessors choose a “base case” that reflects
some perception of median or mean tendency of the status of the stock---“. I confess that
I am far from certain that I understand what this means.
IFC Comment: That is why we suggest “that readers wishing to skip this technical
section should move forward to section 5.7.9”
Principle 2
P 53 What is a ‘joint product’? Is it simply unsorted catch that is landed (p 78, S6.2.7)? A clear
definition at first mention will be helpful.
IFC Comment: The text has been clarified to explain this.
Table 6 Legend: “Catch of non-target species (“bycatch rate”) as a proportion of the catch of the
two hake species, and ranking of the top 5 non-target (i.e. non-hake) species for the
period 2008-13. [Source: Attwood, 2014].” The legend and table column headings appear
to be at odds with each other. If it is the “top 5 non-target (i.e. non-hake) species”, they
should be labelled 1–5 as the hake are the target species. If the current column headings
of 3 – 7 are correct, I don’t understand the table as it implies that hake are 1st and 2
nd non-
target species.
IFC Comment: The legend make sense. The species listed are all non-target species,
and represent the 3rd
, 4th
, 5th
, 6th
and 7th
most abundant retained species after the two
(target) hake species. No change is considered necessary.
P 58 What are St Joseph sharks? The name is not recognised in FishBase.
IFC Comment: They are listed in Table 9. Callorhinchus capensis.
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P 78 “The spatial distribution of discarding activity has been determined from observer data
and is shown in Figure 28.” I think that the assessors should express some opinion or
draw some conclusion from what is shown in Fig 28 rather than leave it hanging for the
reader to drawn their own conclusions, conclusions that might be at odds with what the
authors think.
IFC Comment: Comment noted. A brief description has been added.
Fig 27 What are ‘horse fish’? They are not mentioned anywhere in the text.
IFC Comment: they are Congiopodus torvus. We have now mentioned this in the
text.
P 80 “Observations carried out during 2004 and 2005 aboard SADSTIA trawlers suggested
that around 18,000 birds were killed annually in the fishery (Watkins et al, 2008).” If ‘the
fishery’ is the trawl hake fishery, I think ‘trawl hake’ should be inserted so that there is
no misunderstanding. To many readers, albatross mortality is associated with longline
fisheries rather than trawling.
IFC Comment: We have modified the text to remove any possible ambiguity.
Similarly, does “Albatross mortality is now considered to be negligible (83 birds in 2010)
(Maree et al, 2014)” relate specifically to the trawl fishery?
IFC Comment: We have modified the text to remove any possible ambiguity.
P 82 “the fishing industry commissioned two dedicated seabird observers in 2012”. Is there
any reason why all fishery observers should not be required to record bird mortalities?
IFC Comment: It is our understanding that this task requires considerable training and
it may be impractical to train all fishery observers for this work.
P 84 “The frequency and nature of interactions with different bird species over this period is
shown in Table 11.” Some explanatory text should be added. It is far from clear what
constitutes a ‘high’ (medium or low) interaction other than the legend says that a ‘high’
interaction is more likely to result in death.
IFC Comment: The legend of Table 11 explains the different levels of interaction..
P 87 Sooty shearwater Puffinus griseus
“---the harvesting of its young---“. Who by; South Africa? Whichever it is make it clear.
If it is SA, it must lead to a condition.
IFC Comment: We have modified the text to make it clear that the hake trawl fishery
is not connected with harvesting of young sooty shearwaters.
P 88 “--- inshore trawl fishery in the late 1880s to the current extent of the fishery ---” – 1880
or 1980?
IFC Comment: 1880 is correct. In fact the first record of trawling was in 1878.
P 94 Fig 35 At normal screen page size there only appears to be a single no-take MPA whereas there
are more than that; e.g. under the ‘Port’ of Port Elizabeth. It would be helpful to give
some additional indication (arrows perhaps) as to where these sites are
IFC Comment: We have replaced the map with a higher resolution version which
makes the location and name of the MPAs clearer.
S 6.4 Habitat Interactions – it would be helpful, I think if something was said about how the
authorities propose to monitor and enforce the no-trawl zones, both existing and
experimental areas. Without such an explanation one might think that the whole scheme
is dependent on good will.
IFC Comment: Compliance with the trawl footprint is a licence condition.
Numerous habitat types are identified in this section but there is no indication as to how
one or other of them is more or less vulnerable to adverse effects from trawling.
Compared with other trawl fisheries subject to MSC assessment and certification, I have
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no sense of what the vulnerable features are. Are there coral gardens or areas of other
large upright biota; are there extensive areas of sponges that provide complex habitat for
a myriad of other species? The RSA may be a long way off having a detailed map of
seabed habitats (as opposed to substrata) but there must be some idea of what sensitive
and vulnerable species might be found in the various area types named.
IFC Comment: We have amended the text to make it clear that the maps presented are
based on information about marine benthos as well as substrata; they are more like
biotope maps than habitat maps.
In this context, also, it might be helpful to give some indication of exactly what type of
trawls are used. Depending on habitat type, plain footrope, rollers, rock-hopper rig and
tickler-chain ground gear all have different effects.
IFC Comment: We have added some text to section 5.3 of the report in response to
this comment.
Principle 3
P 97 CITES is of specific relevance wrt ETP species; is RSA a signatory?
IFC Comment: Good point. Yes it is. We have now mentioned this in the text.
Monitoring, Control and Compliance - to ensure that fish resources are protected through
--- other relevant equipment and systems---“. What are these? Does it include VMS or is
it wholly dependent on happenchance surveillance by patrol boats (and aircraft)? If
necessary, cross-reference to 7.7.
