Fisheries Research 100 (2009) 185–190

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Eco-certification of sustainably managed fisheries—Redundancy or synergy? Peter A. Shelton ∗ Science Branch, Department of Fisheries and Oceans, 80 East White Hills Road, PO Box 5667, St John’s, NL, Canada A1C 5X1

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Article history: Received 30 June 2009 Received in revised form 20 August 2009 Accepted 20 August 2009 Keywords: Sustainable fisheries management Eco-certification Maximum sustainable yield Reference points Ecosystem approach Fisheries governance Stock rebuilding Eco-labeling Traceability Sustainability standards

a b s t r a c t There is an increasing global awareness of the consequences of overfishing and the need to implement sustainable fisheries management practices. The traditional custodians, governments and regional fisheries management organizations, have been slow to react creating a niche for environmental and non-profit groups to become increasingly active through eco-certification and sustainability ranking programs. While both the traditional and the new players tend to share a similar approach based on maximum sustainable yield reference points, they differ in scope and delivery mechanisms. The potential exists for confusion with regard to who should be determining whether a fishery is sustainable with the cost of possible redundancy being ultimately borne by the public. However, there is also the potential for synergy and, given the limited progress thus far with respect to achieving sustainable fisheries by traditional means, perhaps both are needed for the time being—a “belt and braces” approach. © 2009 Elsevier B.V. All rights reserved.

1. Introduction Societal interest in sustainably managed wild capture fisheries has increased over the last 20 years as a consequence of growing concern regarding the finite limits of the Earth’s ability to feed an increasing human population and recognition that valuable renewable food resources, such as marine fisheries, can be depleted through over-harvesting and inadequate management. Governments and regional fisheries management organizations (RFMOs) are increasingly emphasizing sustainable fisheries management in policy documents, but effective implementation of these policies is often lagging. The United Nations Food and Agriculture Organization reports that 30% of the world’s fisheries are now over-exploited or depleted (FAO, 2009). The Commission of the European Communities has stated that, for the 43% of European fish stocks for which the status can be determined, only 32% are inside safe biological limits, overfishing is taking place in 88% and 19% are in such bad state that EU scientists advise that there should be no fishing (CEC, 2008). In the U.S., 26% of 173 stocks or stock complexes for which overfished status can be determined are overfished and 21% of 188 stocks or stock complexes for which overfishing status can be determined have overfishing taking place (NMFS, 2009). In New Zealand, for 629 stocks currently under quota management,

∗ Tel.: +1 709 7722341; fax: +1 709 7724105. E-mail address: [email protected]. 0165-7836/$ – see front matter © 2009 Elsevier B.V. All rights reserved. doi:10.1016/j.fishres.2009.08.004

stock status can be determined for 101 stocks and of these, 29% are below their respective management targets (NZ Ministry of Fisheries, 2008). The situation for Canadian fish stocks cannot be reported here because public records of the number of stocks being fished, number being scientifically assessed, and their sustainability status are not available. However, for 25 northwest Atlantic fish stocks managed under the Northwest Atlantic Fisheries Organization, there is sufficient information to determine status for 17 stocks. Of these, 36% are collapsed and only 16% are considered to be safe (NAFO, 2007). This widespread failure of traditional governance structures to successfully implement sustainable fisheries management policy has created a niche for environmental non-governmental organizations (ENGOs) and other non-profit groups to play a significant role. They have become increasingly active in drawing public attention to unsustainable fishing practices around the world and bringing pressure to bear on governments and RFMOs entrusted with fisheries management to implement more conservation-minded and sustainable measures. More recently these campaigns have broadened to include a focus on producers, retailers and consumers through processes such as eco-certification, eco-labeling, endorsement and ranking of sustainably managed fisheries and products derived from these fisheries. It is too early to say what impact this will have in terms of achieving a greater degree of sustainability, but it is certainly increasing the pressure on governments and RFMOs to sharpen policies and to begin implementing sustainable fisheries management.

