Trevor J. Ward PhD
Institute for Regional Development,
University of Western Australia, Perth, Australia
August 2001
| The views expressed in this report are those of the author and do not necessarily represent the views of the New Zealand Ministry of Fisheries |
Trevor J. Ward PhD
Institute for Regional Development,
University of Western Australia, Perth, Australia
August 2001
Classical fisheries science-the approaches, assumptions, models, and data requirements-are only partly relevant to assessing and responding to the environmental impacts of fishing. While there needs to be a continued emphasis on development of better fisheries models and science to assist with meeting the needs generated by specific environmental issues, better fisheries science is only part of the solution to the issues confronting New Zealand's fisheries and management system.
Modern scientific approaches are increasingly moving away from classical reductionist procedures and models (such as those used in much of fisheries science) towards more holistic procedures that are specifically designed to cope with knowledge gaps, vast uncertainty and great limitations of existing data and knowledge. Reductionist science/models are still crucial, but they alone cannot solve complex environmental issues-synthetic and integrated approaches and tools are required to be able to properly admit broader classes on concerns, information and data to the fisheries management system so that issues of sustainability (defined to include the broad ecological and socio-economic impacts of fishing, not just stock maintenance) can be effectively addressed.
There are no jurisdictions that have fully resolved these problems, but some are making good progress. Here I propose the establishment of a Fisheries Environmental Management Strategy for New Zealand (NZFEMS) that would operate within the framework of an Environmental Management System for MFish. While there are various possible approaches, an appropriate framework in this circumstance is the ISO 14000 system. Using this framework leads to the design of a NZFEMS that has a number of new structural elements set within the context of existing procedures within MFish, using procedures based on the concept of strategic risk-assessment and ecosystem-based management, and on activities aligned with modern business practice.
To meet the objectives of an EMS, and to properly address the responsibilities of MFish flowing from the Act, the NZFEMS will need to develop and maintain innovative decision support approaches and tools, broad stakeholder participation and acceptance, and should be based on outcome-oriented objectives, indicators, decision criteria, targets, monitoring systems and performance assessment.
To achieve such outcomes, the NZFEMS should consist of:
The NZFEMS should be designed so that it is closely integrated with existing stock assessment processes-stock assessment and management to achieve environmental objectives is one key aspect of the NZFEMS. Nonetheless, the NZFEMS will need to be publicly accountable, comprehensive, flexible and responsive, because these are the attributes that will enable it to be effective and efficient in dealing with the many challenges that will arise.
Modern fishing management systems are increasingly under pressure to recognise the potential for environmental impact of fishing activities, and to avoid or minimise these impacts (for example, arising from obligations to comply with international conventions and agreements-Tsamenyi and McIlgorm 1997). However, unlike management of fish stocks, where issues can be reasonably defined and objectives clear, environmental issues appear to be diffuse, hard to define in specific terms, and can appear intractable. Some of this difficulty relates to the history of scientific research, which is much greater in fish stock management than in environmental management, but much also relates to nature of the issues themselves, many of which are confounded by the lack of a common and agreed understanding of the detailed responsibilities of a modern fisheries management system.
As in all contemporary business systems, there is a growing awareness and acceptance of the need to broadly demonstrate that the fisheries sector operates in an environmentally responsible manner, and that specific assessment and reporting systems needed are in place (Leadbitter et al. 1999). And where environmental problems do occur, it is necessary for fisheries managers to have in place an adequate framework to be able to identify and correct such problems before they reach a level that will affect the viability of the fishery or the sector as a whole, as well as the environment.
To some extent, the concerns about fisheries management relate to the rising awareness of the nature of wild harvested resources in general, and the potential for the wild resources to be depleted beyond any reasonable condition. Managing such natural resources 'sustainably' is of increasing public concern, given the general view that these resources are held in common by governments on behalf of the public. This concern has tended to be exacerbated in these times of increasing commercialisation, corporatisation and even privatisation of government assets that had been previously owned and managed by governments for the benefit of the public at large. In such circumstances, it becomes important to ensure that there is a coordinated, and indeed integrated, approach to fisheries management to ensure that the many other matters of concern to governments and the public beyond fish stocks alone are adequately incorporated into any responsibilities and arrangements for managing fisheries.