IFC Comment: The text has been amended in response to this comment.
P 101 If skippers are expected to record seabird mortalities on their logbooks, why (as far as we
can tell from this text) do the fishery observers not keep a record? Without observer data
to cross reference with skippers’ logs, how can the logbook data be verified?
IFC Comment: Yes they do. The text has been amended in response to this comment.
With respect to compliance: is there any post-hoc monitoring through auditing of sales
(and export) records for comparison with logbook declared landings?
IFC Comment: Yes there is. We have amended the text to make this clear.
S 7.8 IUU: the 10 IUU vessels may not have been engaged in the hake fishery but were they
SA-registered vessels? If they were, it would suggest that the monitoring, compliance and
control still leaves something to be desired. If they were all non-SA registered vessels, it
would be as well to make this clear.
IFC Comment: We don’t agree with the reasoning. If there was no evidence of IUU
being detected this could also show that MCS implementation is not working. The flag
state of the vessels is irrelevant. What is relevant is that IUU fishing was detected and
punished, and it did not involve vessels in the UoC.
Conditions
P 105 It is noted that one condition has yet to be closed. It should be noted that this condition
relates to the final points raised above under P2.
IFC Comment: Noted.
P 126 Proposed new condition 3 & 5: Is there any reason why this could not be expanded to
include a requirement for observers (and possibly skipper) to record what non-fish biota
are retained in the trawl and brought onto the deck? Such an approach might help
improve the knowledge of what species and habitats are to be found where.
IFC Comment: Although this is a good idea, the condition is focussed on management
of habitat impacts rather than information (which scores more than SG80).
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Performance Indicator Review
Please complete the table below for each Performance Indicator which are listed in the Conformity Assessment Body’s Public Certification Draft
Report.
Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
1.1.1 MP
Yes Yes Yes but see comment.
The information presented is relevant and clear. The condition is appropriate providing recruitment continues to hold up. In the event that poor recruitment results in a downturn in SSB it is not immediately obvious what management action will be taken to maintain stock-rebuilding conditions.
This issue was recognised by both peer
reviewers. There is a stock rebuilding
strategy in place for M. paradoxus that
it is effective (PI 1.1.3 scores 90), and
the condition is continued
implementation of the rebuilding
strategy within the OMP, which has
projected that the M. paradoxus stock
to will reach its target reference point
before 2020 (i.e. within the five year
period of certification). In the event
that there is an unexpected downturn
in recruitment (the assessment
incorporates a stock recruitment
model), the design of the OMP will
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
respond to this (as it did for paradoxus
over the last 10 years), since a main
aim is to ensure profitable catch rates.
1.1.1 MC
Yes Yes N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
1.1.2 MP + MC
Yes Yes N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
1.1.3 MP
Yes Yes N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
1.2.1 Yes Not entirely N/A I have reservations about scoring 100 for 1.2.1a principally because it is not immediately obvious how the OMP would respond to a (sustained) decline in SSB other than limit inter-year changes in TAC to 10%. What if this is not enough?
See comments against 1.1.1
1.2.2 Yes Yes N/A Agreed. The information presented is Comment noted. No action required.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
relevant and clear; it even includes a comment under 1.2.2a acknowledging the concerns expressed above under 1.2.1.
1.2.3 Yes Yes N/A Agreed. The information presented is relevant and clear but see comments made earlier concerning the origins of IUU catches. Under guidepost c it is stated that “IUU fishing is reliably estimated to be negligible” but nowhere in this report is the derivation of this reliable estimate explained. The information given in S7.8 hardly supports the contention that estimates are reliable. A score of 90 might be more appropriate.
Information from DAFF on IUU
vessels has shown no hake in catches.
The text has been amended to help
clarify this.
1.2.4 Yes No N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
2.1.1 Yes No N/A The final score is probably correct but the This is a good observation.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
inclusion of species that do not meet the 5% threshold (or other criteria for main retained species) is confusing – would it be clearer if the two UoC be separated? Specifically – Silver kob: it is said that an annual catch of
c. 200 t by the hake trawlers is unlikely to affect the kob stock. This seems at odds with the evidence presented earlier (Fig 20) that suggest the kob stock is little more than 200 t. Either this needs to be reflected in the scoring here or more information is needed to support this conclusion.
Our text explains that the data on non-
target catch from the inshore area has
some limitations. One of these is that
the analysis of inshore trawl catches
does not distinguish catches from the
Agulhas sole trawl fishery and the
inshore hake trawl fishery. Most of
the silver kob catch is reported to be
landed from the sole fishery.
The text states that the silver kob stock
was estimates at 447t in 2010, and not
“little more than 200t”. We have also
asked the client to confirm stock
status, and have been provided with an
additional source of information
(Winker et al, 2012), which estimates
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
the silver kob stock at just over 7,500t.
We have cited this information in the
report and the scoring rationale.
The catch distribution (Figure 21)
clearly shows that the main catches of
silver kob are taken both inshore and
to the east of the hake fishing grounds.
We have revised the text to make it
clearer that the abundance of silver
kob in the hake trawl fishery is an
artefact of the data. The score is
considered to be appropriate.
2.1.2 No No N/A Notwithstanding the statement (2.1.1) that the authors do not wish to comment further
We have in fact made further
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
on silver kob, see comment above re 2.1.1. If the trawl catch for silver kob is c. 200 t p.a. and the current stock abundance is ≥200 t (Fig 20), it is possible that 2.1.2a only just clears 60 rather than 80.
comments about silver kob in this
scoring rationale, and consider that the
scoring is appropriate.
