Responding to the latest update on the Good Fish Guide
The Marine Conservation Society (MCS) has published it’s updated Good Fish Guide. This consumer-focused online guide gives ratings to various seafood species based on environmental impacts of how they are caught or farmed.
Our response to the updated Good Fish Guide
In response to the latest updates to the Guide, our Director of Operations Aoife Martin said:
We acknowledge that sustainable fisheries management is vital to secure fish and shellfish stocks for future generations. Assessments like the Good Fish Guide are helpful to consumers, but they must be based on the most accurate and up to date information.
Our Fisheries Management team provided feedback to MCS on the proposed ratings. Now that the latest version of the Guide has been released, and we can see the final scores we are concerned that some fisheries have been rated too harshly.
We know that good work is already underway in the UK, with industry stakeholders and regulators collaborating on the sustainable management of economically important shellfish and finfish fisheries. This includes the shellfish management groups, which bring together industry, government, and researchers, and various Fishery Improvement Projects. The Guide does not appear to take account of this activity and the positive impact it can have on stock sustainability.
Our feedback on changes in ratings for some species
We welcome the opportunity to engage in the Good Fish Guide review process and we provided comments and feedback on some ratings.
We highlighted that recent evidence on spotted ray in the North Sea shows that the stock biomass is broadly stable, and that fishing pressure has reduced considerably in recent years. This resulted in the proposed rating of 5 (‘fish to avoid’) being changed to 4 ('needs improvement’).
However, there are some fisheries (including Scottish brown crab and lobster, and English Dover sole) where we had hoped that our feedback would lead to revised scores. Unfortunately, this has not been the case. A consistent concern is that the ratings do not reflect that there is already active management underway across many of the fisheries that were awarded a red rating.
There are a range of reasons why the size of a fishery can fluctuate. Sometimes it is because there is too much fishing, but it can also be due to biological or environmental factors. Regardless of the exact cause, when it happens it is vital that action is taken to help the fishery rebuild. This action will rarely result in a fishery being closed outright, fishermen will still be able to catch fish but in much smaller volumes, until the fishery is back at healthy levels. We do not agree that a fishery that is being actively managed should be listed as ‘fish to avoid’; rather it should be an ‘Ok choice’ because we know that the required improvements are already underway.
Details of our feedback can be found at the link below and a summary of the key points follows.
- We shared information on the management measures in place, from Shetland to Cornwall, to improve the sustainability of our crab and lobster fisheries. These include (1) increases to the minimum landing size which helps ensure that crabs and lobsters can reproduce before they are caught, (2) measures to limit the number of pots in use which reduces the number of crabs and lobsters that a fishing boat can catch, and (3) restrictions on the number of days that a fishing vessel can be at sea to reduce overall fishing effort.
- We acknowledged that entanglement of whales in static gear is an issue that affects marine conservation, animal welfare, and fisher safety. However, we also highlighted the work of the Scottish Entanglement Alliance which recently published a report on the scale and impact of cetacean entanglement and the mitigation measures that can reduce interactions. The best available scientific data suggests that entanglements of minke whales in potting gear in Scottish waters is an extremely rare event (0.017% of the total North Atlantic minke whale population is likely affected annually). Industry is actively working to reduce these interaction’s further, including working with marine mammal experts to learn how to safely disentangle a cetacean. We consider that inclusion of Scottish brown crab and lobster on the “fish to avoid” list on this basis is likely too severe given the scale of the impact and the mitigation work underway.
- We recommended that the score for English Dover sole fisheries should reflect that, while the health of the sole stock is not at optimal levels, there are active management measures in place to ensure it rebuilds to a healthy level. The MCS scoring methodology means that management is scored as inappropriate or ineffective if the stock is not considered healthy – there is no acknowledgement that the stock is being rebuilt.
- We shared details of some of the research that is underway across our shellfish fisheries. While this research has not yet concluded, it should inform the scoring of these important fisheries in future editions of the Good Fish Guide.
- We also note the proposed red rating for North Sea monkfish. Previously we submitted on the proposed rating for North Sea monkfish and we demonstrated that a 5 rating was not correct on the basis of management actions being taken. We are disappointed that a red rating has now been applied to North Sea monkfish. While the recent stock assessment has shown a fall in biomass, we know that biomass reached a historic high in 2017, and that the actual size of the stock remains in line with the long-term average and catches have been in line with scientific advice. Reflecting this reduction in biomass, new management measures have reduced the catch limit by 20%, so there are management measures in place to ensure the long-term sustainability is maintained. In 2019 we supported the industry to complete a Fishery Improvement Programme pre-assessment. This outlined the future management priorities for the fishery which will include establishing methods to assess the status of both monkfish species. The fishery is expected to enter into a full FIP later in 2022. Other positive aspects which the rating does not take account of is the low discard level in the fishery. We are concerned that when assessed in full the available evidence does not support a 5 rating.
A copy of our full response to the consultation on MCS ratings review is available to download below:
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