Last week’s announcement of MSC certification of a portion of the Antarctic krill fishery attracted criticism from the Pew Environment Group. In particular, Pew questioned MSC rules that allow for the certification of a portion of a fishery; raised issues of how the needs of other dependent species were considered in the assessment process; and asserted that uncertainties with regards to the krill population and climate change should preclude certification. The MSC would like to address each of these concerns and clarify the MSC process as well as the krill assessment outcomes.
Assessing stock status and ecosystem impact
On the first point, Pew argued that certifying a part of the Antarctic krill fishery gives a “false impression” that the entire fishery for Antarctic krill is sustainable. The fact is that an MSC fishery assessment, regardless of the portion of participants in the fishery seeking certification, must assess the status and management of the entire fishery under consideration. In the Antarctic krill assessment, conducted by a team of three scientists, the known size of the overall krill resource in the fishing area is officially estimated at 37 million tonnes (with other estimates suggesting it might be as high as 208 million tonnes) [NB in late 2010, this biomass figure was changed to 60.3 million tonnes by CCAMLR]. The current harvest levels of krill –150,000 metric tonnes in 2007/08– is just four per cent of the allowed quota, and less than one per cent of total estimated krill biomass for the area. Given these very precautionary harvest numbers, the assessment report concludes that the current catch from the entire fishing fleet in the area is at sustainable levels.
In addition to reviewing overall stock status and management, the MSC assessment process looks at the impacts of the fishery on the ecosystem in general, and at the impact of Aker Biomarine’s vessel and fishing techniques in detail. Having met the MSC standard against all principles, the Aker operation became certified.
Going forward, only product caught by the Aker vessel can use the MSC label, and even then, can only do so when and if each company in the supply chain that handles the certified krill products has gained an MSC “Chain of Custody” certification. This traceability requirement for making an MSC claim or using the label addresses the concern raised by Pew that all Antarctic krill may be seen or sold as MSC-certified.
Leadership, transparency and consultation
MSC specifically allows certification of a portion of a fishery to enable leaders to move forward without requiring every player in the fishery to agree in advance. In this case, through the leadership of one company voluntarily seeking certification to the MSC standard, the assessment process enabled significant issues to be raised by stakeholders and the assessment team, which were considered in a transparent fashion and which resulted in agreements for specific actions to be taken as conditions of the MSC certification. These conditions are designed to lead to improved understanding and ability to manage key sustainability concerns. They include:
- Condition 1 requires, within one year of certification, to further test the catch limits in place on the fishery to improve understanding of the impacts on krill and other associated species.
- Condition 2 requires the fishery to assess the risk that catches of larval fish are too high and, if too high, implement measures to reduce the level of larval fish catch. This risk assessment must be completed within two years from certification and if management measures are needed, these must be implemented within four years from certification.
- Condition 3 requires that the client provide information to assist the ongoing development of management measures that further reduce the risk of significant localized depletion of krill and, if needed, to implement appropriate measures within four years of certification.
Without the leadership towards independent certification by Aker Biomarine, these commitments to improve knowledge of the krill fishery would not necessarily have been forthcoming, although the fishery would have continued. This demonstrates why the MSC program allows portions of a fishery to move forward with MSC assessment.
Protecting predator species
Another point Pew raised was the concern that certification would pose a serious threat to penguins, seals, whales and other Antarctic animals that depend on krill to survive. We agree wholeheartedly with our Pew colleagues that this is a top priority issue, and MSC’s assessment process is designed to take these issues directly into account.
In this case, the Commission for the Conservation of Antarctic Marine Living Resources (CCAMLR) came into being at least in part to address concerns that an increase in krill catches in the Southern Ocean could have a serious effect on populations of krill and other marine life; particularly on birds, seals and fish, which mainly depend on krill for food. The 25 governments of CCAMLR that regulate the krill fishery have adopted a precautionary approach to minimize risk and to ensure that the food requirements of dependent predators are not jeopardized by fishing removals. To this end overall quota determinations specifically take into account the needs of dependent predators. The independent assessment team considered the adequacy of these controls and concluded that the existing management framework ensured that harvesting was well controlled and that the needs of dependent predators were allowed for.
Breadth and rigour of scientific assessment
Pew asserted that the certifier ignored irrefutable evidence put forward by prominent Antarctic scientists. Yet the evidence put forward by these prominent scientists was in fact a significant contribution that strengthened the outcome, which is how the MSC process is designed to work. Rather than being ignored, the concerns raised and reviewed produced a significant new condition in the outcome.
The assessment report cites an extensive body of literature (100+ references to scientific publications and other articles) that were reviewed by the independent experts that undertook the assessment. Many of the articles reviewed are published by prominent Antarctic scientists. The information reviewed by the assessment team represents a full spectrum of views ranging from those that support sustainable use of the krill resource through to those advocating that all fishing in the Antarctic should cease. The experts reviewed this literature during the initial scoring, in response to comments provided by stakeholders and peer reviewers and in initial consideration of information submitted during an objection to the krill certification.
Accounting for uncertainty and monitoring change
Finally, Pew raised a critical point with regards to uncertainty. The MSC system recognizes that there are levels of uncertainty in all natural systems and most certainly in fisheries, and the issue is how well managers deal with and account for uncertainty. Uncertainty is manifest over very different time and spatial scales and similarly ecosystem responses to changing levels of productivity can also be observed over different temporal (from annual to decadal) and spatial (from localized to ocean-wide phenomena) scales. Climate change will impact at wide spatial scales and ecosystem responses will trend over decades. The MSC program requires that controls in place to limit catch should be consistent with ecosystem productivity and recognizes that as productivity changes so to should these controls. Additionally, the MSC program also requires an annual, scientifically-rigorous, transparent surveillance audit to ensure that the conclusions of the assessment and the performance of the fishery remain valid, and these audits provide a mechanism to address unanticipated change in an agile manner.
In dealing with a subject matter of tremendous complexity, Marine Stewardship Council certification continues to be the world’s most rigorous, science-based, third-party process to certify wild capture fisheries. The MSC standard and many of the elements of the program have been developed with the significant involvement of business, the fishing industry, environmental stakeholders, scientists and concerned citizens, all working together. Dialogue and debate are an essential element of a good certification program and we welcome continued scrutiny of the program and its outcomes by all interested stakeholders. The world’s oceans and marine life matter to us all and it will take everyone together to make sure they are healthy and sustainable in perpetuity.