2.1.3 Yes Yes N/A Agreed – subject to clarification with respect to kob stock and catch figures.
Comment noted. No action required.
2.2.1 Yes Yes N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
2.2.2 Yes Yes N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
2.2.3 Yes Yes N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
2.3.1 Yes Yes N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
2.3.2 Yes Yes N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
2.3.3 Yes Yes Yes The information presented is relevant and clear. A score less than 80 is undoubtedly correct but 70 seems a little harsh. With respect to Condition and action plan: I am still unclear whether it is intended to increase just the number of bird observers or whether recording trawl interactions with birds (or, indeed, any ETP species) is to become a routine aspect of the standard observers’ role. I think it should be the latter.
2.4.1 No No Possible condition required
Despite the statement that there is “a good understanding of both the distribution and sensitivity of marine habitats,” the report is
We have added some more
background information in the report,
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
remarkably coy about presenting any detail. Some information is presented with respect to the relative quantities of various substrata but there is no information about sensitivity to trawl action, and certainly none about the distribution of sensitive or vulnerable benthic species. Without some detail on this, and reassurance that current trawling is not (continueing to) razing all upright species, I fear the rationale does not support a score of 80.
particularly to correct the perception
that the habitat maps are based solely
on seabed substratum; they are based
upon a classification that also takes
account of marine benthos. The text
explains that the vulnerability and
sensitivity of these habitats has been
assessed (in detail in the report by Sink
et al, which is available on the
internet). We have presented a brief
summary of the key findings of this
work, and also presented figures that
support the conclusions drawn in the
report.
2.4.2 Y Y Y Comments at 2.4.1 above still apply re 2.4.2b Comments noted. Our revisions to the
report address this issue.
2.4.3 N N Possible condition The summary of Sink’s (2013) work given in We have revised the report to correct
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
required the report work only identifies the types of substratum or topographical features. Whilst these are a fundamental part of habitats, the distribution of upright macro benthos such as corals, sea-pen communites, bivalve reefs and sponge beds all provide habitat for other species and therefore are part of the total habitat. It is this part of the overall picture that is missing from the report and scoring.
the perception that the Sink et al report
is limited to a classification based
solely on substratum and topography.
It also takes account of information
available about benthic communities.
2.5.1 No No N/A The concerns about habitat expressed above cast a slight shadow over this PI but the principal concern is with the dependence on modelling the (cold-water) Benguela system. Strictly speaking, this system is to the west of the Cape Agulhas and one might (reasonably) assume that the south-flowing, warm-water Agulhas Current system to the east of the cape might have different characteristics. Even if the (not unreasonable) assumption is made that the
These comments are noted. The hake
stocks are dependent inhabit deep,
colder water rather than the warm
surface waters of the Agulhas current.
We have added text to the report to
clarify this point.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
Benguela system modelling is a reliable surrogate (in broad principles at least) for the (eastern) Agulhas system, the division merits explicit mention with an appropriate moderation of scores owing to the lack of site-specific information to the east..
2.5.2 Yes Yes N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
2.5.3 Yes Yes N/A Agreed but comments at 2.5.1 are relevant.. Comments noted, and addressed by the
clarification added to the scoring of PI
2.5.1.
3.1.1 Yes Yes N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
3.1.2 Yes Yes N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
3.1.3 Yes Yes N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
3.1.4 Yes Yes N/A Agreed but it might be argued that the penalties that can be incurred for non-compliance with the management regime are an incentive, albeit a negative incentive, with respect to 3.1.4a.
We have amended the text in response
to this comment.
3.2.1 Yes Yes N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
3.2.2 Yes Yes N/A Agreed. The information presented is relevant and clear. It might be helpful to include the SADISTIA fishery-related web page given in the references.
Comment noted. We have added the
link to the SADSTIA website in the
references.
3.2.3 Yes Yes N/A Agreed – but see earlier comments about cross referencing declared (logbook) catches with sales records.
We have amended the text in response
to this comment. We have also added
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
text concerning the performance of the
MCS regime and have generated a
recommendation about this, in
response to the earlier comments.
3.2.4 Yes Yes N/A Agreed. The information presented is relevant and clear.
Comment noted. No action required.
3.2.5 No No N/A An account has been given of how the science of stock assessment is subject to (international) review and, arguably, the relevant OMP, but are there ‘mechanisms to evaluate all parts of the management system. For example, it is not clear how the performance of the MCS arm of management is reviewed, not least with respect the ongoing problem of out-of-action patrol vessels. What is the review procedure with respect to habitats and ecosystem? Unless it can be shown that the non-fish science and MCS parts of the management
We have amended the text to make it
clear that all of the management
system (including MCS) is subject to
review.
Sufficient evidence is presented in the
scoring rationales for the
“management” aspects of Principle 2
to demonstrate that the management of
ecosystem impacts (i.e. on non-target
fish species, ETP species and marine
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Performance
Indicator
Has all the
relevant
information
available been
used to score
this Indicator?
(Yes/No)
Does the
information
and/or rationale
used to score this
Indicator support
the given score?
(Yes/No)
Will the
condition(s)
raised improve
the fishery’s
performance to
the SG80 level?
(Yes/No/NA)
Justification Please support your answers by referring to specific scoring issues and any relevant documentation where possible. Please attach additional pages if necessary.
Conformity Assessment Body
Response
regime are subject to equally rigorous internal and external review, a score of 80 would seem more appropriate.
habitats) is kept under review. We
have amended the text to make this
clear.
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Any Other Comments
Comments Conformity Assessment Body Response
No comments.
No action required.
