The science of sustainable seafood, explained

MSC certification scrutinized again, this time over Orange Roughy. We spoke to two experts about it.

The Marine Stewardship Council (MSC) certification is being scrutinized again, this time with Australia’s eastern zone orange roughy fishery. The determination for this fishery was scheduled to be in July, after the Conformity Assessment Body (CAB) MRAG Americas Inc. produced a 226-page scoring and assessment report, concluding: “following client, peer, and public review, and review and decision by a qualified individual within MRAG Americas, we have determined that this fishery should be certified as sustainable against the MSC fishery standard.” The fishery was recommended by MRAG for certification without any conditions, meaning that it scored very well compared to the standard.

However, the news was understandably met with scrutiny from conservation groups, particularly the Australian Marine Conservation Society (AMCS) and the World Wildlife Fund Australia (WWF). Both groups have now objected to the certification.

The MSC’s standard requires stakeholders to engage and raise issues early in the process in order to provide the CAB an opportunity to fully consider any objections. After 9 months of silence, WWF and AMCS raised objections controversially late in the acceptable time window. Without precedent, an independent adjudicator ruled that these late objections would be considered. After the ensuing 15-day working period failed to find a resolution between the eNGO’s and the fishery, and tedious legal proceedings could follow.

Orange roughy have remarkably long lifespans, sometimes spanning 100 years or more. They do not reproduce until reaching about 30 years old. This late reproductive cycle and a long life history makes population recovery slow. It also means orange roughy can only withstand very low fishing mortality rates, making them particularly vulnerable to overfishing.

After aggregations of orange roughy were first targeted in Australia in 1989, overfishing is exactly what occurred. The fishery management authority at the time, the Australian Fisheries Service, allowed catches to increase in the eastern zone to an unsustainable 35,000 tons. By 1994 allowable catches were dropped to 4,000 tons and then 2,000 tons in 2003. In 2008 all stocks were listed under the EPBC Act as conservation dependent, the lowest level of concern, but still reflective of orange roughy’s ongoing recovery. While some orange roughy stocks remained healthy and had not been subjected to heavy fishing pressure, other stock status was uncertain and, in some cases, assessed as being at less than 10% of their unfished level. (Bax et al. 2006)

These life-history characteristics and the legacy of mismanagement in the fisheries’ earliest years are the backbone of the arguments against the pending MSC certification. Bottom trawling impacts on sensitive benthic habitat like seamounts, where orange roughy congregate and are targeted during the winter breeding season, were also cited by AMCS. In an interview with the Australian Broadcasting Corporation (ABC), AMCS spokesperson Adrian Meder accused MRAG Americas of copying and pasting exact passages from another report on blue grenadier into the Australian orange roughy assessment, suggesting the entire process was unsound.

But unlike eastern Atlantic bluefin tuna, which officially received its first MSC certification this summer with no precedent for MSC approval, orange roughy has been an MSC certified species in New Zealand since 2016. The New Zealand orange roughy fisheries were discovered around the same time as their Australian counterparts, and the same concerns of slow reproduction, historical overfishing, and sensitive benthic habitat were all addressed four years ago. Of course, there was environmental NGO criticism back then too, but New Zealand orange roughy has been a stable fishery, expecting to maintain its certification when it gets re-evaluated in 2022.

To better understand the criticisms against Australian orange roughy’s bid for MSC certification, we spoke with Simon Boag, Executive Officer of the South East Trawl Fishing Industry Association (SETFIA). We also spoke with Dr. Malcolm Haddon, a quantitative biologist with the government research agency CSIRO and updated the stock assessment of orange roughy in Australia’s Eastern Zone in 2018.

Boag: When I began working on the Australian roughy fishery in 2009 the Eastern Zone total allowable catch (TAC) was approximately 25 tons. All the fishing grounds deeper than 700 meters were shut and only enough quota was available for occasional unavoidable bycatches..

At this time we partnered with The CSIRO and developed something called an acoustic optical system, which is a net-towed, multi-frequency device that takes sonar images of fish, orange roughy, but very close to them. So rather than having the device on the hull, 700 meters above, they now have it down on the headline of a net and you might only be 50 meters from the fish, providing very reliable estimates of stock size.