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Policy on sustainable fisheries management is becoming much more explicit and is being expanded to include ecosystem and governance considerations. Monitoring and public reporting on the number of sustainably managed fisheries are improving and explicit management strategies incorporating harvest control rules are being developed, tested, and more broadly implemented than previously was the case. This is largely a response by governments and RFMOs to international agreements, undertakings and codes of conduct on sustainable fisheries as well as the societal demand for sustainable fisheries. However, recent pressure by ENGOs and other non-profit groups may also be encouraging governments and RFMOs to shore up their traditional roles as arbitrators of societal good, rather than having this authority second-guessed or even usurped. While both groups have similar goals, the mechanisms for achieving sustainable fisheries are very different. One works through a political process to achieve the best compromise between exploitation and conservation whereas the other directly targets human values with regard to what is good and what is not through social conscience and the market place. This could lead to redundancy, with society paying twice, once for a belt and once for braces, to ensure that the sustainability trousers stay up. If governments and other management bodies are already meeting sustainability objectives, why do harvesters and processors have to pay the potentially high cost (eventually passed onto the consumer/taxpayer) of getting a second seal of approval to convince the resource owners (civil public) that all is well with their property and that the leaseholders (fishing industry) are living up to their legal obligations? In some cases, differences in definitions and standards may lead to contradictory outcomes and confusion. In other cases the two processes may work synergistically to achieve what neither process may be able to achieve by itself—fisheries that actually are sustainably managed for long-term public good, and which are seen to be so. In this article I discuss these two approaches for achieving sustainable fisheries with regard to defining sustainability, establishing standards and delivery mechanisms. Consideration is given to the degree of redundancy on the one hand and potential for synergy on the other. Ultimately society will determine, either through votes and taxes or in the market place, how much sustainability it wants, how much it is prepared to pay to get it, and who is going to deliver it.

2. Defining sustainability Sustainability has been an elusive notion widely touted by governments and politicians as the justification for a diverse range of actions. Shelton and Sinclair (2008) have attempted to narrow down the definition in a fisheries context by reviewing the theoretical basis and considering current national and international policy and agreements with regard to the management of capture fisheries. While in theory a fishery can be considered “sustainable” over a range of stock sizes and harvest rates (fishing mortality), only those fisheries that meet clearly defined management targets most of the time and avoid limits nearly all of the time should be considered sustainably managed. Generally these targets and limits have been defined in single species terms and are in relation to maximum sustainable yield (MSY), the biomass consistent with MSY (BMSY ), and the harvest rate or fishing mortality that achieves MSY (FMSY ). Although not without complications related to uncertainty in stock assessments and variability in stock productivity over time, single species MSY-based definitions of sustainability are the most widely used in determining standards for sustainable fisheries management.

In addition to single species considerations, there is increasing emphasis on adopting an “ecosystem approach” to the management of fisheries (EAM; FAO, 2003, 2008). The term is beginning to achieve a politically correct cachet rivaling “sustainable” and surpassing it in convenient vagueness. In practical terms, the ecosystem approach has thus far translated into a limited number of management measures such as protected areas to safe-guard vulnerable habitats and threatened species, limits on overly destructive fishing practices and attempts to restrict by-catch of non-target species. Theoretically, a multispecies or ecosystem approach would dictate more conservative targets and limits than those defined under single species management (Shelton and Sinclair, 2008), a realization that may not have fully permeated the thinking of fisheries managers and industry. Because ecosystembased sustainability objectives have not yet been clearly articulated for most fisheries, lack of progress relative to the currently more explicit and measurable MSY-based definition of sustainability may be obscured by emphasizing purported “progress” relative to vague ecosystem objectives. The pragmatic approach to EAM addresses the traditional target species MSY objectives in addition to broader characteristics of the fishery (by-catch, benthic disturbance, etc.). In this regard, achieving a fishing mortality less than FMSY on constituent species being fished is tangible and would be a very good step towards an ecosystem approach to fisheries (Mace, 2001). A sufficient definition of sustainability proposed by Shelton and Sinclair (2008) is a fishery in which the stock is fluctuating around BMSY or above under a fishing mortality which is, on average, less than FMSY , or a fishery on a stock which is depleted below the range of normal fluctuations around BMSY but which is being managed to rebuild to the vicinity of BMSY or above with a high probability within a specified and acceptably short period of time by setting F well below FMSY . Whether or not this definition is met can be determined for most stocks for which analytical assessments are feasible and where there is adequate data contrast to determine functional relationships related to productivity of the stock. In other cases there may be sufficient data to develop scientifically defendable analytical or conceptual proxies for MSY reference points and these could be used while striving to obtain better data. For cases where not even proxies can be determined, it could be argued that to proceed with commercial scale fisheries without any measure of sustainability is being unacceptably risk-prone and irresponsible with regard to public property and such fisheries should be postponed until scientific assessments of sustainability become feasible. Although arguably providing a sufficient definition of sustainability, this does not specify how it is to be achieved. It is widely accepted that international best practice is to develop predetermined management strategies that specify the stock status data to be considered and the harvest control rules (HCRs) to be applied to link management actions (such as changes in total allowable catches or TACs) to the data (FAO, 1995). Furthermore, it is generally suggested, although not yet common practice, that a management strategy should not be accepted until the HCRs have been evaluated with regard to robustness in achieving low risk of breaching limits and high probability of achieving targets. Unfortunately, uncertainties with regard to both estimates of reference points and current state and productivity of the stock could detract from applying HCRs in this manner. Use of reference points as performance statistics in a management strategy evaluation (MSE) provides an alternative approach which is arguably superior. In MSE, the performance of feedback harvest control rules, which respond to the perceived state of the stock, but not necessarily the state of the stock relative to the estimated MSY reference points, is evaluated through simulation with regard to the “true” state of the stock and the “true” reference points (where “true” refers to the actual values without error determined within