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17 STAKEHOLDER SUBMISSIONS
17.1 Stakeholder interviews conducted during the site visit
During the site visit in March 2014, the assessment team met with and interviewed the client and key
stakholders in Cape Town. A summary of each meeting was compiled by the team and sent to each
stakeholder for comment and revision. The edited versions of each interview are reproduced below.
The interview records are presented in alphabetical order.
17.1.1 Bird Life South Africa
MSC Fishery Assessment Stakeholder Interview Record
Assessment Team Names
Lead Assessor Jim Andrews
P1 Team Member Mike Pawson
P2 Team Member Jim Andrews
P3 Team Member Johan Groeneveld
Meeting Location Cape Town, South
Date 17th March 2014
Stakeholders Name Affiliation
Bronwyn Maree BirdLife South Africa
Melanie Smith Capfish (observer)
2. Status
What is the nature of the organisations interest in the fishery (e.g. client / science / management /
industry / eNGO, etc)
BirdLife South Africa (BLSA) is an environmental NGO and the largest (and only) bird conservation
organization in South Africa. BLSA is the local partner of BirdLife International and was the first to
initiate an Albatross Task Force team in 2006. Recently BLSA has also become a member of the
Responsible Fisheries Alliance.
BLSA is responsible for drawing up the Bird Mitigation Plans required by fishing vessels in South
Africa (in collaboration with the fishing industry).
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3. Stakeholder Key Issues
What, if any, specific substantive issues or concerns are identified regarding the fishery? (P1 – P2 –
P3) and what information is available to allow us to determine the status of the fishery in relation to
each issue?
The key issues considered during the meeting are set out in the letter submitted by BLSA to the
assessment team. The discussion is summarised below.
Bird bycatch and mitigation measures
BLSA are shortly due to publish a paper which shows a reduction of overall bird mortality by
90% and albatross mortality by 96% over the period 2006-2010. This is largely due to the use
of tori lines and also the reduction of fishing effort.
BLSA is confident that Tori Lines are being used by the vast majority of the fleet.
Observer programme
BLSA were concerned that the government observer programme (OROP) had not yet been
reinstated (it was understood that the contract for this was out for tender). Although in the
past the observers collected mainly fish-related data, the new programme seeks to also collect
bird-related data.
Currently BLSA continue to collect the majority of seabird-related data within the fishery.
BLSA noted the level of coverage achieved by SADSTIA, but felt that it could be improved
by:-
o Training of more observers to monitor birds (there is currently only one trained
observer in seabird data collection in the SADSTIA programme).
SADSTIA observer data was being made available to BLSA.
BLSA have 3 observers working on trawl vessels; observer effort is focused/increased during
winter months (due to higher bird abundance) when they aim for each observer to work 21
days every two months. During summer months BLSA observers average about 6 days per
month observed.
BLSA observers had made incidental observations of occasional capture of seals (which are
returned alive) and other species such as cat sharks. Some benthic animals (such as starfish)
were observed, but no cold water corals.
Compliance at sea
BLSA were concerned about the level of at-sea and aerial compliance and enforcement
activity in the fishery.
Bird Mitigation Plans
BLSA are responsible for drawing up BMPs for fishing vessels.
BLSA were concerned that they were not being asked to inspect new trawl warps (as outlined
and agreed upon in the BMPs).
All BMPs require that sticky warps (i.e. warps with high grease & bitumen coating) should
not be used.
o Observations aboard vessels suggest that sticky warps are not being used in general,
although one vessel has been observed with sticky warps recently.
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Inshore fleet
There is no observer programme in place for the inshore fleet (considered by BLSA to be
those vessels permitted to work in water less than 110m deep as well as in deeper water).
Observer coverage for this fleet should be provided by the government OROP which has not
been operational for several years.
There are currently no BMPs in place for the inshore fleet
BLSA are not aware of the level of use of tori lines by the inshore fleet.
The main bird interaction with the inshore fleet is likely to be with Cape Gannets which
occasionally become entangled in nets but may include offshore/pelagic seabirds as well
Seabird bycatch within this fishery is unknown.
4. IMM Assessment Team Questions
Assessment team questions for stakeholders
Update on current level of interaction between the fishery and birds.
Update on observer coverage for bird interactions.
Any other issues that BLSA wish to discuss.
5. Other issues
(e.g. any other stakeholders we should contact, any written submissions to follow?)
BLSA offered to provide:-
An update on the background information on seabirds in this fishery set out in the previous
assessment report.
A copy of the publication in press concerning bird bycatch in the trawl fishery, when this is
available.
A template of a bird mitigation plan.
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17.1.2 CapFish
MSC Fishery Assessment Stakeholder Interview Record
Assessment Team Names
Lead Assessor Jim Andrews
P1 Team Member Mike Pawson
P2 Team Member Jim Andrews
P3 Team Member Johan Groeneveld
Meeting Location Capfish Offices, Cape Town
Date 21st March 2014
Stakeholders Name Affiliation
Melanie Smith Capfish
Sarah Wilkinson Capfish
Victor Ngcongo Capfish
2. Status
What is the nature of the organisations interest in the fishery (e.g. client / science / management /
industry / eNGO, etc)
Capricorn Fisheries Monitoring (CapFish) is an international marine monitoring and fisheries
consulting group based in Cape town, South Africa. We train and deploy marine observers for South
African and global maritime activities. The Company works closely with our national marine
management authorities as well as with Regional and International Fisheries Management
organizations (RFMOs). Our activities also working directly with fishers, hydrocarbon exploitation
(i.e. seismic activities) phosphate mining companies and Non-Governmental Organisations such as
WWF, Birdlife and many other groups. Our goal is to provide a professional service supporting both
management and science to maintain the long-term sustainability of marine resources.