This report is a brief overview of selected overseas experiences and the scientific literature, and summarises contemporary views of fisheries environmental issues. With this as background, this review identifies an approach and the scope of a strategy that could be used to manage fisheries environmental issues in New Zealand, and identifies some of the key elements of this strategy that will assist to meet the environmental obligations of the Ministry of Fisheries.
The Terms of Reference for this 5-day desk-top review are:
There are three main classes of environmental concerns about the effects of fishing (leaving aside the shore-based issues such as ports, harbours, or processing facilities):
Research studies indicate that fishing has impacts on population size, population structure, on fecundity and spawning biomass, on average age and size of individuals, and many more. Of course, some of these are the direct result of targeted fishing activities and are intentional alterations to fish populations, or at least cannot be avoided if fish are to be taken out of the population by a fishery.
Fishing efficiency is often considered in terms of productivity of the harvest stock, and fisheries systems attempt to maximise, for example, yield per recruit, depending on the approach taken to stock assessment. Such management objectives have the effect of changing the basic characters of the population being fished (such as reducing the maximum age in the population, and increasing the mean growth rate of individual fish). While this is an entirely appropriate objective for a stock objective to meet efficiency goals, from an environmental perspective, fishing efficiency is more likely to be considered to be the efficient use of the fleet to harvest the environmentally acceptable quota of fish in the manner considered to have the least environmental impact. In this environmental setting, efficiency considers the use of fossil fuels, socio-cultural context, fish population characteristics, etc, not the relatively simple concepts of fish productivity coupled with return on investment, or profit, or other stock-specific attributes. In essence, the major difference between an environmental perspective and a fishery (narrow) perspective of the management of a fishery is a different set of objectives that are being sought for achievement, and then within those, a different set of targets that may be considered to be optimum. The difference in these approaches is also evident in the nature of science constructed to support fisheries management. Much fisheries research, is, for example, focused on optimising biomass production.
The basis for different approaches is, in part, a different perception of the responsibilities of the fishing sector. In New Zealand, these responsibilities are relatively clearly set out in the Act, and range broadly rather than narrowly. In this sense, an impact of fishing on fish stocks would probably need to be assessed on a range of population attributes that are consistent with the interpretation of the Act and within the broader responsibilities to meet international conventions as expressed within the Act. For example, this might mean that, for the target species of a fishery, the genetic structure of the population, the size/age structure of the population, the range of habitats and areas occupied by the population, and capacity to respond to specific threats to the population from climate change, all might be used as indicators to determine if the population was being acceptably maintained. It is clear that fishing will reduce biomass in the population from what might be considered to be a benchmark natural level (sometimes referred to as 'virgin biomass') to levels much lower, often to less than 30% of the benchmark level. To meet stock management objectives, this might not be assessed as adversely affecting the population (i.e. the population is 'maintained'), but if the 30% of biomass consists of all small fish, with the larger individuals being fished down to very low levels, then this might be considered to be an unacceptable reduction in the diversity of the population from an environmental perspective. Such matters are of environmental concern because of the potential they have for affecting population viability in the face of a changing ocean climate, or an extreme El Nino year, and, specifically, the substantial reduction in the genetic diversity of the fish population. Such arguments are often used to support the case for closed areas, where samples of an otherwise exploited population may be able to behave, grow and reproduce 'normally' (Ward et al. 2001).