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a computer simulated fishery termed the “operating model”). A management strategy that does not perform well on a simulated fishery is unlikely to perform any better on a real fishery. Only those management strategies that ensure a low risk of transgressing limit reference points and high probability of meeting targets and rebuilding depleted stocks would be candidates for further consideration by decision-makers in terms of sustainable fisheries management. The MSY-based definition of sustainability may be considered insufficient by some ENGOs and non-profit groups concerned with improving not only the management of commercially exploited fish stocks, but also the ecosystem as well as a range of governance aspects. While broader ecosystem and governance considerations should certainly augment MSY-based approaches, they should not be allowed to detract from the primary need to first meet basic sustainability requirements related to MSY.

3. Establishing standards Various standards for sustainably managed fisheries have been developed or are under development by governments and RFMOs, and more recently by ENGOs and non-profit groups. While they tend to share a common genesis in the United Nations Fish Stocks Agreement, FAO Code of Conduct for Responsible Fisheries and other international agreements and guidelines (Shelton and Sinclair, 2008), they differ in rigor, detail and comprehensiveness. Arguably the best developed government standard is the New Zealand Harvest Strategy Standard (NZ Ministry of Fisheries, 2008). The U.S. also has an established standard and maintains a Fish Stock Sustainability Index to measure compliance which is updated quarterly. In the case of ENGOs and non-profit groups, the Marine Stewardship Council (MSC) claims to have the only global environmental standard for sustainable and well-managed fisheries, although prominent and well developed regional or national frameworks also exist, such as the Monterey Bay Aquarium’s Seafood Watch ranking system which is widely applied in North America. The NZ Standard provides a consistent and transparent framework for setting fishery and stock targets and limits and associated fisheries management measures to ensure a high probability of achieving targets, a very low probability of breaching limits, and acceptable probabilities of rebuilding stocks that nevertheless become depleted, in a timely manner. There are three core components: (i) a specified target about which a fishery or stock should fluctuate (MSY-compatible reference points or better); (ii) a soft limit that triggers a requirement for a formal, timeconstrained rebuilding plan (1/2 BMSY or 20% B0 (unexploited biomass), whichever is higher); and (iii) a hard limit below which fisheries should be considered for closure (1/4 BMSY or 10% B0 , whichever is higher). The NZ Standard is compatible with an MSE approach. The three core components together with the associated acceptable probabilities provide performance measures which can be used in evaluating alternative management strategies. The U.S. Magnuson-Stevens Fishery Conservation and Management Act, as amended in 1996 by the Sustainable Fisheries Act and again in 2007 by the Magnuson-Stevens Fishery Conservation and Management Reauthorization Act of 2006, emphasizes the need to end overfishing, rebuild overfished stocks, and establish fisheries management plans (designed to ensure biologically and economically sustainable fisheries). The Act requires NOAA’s National Marine Fisheries Service (NMFS) to report annually to Congress and the eight Regional Fishery Management Councils on the status of fisheries. Revisions to the National Standard 1 Guidelines provide guidance on annual catch limits and other requirements of the Act (U.S. Department of Commerce, 2009). The NOAA Fisheries Office of Sustainable Fisheries maintains a Fish