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3. Stakeholder Key Issues
What, if any, specific substantive issues or concerns are identified regarding the fishery? (P1 – P2 –
P3) and what information is available to allow us to determine the status of the fishery in relation to
each issue?
Observer programme
The procedures associated with the SADSTIA observer programme were explained. These
encourage representative sampling, which are summarised in a document presented to the
team.
o Capfish has 27 SADSTIA dedicated observers, which are allocated at random to
vessels leaving from their local port.
o 2 observers are trained to observe interactions with birds (monitored according to a
protocol which looks at seabird-fishing gear interactions while nets are being set,
during trawling, and whilst hauling the gear). Observations are made for the number
and nature of interactions, and the number of birds observed in the vicinity of the
vessel.
o All observers are fully trained to sample the catch according to a sampling protocol as
well as record catch and effort data, gear and equipment information and
environmental data.
o During a fishing trip, observers take a random sample from each net haul and
examine and measure the species composition of the unsorted catch.
o Most of the observer effort is directed at the offshore fleet; there is less observer
coverage for the inshore fleet.
The OROP observer programme ran from 2002-2011 and covered both the offshore and
inshore fleets.
Discard monitoring
Discard-dedicated sampling took place from 2002-06. Discard monitoring since 2006 has
been sporadic.
Some discard monitoring took place in 2013, in response to comments made by the
International Peer Review Panel. To date, 23 trawl hauls have been sampled, for discard
monitoring .
Otherwise, a comparison between observer catch data and commercial landings data has been
used to identify discarded species and estimate the quantities discarded.
Distinctions between inshore and offshore fleets
The inshore fleet fishes on the Agulhas Bank and uses lighter gear than the offshore fleet.
The inshore fleet is composed of vessels smaller than 30m LOA, which are permitted to fish
in waters shallower than 110m. These vessels are also permitted to use cod-end mesh size of
less than 90mm in these waters.
The results of observer sampling have not been split between the inshore and offshore fleets,
but this can be done.
Trawl ring-fencing
The trawling footprint is based on fishing position records from 1998-2008 and was
implemented in 2009.
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A MaxSea file showing the ring-fence boundary was issued to all vessels for use with fishing
vessel navigation equipment.
Compliance is monitored by DAFF using VMS records from the fleet: however, compliance
with the ring-fence is currently does not form part of permit conditions.
Experimental area
The benthic impact experimental area was chosen to be within an area that was heavily
trawled, contained specific seabed habitats, was in a certain depth range, and would be easily
accessed by both patrol and research vessels.
The experimental area is divided into 5 lanes
The location of the boundary of the experimental area has been distributed to all vessels as a
MaxSea file for use in vessel plotters.
The trawl track information was used to optimise the experimental area boundary.
Hake longline fishery
Capfish are working with the hake longline fishery as part of a Fishery Improvement
Programme endorsed by WWF with the aim of improving the performance of this fishery
with respect to the MSC standard.
Observer trips have taken place on 6 vessels to date, as part of a process of developing
protocols for catch monitoring and observing seabird and seal interactions in this fleet.
Information is being provided to help minimise gear conflict with trawlers (e.g. providing
coordinates of longline sets to trawl operators).
The longline fishery footprint is known and catch composition data are available.
Information on seal depredation and damage to the catch, and seabird interactions (which are
chiefly feeding on offal) has been recorded.
A code of conduct for responsible fishing practices has been developed to enforce compliance
with management recommendations and permit conditions..
Observer catch and length data have been provided for use in the hake stock assessment.
4. IMM Assessment Team Questions
Assessment team questions for stakeholders
Update on observer programme and any scientific / monitoring work carried out by Capfish
which may be relevant to the MSC assessment.
5. Other issues
(e.g. any other stakeholders we should contact, any written submissions to follow?)
Capfish agreed to split the observer records for discarded fish so that fishing by the inshore
fleet and offshore fleet could be distinguished.
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17.1.3 Department of Agriculture, Forestry and Fisheries
MSC Fishery Assessment Stakeholder Interview Record
Assessment Team Names
Lead Assessor Jim Andrews
P1 Team Member Mike Pawson
P2 Team Member Jim Andrews
P3 Team Member Johan Groeneveld
Meeting Location DAFF offices, Cape Town, South Africa
Date 19th March 2014
Stakeholders Name Affiliation
Mortimer Mannya Deputy Director General, Fisheries Management
Kim Prochazka Director, Resource Research
Deon Durholtz Scientist, Hake Research
Saasa Pheeha Director, Fisheries Management
Nambulelo Magqira Communications
Dennis Frederiks ACD, MRM
Ceba Mtoba CD, MCS
Belamane Semole ACD, CRD
Bernard Liedemann Acting Director, Fisheries Patrol Vessels
Nkosinathe Dana Director, Monitoring & Surveillance
Xolela Wellem Control & compliance
Andile Mosheni ADD – FPV
Thabiso Maratsane ADD – FPV
Martin Purves Marine Stewardship Council (Observer).
2. Status
What is the nature of the organisations interest in the fishery (e.g. client / science / management /
industry / eNGO, etc)
The Department of Agriculture Forestry and Fisheries (DAFF) are the government department
responsible for managing the hake fishery.
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3. Stakeholder Key Issues
What, if any, specific substantive issues or concerns are identified regarding the fishery? (P1 – P2 –
P3) and what information is available to allow us to determine the status of the fishery in relation to
each issue?
Government Policy
The government is working to achieve inclusive growth in all sectors of the economy as part
of its fight against poverty and illegal activity.