Over the course of a few years, CSIRO completed several surveys using this device that revealed very large numbers of orange roughy and ultimately informed an increase in the TAC to approximately 250 tons. On our most recent survey we found 42,500 tons of orange roughy, so about 10 million fish, on just two hills—and that is just a single stock of four or five. This is a lot of fish for a fishery that’s meant to be extinct.

Opponents of this potential MSC certification have argued that: orange roughy are too long-lived to be harvested sustainably, trawl gear used to harvest roughy will harm sensitive benthic habitat, and more fishing exclusion zones are needed. How would you respond to these criticisms, beginning with the long-lived nature of this species?

Boag: The fishery engaged an external MSC assessor to examine all of these concerns, and they scored the fishery highly concluding no conditions were required. That determination was then peer reviewed by three other experts not related to MRAG in any way, and also peer reviewed by MSC’s technical staff, and finally the entire process of this assessment was overseen by an organization called ASI who define standards and license CABs (MSC assessors). So, this assessment had more scrutiny on it than probably any fishery in the history of the MSC, yet it scored almost perfectly with no need for conditions. With regard to habitat, very little orange roughy habitat has ever been trawled and huge amounts are protected by closures and marine parks.

We have seen huge and regular recruitment. Additionally the Australian system manages the fishery at a relatively high biological limit reference point, so there is still only a very small, conservatively set, rebuilding TAC. Current catches are less than 4% of what they were at the peak of the fishery.

Haddon: Based on the evidence that we have in terms of age, the stock has recovered above the limit reference point that is part of the Australian harvest strategy. That point is 20% of the estimate of the unfished biomass, which is a very common reference point throughout the world. At the moment, even with the worst possible projections, Eastern Zone orange roughy is not below that point. So, I think I can defensibly argue against that notion that it has not sufficiently recovered.

That percentage (20%) is a bit arbitrary because the depletion level which is most productive, in theory, is quite low for orange roughy. What this means is that a maximum economic yield (MEY) would actually be achieved if we harvested more of the stock than we are presently, to drive the population down a bit more to a point where they are most productive. The value of not fishing the stock to that lower, albeit more productive level, is that if something changes unexpectedly and the stock depletes, it will be boosted by an increased productivity level, thus providing some added resilience.

What about the impacts of bottom trawling on benthic habitat like seamounts?

Haddon: A good deal of orange roughy fishing is midwater trawling. In other words, they don’t want to touch the bottom. The best way to fish for roughy is to target the spawning aggregations. But you don’t want to put your gear through that, you’ll fill up and potentially break gear or lose it. The good fishers – and we’ve got some good ones in this fishery – they fly their gear in and just scoop up the top, just take the edge, and they don’t actually fish the bottom. Unfortunately, the AMCS and other eNGOs tend to be using old information on some of these criticisms.

Boag: We have maybe 30 stern trawlers give or take, operating in this fishery of which six four are engaged in targeting orange roughy. With great respect to their operators they are the most underwhelming fishing boats you’ve ever seen. So, we have a very small industry, using very small vessels towing very small nets with most grounds closed .

How do you respond to calls for more MPAs or fishing exclusion zones as tools necessary to properly manage this fishery?

Boag: There are only two hills in the eastern zone subjected to orange roughy fishing effort. Almost the entire fishery is still shut. Seabed mapping data shows that in the entire fishery from 3 miles, which is commonwealth waters, to 1,000 meters deep, we are only ever fishing 6% of the fishery with trawl nets. If we were to introduce a new MPA to the existing 388,000km2 network it would need to be a very small one because there isn’t much fished bottom around left in which to place it.

Haddon: This is the easiest criticism to address because there are closures. Most waters deeper than 700 meters are closed to fishing in Australia. They have opened up a few areas for particular species, but those open areas have been selected to avoid areas of concentration for things like orange roughy and in particular, deep-water sharks. So, there are already very large areas which are closed. Even the eastern orange roughy fishery which has been opened for about 5 years now, their fishing effort is restricted to particular seamounts and other very small, specific areas. Everywhere else is shut. There are lots and lots of closures.

There seems to be a discrepancy in the stock recovery timeline and the life history of orange roughy which are said to not reproduce until about age 30. How has the stock seemingly recovered ahead of schedule?