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Stock Sustainability Index (FSSI) with respect to compliance with the Act and provides a quarterly public update based on the results of the most recent scientific assessments of stock status (URL: http://www.nmfs.noaa.gov/sfa/statusoffisheries/SOSmain.htm). FSSI is calculated by assigning a score (indicated in brackets) for each fish stock or stock complex based on five criteria: (i) “overfished” status is known (0.5), (ii) “overfishing” status is known (0.5), (iii) “overfishing” is not occurring (1.0), (iv) stock biomass is above the “overfished” level defined for the stock (1.0), and (v) stock biomass is at or above 80% of the biomass that produces maximum sustainable yield (BMSY ) (1.0). The maximum score each stock may receive is thus 4. The value of the overall FSSI is the sum of all individual stock scores. The default threshold for “overfished” is 1/2BMSY and for “overfishing” is FMSY . The MSC Sustainability Standard recognizes that a sustainable fishery should be based on three principles: (i) maintenance and re-establishment of healthy populations of targeted species, (ii) maintenance of the integrity of ecosystems, and (iii) development and maintenance of effective fisheries management systems including compliance with relevant local and national laws and standards and international understandings and agreements (MSC, 2002). Methodology developed to score a fishery against the MSC standard has been subject to criticism that it afforded too much flexibility to the certifying bodies, leading to variable and inconsistent assessments (Nick et al., 2008). In response MSC has introduced a revised certification methodology that is more prescriptive and explicit (MSC, 2008). Numerous performance indicators grouped under each of the three principles are scored by an assessment team through a partially subjective consensus approach. An assessed stock can be judged to meet the standard unconditionally, to meet it under specific conditions that have to be addressed, or to fail. The methodology identifies 1/2BMSY or 20% of B0 as a default biomass limit, considered to be above the point where there is an appreciable risk that recruitment is impaired, and BMSY as a default biomass target (or higher if this is warranted from a consideration of the trophic inter-dependencies of the target species or in order to decrease the probability that biomass will drop significantly towards the point where recruitment becomes impaired). Suitable proxies for the target and limit are considered acceptable. Risk tolerances are specified with respect to meeting the target and avoiding the limit to assist in scoring. Consideration is given to whether or not there is a management strategy in place incorporating harvest control rules that ensure that harvest of the target species is maintained within sustainable levels consistent with a precautionary approach. MSC recently introduced a new “Risk Based Framework” as an addition to the standard assessment methodology that can be used in certain well-defined instances where there is not enough data available about a fishery to follow the regular heavily data-based standard assessment methodology (MSC, 2009). Seafood Watch of Monterey Bay Aquarium, has developed a standard for capture fisheries evaluation (Seafood Watch, 2006) that incorporates the following five guiding principles to determine a sustainable fishery: (i) a low vulnerability to fishing pressure, and hence a low probability of being overfished, because of inherent life history characteristics; (ii) stock structure and abundance are sufficient to maintain or enhance long-term fishery productivity; (iii) fish are captured using techniques that minimize the catch of unwanted and/or unmarketable species; (iv) fish are captured in ways that maintain natural functional relationships among species in the ecosystem, conserve the diversity and productivity of the surrounding ecosystem, and do not result in irreversible ecosystem state changes; (v) a management regime exists that implements and enforces all local, national and international laws and utilizes a precautionary approach to ensure the long-term productivity of the resource and integrity of the ecosystem. In Canada this stan-