There is a growth and development plan to ensure that there is wide participation and benefit
from the natural resources of South Africa whilst ensuring that industry remains competitive.
The government is committed to the sustainable use of shared natural resources as part of its
commitments to international conventions.
South Africa is committed to collaboration with international partners in the fields of
enforcement and research.
It is important to strengthen governance arrangements.
DAFF are developing new plans and policies and will be implementing a rolling 5 year plan
for fisheries.
DAFF acknowledge that there have been problems with research and enforcement vessels in
recent years and have now taken steps to return them to operation.
The government has recently amended the Marine Living Resources Act to establish new
measures to encourage the development of small scale fisheries that will provide
opportunities for meaningful participation of previously excluded people.
Marine Stewardship Council Certification
There was some discussion of how more fisheries in South Africa might be put forward for
MSC assessment and certification.
It was noted that there could be opportunities for pre-assessment of fisheries if funding was
available to meet the associated costs. Pre-assessment could lead to either full assessment or
alternatively the development of a Fishery Improvement Programme for the fishery.
Operation of management systems
The operation and effectiveness of the management systems for the fishery were discussed. The main
points discussed were.
Observer programme
o The tender process for reinstating the OROP observer programme was still underway.
o Funds have been allocated for the observer programme in the budget.
CPUE data
o The process for gathering, inputting and checking data was explained and discussed.
o Log book and landings and length data are inputted to a database, and this
information was appropriately validated before use in management.
o Data are usually input and available for use in the assessment within 6 months.
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Stock surveys
o The industry vessel Andromeda is being used to carry out stock surveys in the
absence of the DAFF research vessel FRS Africana, which is currently undergoing
major refitting and repairs. It is anticipated that the Africana will be available during
the second half of 2014.
o DAFF scientists have borrowed an instrument package from the BCC for CTD
monitoring that can be attached to the headline of the trawl to gather environmental
data; DAFF now plan to modify an existing CTD for used in this manner.
o Hake ageing – the Department’s full time otolith ageing technician has been
concentrating on on hake ageing.
Decision making processes
The decision making processes for the fishery were discussed.
The annual preparation of fishing plans and permit conditions was discussed.
The DAFF fishery manager dedicated to the hake fishery works with the industry to agree and
implement these fishery plans.
The process for agreeing the TAC was explained
o A TAC recommendation is made by the Demersal Scientific Working Group
o This recommendation is considered by the Hake Resource Management Working
Group taking into account factors such as legislation, socio-economics, EAF, and
stock advice.
o The recommendation is then submitted to the decision maker (normally delegated by
the Minister to the Deputy Director General) in line with Departmental protocols.
o The OMP (which already contains consideration of socio-economic factors) cannot
be over-ridden unless in “exceptional circumstances” (under s61 of the MLRA).
o The OMP is agreed and set for a 4 year period.
It was explained that there was a problem including resource managers in the SWG, which
now includes many external stakeholders, which can lead to questions being directed at the
manager which can be a distraction from the purpose of the meeting.
Reorganisation of working group meeting composition and flow of information are being
attended to.
Enforcement & Compliance
The assessment team were shown around the DAFF VMS suite, visited the FPV Sarah Baartman, and
also inspected enforcement records at the DAFF offices.
At sea inspections have been resumed now that patrol vessels have re-entered service (2 of the
4 FPVs are now operational5.
5 Update: prior to the publication of the PCDR it was reported by SADSTIA that 3 out of the 4 FPVs are now
operational
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A file of all patrols at sea was provided, together with records of inspections, infractions and
boardings data.
The VMS suite was fully operational and soon to be upgraded.
DAFF have a compliance auditing plan for all sectors of the fishing industry. The hake
sectors is one of the 4 compliance priorities in South Africa. Over the course of the past year
they aimed to audit 8 of the deep sea trawl fishery rights holders, and 16 of the inshore trawl
fishery rights holders.
During the past year, DAFF enforcement activity directed at the hake fishery had detected
only 7 minor administrative errors, which had been well documented. The vessels had been
fined for these transgressions.
Fishing vessels comply very well with fishery regulations – non compliance can result in the
suspension or loss of fishing rights under s28 of the MLRA
DAFF have recently had significant enforcement successes including:-
o Detecting and apprehending 10 IUU vessels
o Intercepting, seizing and repatriating consignments of illegally shipped fish products
(not hake).
o Mobile scanners are used to inspect the contents of frozen containers.
o 70% of cases brought by DAFF are successful; as part of its work, DAFF officials
provide training to the judiciary and prosecuting counsel about fisheries legislation
and regulation.
Discarding of target species is not allowed; all of the target species have to be landed.
Research
An annotated list of research projects was made available to the team which included
priorities and timeframes.
It was confirmed that this research plan covers all priorities and uncertainties in relation to the
hake fishery.
It was noted a more continuous south coast survey might help to reveal the effects of putative
environmental changes in that area on fish stocks.
Information was provided on some specific areas of research, which were discussed. These
included:-
o The Observer programme
o Multi species modelling / predator-prey / ecosystem effects of the hake fishery
o The implications of including data from Namibia in the hake assessment
o The question of changes in day: night fishing behaviour – data for the past few years
shows no evidence in the ratio of fishing during the day or at night.
o Age validation of hake
o Stock status assessments for non-target species
o Stock identification of both the target and also non target species (using genetics,
parasites, meristics, and further analysis of CPUE data)
o Closure of areas to fishing for the purpose of fisheries management and/or benthic
protection.
