The other day I was reading through the Rainer Froese and Alexander Proelß rebuttal (Is a stock overfished if it is depleted by overfishing? A response to the rebuttal of Agnew et al. to Froese and Proelss “Evaluation and legal assessment of certified seafood”) and found myself a little bewildered.
Teh purpose of the above rebuttal was to rebut the D. Agnew et al. article (Rebuttal to Froese and Proelss “Evaluation and legal assessment of certified seafood” published in Marine Policy (March 2013)) which stated that Froese & Proelß applied definitions of ‘overfishing’ that were inconsistent with internationally accepted definitions. The Agnew article was itself a rebuttal to an earlier article by Rainer Froese and Alexander Proelß (Evaluation and legal assessment of certified seafood)) that was also in Marine Policy (November 2012).
Yes I know… :S
Anyway… Froese & Proelß’s rebuttal is essentially defending its definition of ‘overfished’ and its interpretation of ‘overfishing‘ vis-a-vis ‘recruitment overfishing‘. They wrote:
“[w]hen stocks are below BMSY but above their respective limit reference points, they are considered to need ‘rebuilding’ and are regarded by MSC as ‘depleted’ (not ‘overfished’)”.
They then referred to an online dictionary and provided the following definition for depleted:
“weakened severely by removal of something essential”
So far so good.
However things begin to get murky when they start employing FAO definitions [which for other commentator would be a good place to start, but it seems not for Froese & Proelß]. They refer to the FAO Review of the state of world marine fishery resources where they illustrate that the Review:
“defines ‘depleted’ as “[c]atches are well below historical levels, irrespective of the amount of fishing effort exerted” and ranks it as a stock status between overexploited and collapsed. Thus, it seems that, according to this FAO definition, ‘depleted’ refers to stock sizes below the biomass limit reference point.”
Ummmm. No! The Review does not do that at all!
The FAO Review provides the following definitions (quoted):
- Underexploited Undeveloped or new fishery. Believed to have a significant potential for expansion in total production;
- Moderately exploited Exploited with a low level of fishing effort. Believed to have some limited potential for expansion in total production;
- Fully exploited The fishery is operating at or close to an optimal yield level, with no expected room for further expansion;
- Overexploited The fishery is being exploited at above a level which is believed to be sustainable in the long term, with no potential room for further expansion and a higher risk of stock depletion/collapse;
- Depleted Catches are well below historical levels, irrespective of the amount of fishing effort exerted;
- Recovering Catches are again increasing after having been depleted
First. I question the reference to “ranking”. The terms are merely listed in order of intensity of exploitation. From under-exploited to over-exploitation and then depleted and then to recovering.
Second. The FAO has not “[ranked depleted] as a stock status between overexploited and collapsed“. In fact the FAO did not provide a definition of ‘collapsed‘ at all after the definition of ‘depleted‘; instead they provided a definition of ‘recovering‘. Furthermore this definition of recovering expressly refers to a state of increase following depletion (so it is not a stock status between overexploited and collapsed at all).
It would seem with respect to FAO Review, Froese and friend are recounting fairy tales.
In pursuit of further point buttressing, Froese & Proelß jump to the Guidelines for the Ecolabelling of Fish and Fishery Products from Marine Capture Fisheries, (which state on page 8) that:
“The management system should specify limits or directions in key performance indicators, consistent with avoiding recruitment overfishing…”
They conclude that this suggests that:
“FAO considers stock sizes below the biomass limit reference point as “recruitment overfished”, i.e., the same definition as used by Froese and Proelss”.
Ummmm. No! The Guidelines don’t do this all!
I have said here [on this blog] on a number of occasions that context is everything. Well This is lost on Froese & Proelß. It seems that Froese & Proelß found a reference to “recruitment overfishing” in the FAO Guidelines for Ecolabelling and simply cut it and pasted it for use as a supporting premise to their already dubious definitional defence.
Who are these Guys? And what are they doing? I really am bewildered… They are publishing in Marine Policy!
The reference to page 8 of the FAO Guidelines for Ecolabelling is from the section entitled “MINIMUM SUBSTANTIVE REQUIREMENTS AND CRITERIA FOR ECOLABELS“. This section states somewhat expressly:
The following sets forth the minimum substantive requirements and criteria for assessing whether a fishery can be certified and an ecolabel awarded to a fishery. Ecolabelling schemes may apply additional or more stringent requirements and criteria related to sustainable use of the resources.
The Guidelines for Ecolabelling go on:
The requirements and criteria presented below are to be based on and interpreted in accordance with the current suite of agreed international instruments addressing fisheries in particular the 1982 UN Convention on the Law of the Sea, the 1995 UN Fish Stocks Agreement and the 1995 Code of Conduct for Responsible Fisheries…
Is it just me, or is this document deferring interpretations to other more authoritativeness documents?
If I am correct, and that the Guidelines are in fact deferring to other documents of better normative standing; then it would follow that the use of the Guidelines in a normative context for the purposes of deciphering interpretation, would result in any of the interpretative conclusions remaining subject to the interpretations provided in the documents to which the Guidelines for Ecolabelling showed deference .
Back to Froese & Proelß and their assertions! In particular the suggestion that the ‘requirement for eco-labelling systems to “specify limits or directions in key performance indicators, consistent with avoiding recruitment overfishing when assessing management systems“, somehow means that the “FAO considers stock sizes below the biomass limit reference point as “recruitment overfished”.
The reference that Froese & Proelß used to defend their position is eco-labelling criterion 29.2bis which wants “the determination of suitable conservation and management measures“; in particular measures in place that guard against “recruitment overfishing” and/or “other impacts that are likely to be irreversible or very slowly reversible, and specify the actions to be taken if the limits are approached or the desired directions are not achieved”
[Sounds very much like tha MSC Certification P1 component doesn’t it? In particular PIs 1.1.1, 1.1.2 and 1.1.3]
So what is my point?
My point is this… I am unable to see how my friends Froese & Proelß arrived at their point (the “FAO considers stock sizes below the biomass limit reference point as “recruitment overfished”), so I am not sure that others will either. At least I hope they don’t.
Froese & Proelß claimed in their first article (Marine Policy. Nov. 2012) that 31% of MSC stocks do not deserve their eco-labels because they are overfished. Well, as we have seen above, Froese & Proelß are not too handy at pinning down definitions, so I am not sure that I can take their MSC assertions at face value.
What did drive their conclusions I hear you ask? I can really only speculate, and assume that they took a formulaic approach, applying the following formula:
1+1 = 71APFVOC
- Can Fish Eco-Labeling be Trusted? An MSC Label Can!! Right? (greenfishbluefish.wordpress.com)
- MacD’s and the Marine Stewardship Council (MSC) (greenfishbluefish.wordpress.com)
- World Fisheries: are we managing an effective decline? (worldfishing.net)
- International guidelines take aim at illegal fishing – FAO (ghanabusinessnews.com)
- Overfishing in Indonesia? What do you mean: I don’t see any fishers! (newswatch.nationalgeographic.com)
- Farmed Fish Rise, While Wild Fish Remain in Trouble (blueocean.org)