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dard is applied under the SeaChoice program. Sustainability criteria have been developed to support the application of the principles in order to evaluate capture fisheries and develop seafood recommendations for consumers and businesses. Evaluation of factors under each of the criteria results in an overall colour ranking of red, yellow or green for a fish species. Consumers are encouraged to purchase seafood from the “best choices” (green) species because these fisheries are deemed to be sustainable. “Good alternatives” (yellow) are suggested in preference to species from the “avoid” (red) category, although concerns are voiced that yellow species do not demonstrate all of the qualities of a sustainable (green) fishery as defined by Seafood Watch. Primary factors evaluated to determine stock status are size of the population size relative to BMSY and fishing mortality relative to FMSY . It is evident that there is a lot of commonality in the standards adopted by governments and ENGOs. MSY-based reference points are universal, although treatment of risk may differ. Some other differences also exist. There is greater emphasis by ENGOs and nonprofit groups on ecosystem and governance considerations and consequently their frameworks tend to be more complex, possibly to the point where these considerations could obscure the need to meet the basic fish stock sustainability criteria first (MSY related or better). With regard to resolution, governments and RFMOs tend to address the sustainability status of defined geographic fish stocks comprising a single species within a specified geographic area, but which may be fished by a number of different gears. ENGOs and non-profit groups may look at sustainability with respect to a particular gear type on a stock or a subcomponent of a stock on the one hand (MSC) or group the fisheries for several stocks and gear types for the same species (Seafood Watch/SeaChoice) on the other hand. Governments and RFMOs have been somewhat coy in the past about communicating which fisheries are not in a healthy state, but this is improving as shown for example by the quarterly updates of the sustainability index in the U.S. Some non-profit groups are also not very forthcoming, presumably in order to maintain the support of various components of the fishing industry. For example, all information related to pre-assessment for certification under the MSC process is confidential. Consequently there is no public disclosure of those fisheries that are judged unlikely to meet the MSC standard and therefore do not go forward to full assessment. All, or nearly all, fisheries that go forward with full assessment for certification are successful although conditions may be imposed for ongoing certification. Seafood Watch and SeaChoice on the other hand openly advertize “red” species which should be avoided because they have failed their sustainability standard. Government standards such as those applied by the U.S. and NZ are also clear with regard to which fisheries fail to meet the criteria and therefore are not sustainable. Under the MSC standard, depleted fisheries can still be deemed “sustainable”, or conditionally sustainable, on the basis of efforts being pursued to rebuild them, even if there is not much tangible evidence that these efforts are being successful. Further, some fisheries judged to be sustainable under the MSC standard may only just meet the requirements and there may be inadequate emphasis on further performance improvement with regard to achieving MSY targets or better. 4. Delivery mechanisms Different approaches for delivering sustainable fisheries exist within traditional management bodies such as governments and RFMOs, compared to ENGOs and non-profit groups newly engaged in eco-certification and endorsement of sustainable fisheries. Governments and RFMOs consider the biological, social, economic and political landscape and the cajoling of lobbyists and other pressure groups to try to negotiate politically acceptable compromises that satisfy both the fishing industry and perceived public wellbe-