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4. IMM Assessment Team Questions
Assessment team questions for stakeholders
Update on enforcement activity
Update on status of observer programme
Discussion of management procedures
5. Other issues
(e.g. any other stakeholders we should contact, any written submissions to follow?)
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17.1.4 Marine Resource Assessment and Management Group, MARAM
MSC Fishery Assessment Stakeholder Interview Record
Assessment Team Names
Lead Assessor Jim Andrews
P1 Team Member Mike Pawson
P2 Team Member Jim Andrews
P3 Team Member Johan Groeneveld
Meeting Location Cape Town, South Africa
Date 18th March 2014
Stakeholders Name Affiliation
Professor Doug Butterworth MARAM-UCT
2. Status
What is the nature of the organisations interest in the fishery (e.g. client / science / management /
industry / eNGO, etc)
MARAM have developed the assessment models and undertake the OMP revision processes which
underlie the management of the hake resource.
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3. Stakeholder Key Issues
What, if any, specific substantive issues or concerns are identified regarding the fishery? (P1 – P2 –
P3) and what information is available to allow us to determine the status of the fishery in relation to
each issue?
Reference Points
The reference points used for the fishery were discussed
Target Reference Point
o This is biomass based; it is not fixed
o The target for the fishery is not Bmsy, but is considered to be compatible with MSC
requirements. Bmsy and Bcurrent/Bmsy estimates are relatively sensitive to
assumptions necessary in the assessment process, but for the median over a range of
assessment models in the reference set that was used to test the current (2010) OMP,
the effective targets are above Bmsy for both M capensis and M paradoxus.
o The TRP will be subject to review with the development of the new OMP later in
2014.
Limit Reference Point
o LRP is currently fixed at the 2007 biomass for M paradoxus which is the lowest in
the time series.
Commercial CPUE
The stock assessment uses both commercial CPUE and biomass survey data.
An annual 2% increase in commercial CPUE catchability will be included amongst the
robustness tests for the 2014 OMP revision to allow for the possibility of technology creep.
OMP
2014 OMP Review
o The current OMP revision in scheduled for completion in September 2014. This
regular four-year revision provide an opportunity to review alternative stock
management models and their consequences for long term management of both the
risk to the stock and outputs from the fishery.
o It was noted that the outcome of the OMP revision would be an important
consideration in the ongoing MSC certification of the fishery.
Annual operation
o The operation of the OMP to determine the TAC for each year was discussed.
o The OMP, once agreed, allows a TAC to be determined on an objective basis using
updated information about stock status from monitoring indices (survey abundance
estimates and CPUE).
o The transparency to stakeholders and stability provided by the OMP is felt to be a
central component of the sustainable management of the fishery.
o The OMP revision process includes ongoing internal reviews by the Demersal
Scientific Working Group and also reviews of aspects of the process by an
international peer review panel (which meets annually, and will typically consider
hake-related issues on an average of one year in every two.).
Longline catch
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Longline length data since 2000 have recently been included in the assessments and have led
to a decrease in estimated spawning biomass (and also this biomass in relation to Bmsy) for
M. paradoxus in the 2013 assessment.
The longline hake fishery developed in the mid 1990s when vessels that had previously been
fishing for kingklip moved to hake when the directed longline fishery for kingklip was closed.
The fishery initially operated primarily outside areas fished by trawlers, and caught larger fish
than the trawlers.
The longline fishery is understood to be operating in difficult economic conditions at present.
Survey vessel
Africana has not been available for surveys since early in 2012. There is uncertainty about
future availability.
Commercial CPUE data show less variability and consequent have greater weight and
influence in assessment than the survey estimates of abundance; the same holds for the OMP
formulae.
Survey indices are required by the model and the OMP in future, and intercalibration between
the Africana and industry trawlers used for surveys is indicated; however this is not possible
if the Africana is unavailable, and in any case such direct intercalibration tends to yield high
variance results. It has thus been decided, in lieu of intercalibration studies, to include a prior
on the calibration coefficient which centred on 1 and has a CV of 0.169, based on an analysis
of inter-vessel variation in similar surveys in the eastern North Pacific. The OMP review will
consider future scenarios both with and without the Africana available.
Stock identity
The possible sharing the hake stocks of South Africa and Namibia has been under review.
Workshops will be held during the course of 2014 to develop greater clarity on this.
The outcome of these workshop and associated studies was not felt to be likely to affect the
SA stock assessment to a great extent.
The most likely of the scenarios possible is that the the Namibian catch of M. paradoxus
could be producing some effect on the SA M. paradoxus resource that is currently not taken
into account in the assessment.
Non-target species
The status of non-target species in the hake fishery was discussed briefly.
Kingklip
o A full assessment of kingklip is planned to be carried out later in 2014 or in 2015.
o The stock has most recently been assessed using a replacement yield model.
o The model indicates that stock status is improving for both west and south coasts
components of the resource.
Monkfish
o Monkfish stock status is assessed using a replacement yield model.
o Stock status is indicated to be stable or improving.
Silver Cob
o It was suggested that the team should discuss the status of the silver cob stock with
other workers.
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4. IMM Assessment Team Questions
Assessment team questions for stakeholders
Update on current stock status
The consequences of limited survey data for the stock assessment(due to the problems with
the Africana)
Discuss the procedure for review of the OMP in 2014.
5. Other issues
(e.g. any other stakeholders we should contact, any written submissions to follow?)