Haddon: What you’re going to realize is because they don’t mature until around 30 years, we are still experiencing unfished recruitment levels. For 30 years prior to the fishery, orange roughy were spawning without any fishing mortality. The population would have been going up and down a bit naturally, but we killed off all the sperm whales and various other species that would have eaten roughy, (not many species eat roughy) so the stock would have been at a fairly high level and they all would have been spawning merrily away, doing their thing.

So, there was 30 years-worth, at least, of unfished recruitment going on. We’re still getting that entering the fishery in the year 2020 because the fishery has not been around that long. Where the intuitions go wrong, I think, is that people say, “well look, you knocked this stock down to a very low level, less than 10%, how can we possibly get enough recruits out of that to recover the fishery as of today?” It’s because we’re not dealing with those recruits, which would not have been enough to recover the stock in this time frame. What is entering the fishery is still effectively unfished recruitment levels. You have to get your head around these long time lags to understand what is happening. It’s wild stuff. The recovery rate does not surprise me because it is recovering at the rate an unfished stock would recover.

What, if anything, gives you cause for concern about this fishery?

Haddon: We must project this long time lag into the future in our management strategies. Irrespective of what life history characteristics of the stock you put in or what catches of the stock you put in, in around 2028, there is a very slight dip in the recovery:

The predicted spawning biomass for orange roughy in Australia’s eastern zone projected for 55 years. Natural mortality rates of 4% (the blue and black lines) and 3.6% (the red and green lines) were both illustrated to account for multiple potential scenarios.
The predicted spawning biomass for orange roughy in Australia’s eastern zone projected for 55 years. Natural mortality rates of 4% (the blue and black lines) and 3.6% (the red and green lines) were both illustrated to account for multiple potential scenarios.

The reason it is only a slight dip and not a precipitous one, is on the way there, the stock passes through its most productive state, which I described earlier. But this dip you see is because of the massive hole in the spawning biomass that marks the beginning of the commercial fishery and high fishing effort. At that point we will no longer be seeing pre-fishery recruits entering the fishery. It is completely expected, but the timeline on these graphs go all the way out to 2070. Managers must stay vigilant and patient.

The green line is the essence of my concern. In that projection the stock goes down and continues to go down. Managers have to be careful to consider this dip in production in about 5 years from now and steer the fishery away from the green line in these graphs. That will be challenging as the productivity of the stock increases slightly before going down, and the value of the fishery potentially increases from an MSC certification.

I’m hoping the MSC certification has included a precautionary approach. If they have, I would cease worrying so much.

What might this certification do for orange roughy in domestic or international markets?

Boag: The Australian community right now, more than ever, wants to eat Australian food. Australia imports 80% of its seafood. More than ever Australians want Australian food.

Our two largest supermarket chains here in Australia, Coles and Woolworths, have shown increased support recently for local fish. As soon as the pandemic happened, Coles in particular began selling local fish. I think the Australian community is starting to question the broken record “doom-and-gloom donation model” pedaled by some environmental NGOs. Consumers are wising up, and the supermarkets are wising up to the reality that our fish stocks are generally in great shape.

All Australian consumers should look at this potential orange roughy MSC certification as a huge success and as a source of pride. I am 48 so I was in high school when orange roughy was overfished, all the fishery managers around me and all the stock assessment scientists too – we weren’t here, none of the people involved in the fishery today were involved in the fishery when it was overfished in the past. All we can do is try to fix what we have been left with, and we are doing that with low TACs, lots of monitoring, lots of science, lots of precaution.

Haddon: Orange roughy is a relative luxury good. Our fish and chips are what they call “gummy shark”, its common and cheap – I do not consider roughy cheap. Roughy get the best market, frankly, in the US. In the US, you can’t sell to the big stores without having MSC certification. So, I’m not sure if you will see an influx of orange roughy domestically in Australia if this certification is approved.

But I think that is appropriate. I actually do think orange roughy can be sustainably fished, as long as the management is firm enough. If that is done properly then it will always be a luxury item. You are never going to get a massive fishery again that will drive the price down. It should be a valuable fishery, but never a big one.

Jack Cheney

Jack Cheney

Jack has sourced, sold, cooked, and sustainably certified seafood over the past 9 years. In addition to his contributions to Sustainable Fisheries UW, he is working to connect chefs with US fishermen to create more value for both ends of the supply chain. He earned a Master's in Marine Affairs from the University of Washington in 2015.

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