ing. In the past, emphasis has tended to be on short-term tactical problem solving (fighting fires) through the implementation of a sequence of ad hoc measures rather than longer term strategic planning for sustainable fisheries. However, pressure on governments and RFMOs to live up to international agreements and to start delivering on undertakings regarding sustainable fisheries and rebuilding depleted stocks, together with increased societal awareness, is changing the landscape and strategic management plans are being developed and are starting to be implemented. ENGOs and non-profit groups are not in the negotiating game—they appeal directly to public sentiment to do the right thing in order to make the world a better place for ourselves and those that follow. They coerce people to question what it is we are eating, where it comes from and what the impact is on the ecosystem to get it from the ocean to the plate. They helpfully provide the correct answers to these questions. Their main strategy is communication. If they have a just cause and a good communication strategy, they gain public support which can be used to lever the supply chain all the way down to consumer, and even governments and RFMOs, to conform to their standard. Building public trust in an eco-certification or ranking process is essential if it is to be successful. This requires clear standards that are supported by experts and which are consistently and objectively applied through a transparent process. Fisheries that meet the standard need to be clearly identified, either through an ecolabel or through publicly accessible rankings. Fisheries that do not meet the standard should also be identified. Because there is no political recourse through a democratic process, the public (resource owners) need to be given the opportunity to contest the determinations of ENGOs and non-profit groups. In this regard, MSC has been criticized for providing only a limited and costly objection mechanism (Greenpeace, 2009). To complete the circle, the provenance of the fish being purchased and consumed must be clear so that it can be traced all the way back along the supply chain to a point of origin in a sustainably managed fishery using a particular fishing gear type, on an identified taxonomic species caught within a clearly demarcated geographic location. Provenance cannot easily be determined without government regulation, quality control and auditing. It is common currently to find fish products in restaurants and grocery stores that are marketed under a variety of misleading names with little indication of the actual species, whether wild or farmed, geographic location of capture or fishing gear used. Even worse, low priced fish or overfished species may be deliberately mislabeled as higher priced or sustainably managed species by purveyors. For example, Wong and Hanner (2008) used DNA barcoding to show that 25% of 96 samples of fish and seafood muscle tissue acquired from commercial markets and restaurants in north eastern North America (both Canada and the U.S.) were potentially mislabeled. Globalization of the fishing industry complicates the problem. A species may be captured in the EEZ of one country by a trawler registered in a second country, only to be landed in a third country and then shipped to a fourth country for processing and finally marketed around the world under a variety of vague and potentially misleading product names. Clearly an eco-label that provides reliable provenance to guarantee that a product is from a fishery in which overfishing is not occurring and from a stock of an identifiable species that is not overfished, would be a major step forward, and probably essential, for achieving sustainable fisheries on a global scale. Given that fisheries are one of the most highly traded resources, it is doubtful whether traceability along the supply chain can be accomplished without international agreements along with national regulation, quality control and auditing to ensure compliance. This is too big and important a job for governments to download on ENGOs and non-profit groups. Governments and RFMOs do not require the same level of public trust. In a healthy democracy it is reasonable to question and

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even mistrust government. Instead the public relies on the constitution and legislation of countries and the conventions of RFMOs to limit the powers of these bodies to legal or convention-compliant means. In addition, international agreements and codes of conduct define best practice and fear of potential embarrassment at a high international level favors compliance. Despite constitutions, legislation, conventions, and guidance on best practice, there is often scope for considerable discretionary powers in governments and RFMOs which provide “flexibility” in the way fisheries are actually managed, mostly to the detriment of sustainable fisheries and long-term public good. Regulations for achieving sustainable fisheries are usually imposed and enforced by governments and RFMOs, often against an unwilling and uncooperative fishing industry—compromises generally do not please anyone and cuts to fishing quotas are never popular with the fishing industry. ENGOs and non-profit groups can please mostly everyone nearly all the time. They do not impose and they do not enforce. They use incentives to achieve compliance by providing an attractive badge of honor though an eco-label or ranking score which is expected to lead to enhance brand awareness, increased competitiveness and other market advantages. CEOs of large corporations can hold press conferences to announce their eco-achievements and consumers get to feel good about their ecofriendly choices. Sustainable fisheries management of overfished stocks invariably requires certain short-term economic losses with only an unknown probability of these losses being offset by longer term gains. Further, these gains tend to accrue outside the normal planning horizon of governments and corporations and are commonly devalued by applying high economic discount rates. As a consequence, lost value through forgone future opportunities caused by depleted and non-rebuilt fisheries are seldom accurately accounted for in arguing to delay implementation of sustainable fisheries management. Eco-certification has the potential to change the balance by improving market share and revenue streams making sustainable management more profitable in the short-term. How far these benefits of eco-certification can accrue beyond affluent first-world communities has yet to be established. A large proportion of the world’s population would happily settle for a no-name brand piece of fish caught using a blast of dynamite, as long as it is edible and fills you up, and can they be blamed? Governments and RFMOs generally have either in-house expertise or established standing committees of experts to deliver regular high quality scientific analysis and advice on sustainable fisheries management options through a peer-review process. Costs are covered from the public purse and by RFMO convention dues. ENGOs and non-profit groups have to buy what expertise they can afford. Status reviews and certification or ranking costs are paid for by public or corporate donation and by components of the supply chain desirous of certification. Costs can be high. Even non-profit organizations have overheads and an expanding global presence can have considerable infrastructure costs. If an independent third party certifier is engaged to facilitate the process, the price can double or triple because these are typically consulting companies seeking to maximize profit and they have to offset the costs of hiring experts to assist them because of limited in-house capacity. The quality of analysis and review may suffer if cost is an issue and although an objection procedure may be provided late in the process, this may not compensate for more rigorous and open expert analysis, debate and independent review at an earlier stage. While both delivery systems have merit, a publicly funded system governed by legislation, regulations, conventions and codes of conduct may seem to be the most logical approach to managing public property for long-term public good. The reasonable role for ENGOs and non-profit groups would be the traditional one of carping and criticism to keep the traditional fisheries manage-