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17.1.5 OLRAC
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17.1.6 South African Deep Sea Trawling Industry Association (SADSTIA) and South East
Coast Inshore Fishing Association (SECIFA)
MSC Fishery Assessment Stakeholder Interview Record
Assessment Team Names
Lead Assessor Jim Andrews
P1 Team Member Mike Pawson
P2 Team Member Jim Andrews
P3 Team Member Johan Groeneveld
Meeting Location SADSTIA Offices, Cape Town, South Africa
Date 17th March 2014
Stakeholders Name Affiliation
Tim Reddell SADSTIA
Roy Bross SADSTIA
Irvin Esau Sea Harvest
Jon de Gouveia Echalar
Zuko Mgawuli Sea Harvest
Johann Botha Irvin & Johnson
Colin Attwood UCT – Scientist
Kobus Maritz Sea Vana / SECIFA
Craig Bacon Viking / SECIFA
Melanie Smith SADSTIA Co-ordinator
2. Status
What is the nature of the organisations interest in the fishery (e.g. client / science / management /
industry / eNGO, etc)
SADSTIA and SECIFA operate a representative industrial bodies for the hake trawling industry.
They are also Recognized Industrial Bodies in terms of Section 8 of South Africa’s Living Marine
Resources Act.
Regarding hake, the differentiation is historical and, in present day terms, largely an artifact of the
system of fishing rights. SECIFA derives from small boat (historically) multi-species activities
conducted within 60 fathoms of the shoreline that are now focused on hake. The deep-sea sector has
long been conducted with larger vessels, fishing almost entirely outside territorial waters. Fishing
rights in the deep-sea sector are of longer duration. There are no practical impediments to exercising
inshore hake trawling rights in the offshore sector provided such trawling is conducted under offshore
regulations. The inshore sector enjoys a nominal 7% of the combined hake trawl allocation.
However it is estimated that ±1.2% of trawled hake was caught inshore in 2013.
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3. Stakeholder Key Issues
What, if any, specific substantive issues or concerns are identified regarding the fishery? (P1 – P2 –
P3) and what information is available to allow us to determine the status of the fishery in relation to
each issue?
The key issues discussed during the meeting are summarised below.
Benthic survey work
Survey has been carried out using the DAFF research vessel Ellen Khuzwayo
Closed areas were established as part of the research project on 1st January 2014.
Skippers have been provided with comprehensive information about the location of the closed
areas including inputs on their MaxSea navigational systems.
DAFF have been informed of the location of the closed areas and are monitoring it with the
aid of the Department’s vessel observation facilities
Trawl ringfence
o It was confirmed that compliance with the ringfence was monitored for SADSTIA by
DAFF using its Vessel Monitoring System. There had been no transgressions of the
ringfence area since the last Surveillance. Such transgressions as occurred before
2013 have been successfully dealt with by action within SADSTIA.
o SADSTIA noted that the trawl fishery ringfenced area consisted very largely of soft
and gravelly bottom and covered a limited portion of the hake domain.
Benthic closed areas were discussed. The Benthic Task Team had looked at prospects for
establishing closed areas. The site selected for the trawl impact study had been chosen for the
dual purpose of assessing recovery from trawling and also the issues associated with
establishing protected areas. An additional MPA has been established in the inshore area in
the course of 2013.
Non target species
The management of the Precautionary Upper Catch Limits (PUCLs) for non-target species
was discussed.
o All retained species are governed by collective landing limits
o Deep-water species, such as Alfonsino, Grenadiers, Oreo Dories and Roughy are
controlled by small specific landing limits. Governing “prohibited unavoidable
species”
o Trawled Snoek is subject to a move on regulation
o Horse Mackerel, Kingklip and monkfish PUCL controls are an intrinsic part of the
permit conditions for the offshore fleet.
o Kingklip and Monk uptake is monitored on a monthly basis by external auditors
appointed by SADSTIA.
o Vessels and operators in the inshore area are engaged in an experiment to swap a
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range of “retained species” PUCLs to ensure that they remain compliant with
assessed limits.
o Kingklip PUCL uptake during 2013 was higher than expected; this contributed to a
(overdue) review of information about the stock by DAFF. The stock was found to
be in better condition than previously thought.
o SADSTIA consider there is no need to add PUCLs for other non-target species in the
offshore fishery. The PUCL for one retained species, Monkfish, falls on the 5% cusp;
all other retained species fall well below this threshold.
Inshore bycatch data are available since 1995 and research has been done to establish
temporal and spatial patterns.
PUCLs are being trialled voluntarily in the inshore fleet. As part of the trial all vessels had
signed up to a MoU to comply with the PUCL requirements voluntarily. Depending on test
outcomes, measures are planned to be introduced as licence conditions in 2016.
Patterns in bycatch from the offshore fleet for the period 2008-13 have been examined
recently. There are good landings data for the past 25 years for non-target species in the
offshore fishery.
Institutional and administrative arrangements
Scientific and compliance aspects of fishery management were working well.
Recent changes in senior personnel within DAFF were felt to have compromised progress
with decisions about resource allocation and management.
The procedure for allocating TACs in response to scientific advice was discussed. This has
been unaffected by recent changes at DAFF.
A procedure for improved synchronization of trends in assessed TAC and experiential catch
per unit effort was discussed.
The methodology for secondary controls by way of fishing effort controls (horse power sea
days) was also discussed. It was noted that existing effort controls amounted to a constant
effort regime under variable TACs.
Observer programme
SADSTIA are funding an independent observer programme, outsourced to Capfish. It is
budgeted to achieve 1,000 observer days per year. This is higher than the level of coverage
achieved previously by government. Largely thanks to focus on training the SADSTIA
observer programme gathers more information than the previous DAFF programme and it has
been more productive of scientific outputs including ongoing amendments to species splitting
algorithms.
Stock assessment
Two CPUE surveys have been carried out by the Andromeda, an industry vessel while the