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ment bodies honest, rather than trying to do the job themselves. However, the poor performance and lack of transparency of some governments and RFMOs has resulted in deterioration in public trust, creating an expanded niche for ENGOs and non-profit groups. For the time being the public are being asked to pay twice for sustainable fisheries, but government downsizing to reduce budget deficits, for example Program Review in Canada (Treasury Board of Canada Secretariat, 1997), may be shifting more of the burden to the private sector and ENGO pathways as federal services are downsized. Government enforcement of fisheries regulations is costly and frequently fails. The poor optics of mismanaged fisheries and the high cost of enforcing regulations that have only limited success may be hastening this shift. However, the cost of managing fisheries for long-term public good must be compared with the lost opportunity costs of depleted stocks and unsustainable fisheries, the “sunken billions” (World Bank, 2009). Increasingly governments would rather advise and regulate self-managing entities from a distance instead of being held directly accountable. The idea of “stewardship” where the main “stakeholders” are given long-term transferable resource access rights so that they have an inherent incentive to not “muck it up” has generally been the preferred route for downloading government responsibility as direct custodians of public good, but eco-certification may also look like an attractive opportunity “to pass the buck”, thereby making life easier for traditional fisheries management authorities. A more positive view is that eco-certification may create the opening governments and RFMOs have been looking for in order to move forward on the implementation of stalled sustainable fisheries management policies. 5. Conclusion There is no question that sustainable fisheries are of paramount importance to all concerned. Both traditional forms of fisheries governance and the new and emerging process of eco-certification, eco-labeling and ranking can facilitate the achievement of sustainable fisheries. The question is, do we need both? For the time being we have to argue “yes”. Traditional measures have been slow to deal with the enormity of the problem. Although some fisheries are being rebuilt through concerted efforts of governments and RFMOs with co-operation from the fishing industry, and others have a history of sustainable management, yet others are becoming newly depleted. There is little doubt that the 2002 Johannesburg World Summit on Sustainable Development promise to try and rebuild fish stocks to BMSY by 2015 is largely a hollow one. Marine fish populations are being added to endangered species lists every year. Populations of the iconic bluefin tuna are in jeopardy on both sides of the north Atlantic. While there are some notable successes achieved by traditional means, such as the Pacific halibut fishery, fisheries governance needs all the help it can get. There is redundancy in ENGOs and non-profit groups second-guessing governments and RFMOs, but it is the synergistic side of the equation that needs to be emphasised. Yes, we need belt and braces to keep the sustainability trousers up, at least for the time being. References Commission of the European Communities, 2008. Fishing Opportunities for 2009: Policy Statement for the European Commission, Brussels, 30.5.2008. Com(2008) 331 final. URL: http://eur-lex.europa.eu/LexUriServ/ LexUriServ.do?uri=COM:2008:0331:FIN:EN:PDF. Food and Agriculture Organization of the United Nations, 2009. The State of World Fisheries and Aquaculture 2008, URL: http://www.fao. org/docrep/011/i0250e/i0250e00.HTM. Food and Agriculture Organization of the United Nations, 2003. Fisheries Management-2. The Ecosystem Approach to Fisheries. FAO Technical Guidelines for Responsible Fisheries, vol. 4 (Suppl. 2), URL: http:// www.fao.org/docrep/005/Y4470E/Y4470E00.HTM.

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