Wild and unfished populations of fish represent the benchmark against which the effects of fishing on the target species are usually evaluated. In order to make such an assessment, information on the unfished populations of the target species are needed. And, in general, similar forms of information are also needed for conventional fisheries modelling purposes-knowledge of parameters such as natural mortality rates, or growth rates. However, as now increasingly recognised (Jennings and Kaiser 1998), much of the knowledge used in fisheries models is derived from populations that have been long fished before scientific assessment, thus adding an additional envelope of uncertainty to parameter values and stock assessment outcomes. Also, recent analyses suggest that fishing has preceded all other forms of human degradation of coastal ecosystems, and hence all contemporary benchmarks for ecosystems (including fish populations) are mere 'ghosts' of what they once were (Dayton et al 1998, Jackson et al 2001).
Overall, while it may superficially appear that the management of populations of target species for fisheries purposes satisfies the requirements for sustainability, in practice, this is not necessarily the case. Similarly, management of fishing for improved efficiency, and to attain specific production objectives, is not necessarily in accord with the ecological objectives for maintaining populations, and economic efficiency can be opposed to ecological responsibility. Nonetheless, some of the ecological objectives may be met using specific tools already used (or available) within existing management systems, such as space and time closures, spatial allocation of effort, and gear design to reduce catch of under- or over-sized individuals. Perhaps the biggest difficulty will be in adapting existing stock assessment models and systems to predict and explore the potential success of management changes to meet environmental objectives because environmental objectives are hard to express in terms that can be easily incorporated into existing management.
3.2 Impacts of Fishing on Non-target Species
The act of fishing usually results in catch of species that are not the target of the fishing gear or fishing activity. While much of the non-target catch may be inconsequential from a fisheries perspective (although bycatch reduces fishing efficiency), in a responsible environmental management system such bycatch may have ecological consequences for the populations of species caught, or may have other consequences for the fishery. This is particularly true where the bycatch species are large, are formally protected by legislation or convention, or are otherwise high profile 'icon' species.
Non-target species may be affected by fishing in many different ways; they may be caught in the gear during the fishing operations simply because they are co-located with the target species and cannot sense and avoid the fishing gear; they may actively seek out fishing operations to seek bait, offal or trapped prey, and they themselves may become trapped in the gear; or they may simply be attracted to the fishing operation, say because of lights at night, and by accident become caught on a vessel or in gear.
While many such species can be released from gear entanglement etc, if they are released alive, the survival rate for most is highly dependent on at-sea practice, and high mortalities are suspected for many such releases.
The effects of fishing on non-target species is closely related to gear types, on fishing practices and on specific avoidance technologies. This is the area of fisheries management where most effort has been invested in recent years, and most jurisdictions have developed bycatch action plans and strategies, and these are generally being propagated into the level of fisheries. Also, there is much active development and testing of gear that will behave in a specific manner to avoid bycatch species, and given acceptance by fisheries, it is assumed that such developments will be adopted. Experience though suggests that gear technology that is designed to reduce bycatch (or assist with other environmental improvements) will have limited voluntary uptake in a fishery unless it also has demonstrated benefits for improving catch of the target species, or reducing costs etc. Improvements in the NSW prawn fishery have been generally adopted, but an 'environmentally friendly' scallop dredge has been ignored because although it reduced impacts on benthos it also reduced scallop catch rates.
The effects of a fishery on 'icon' species is perhaps the most difficult issue for a fishery to deal with. Generally, bycatch is not conducive to efficiency, no matter how expressed. But capture of highly valued species (mammals, birds) is an emotive issue and ecological and efficiency parameters are not the only criteria used to determine if impacts on these species are acceptable within a sustainably fishing system. Here, public opinion is crucial to the success of the fishery in maintaining an image of sustainability. For example, a fishery may not be able to operate and avoid bycatch of all seals. While a small number of seal deaths caused by the fishery may not be of ecological consequence, the public perception may be different, and here different criteria may be applied in judging if a fishery is 'sustainable'. Issues like these are common in many fisheries, and other than public education, there are few tools available to manage such matters. This doesn't mean that a fishery should resort to an advertising campaign, rather, it should move to more inclusiveness in its strategic planning, and adopt an management approach that befits a modern natural resource management system. This might include more transparency and accountability, and more involvement of stakeholders in decision making in the fishery (Hall 1996, Cortner and Moore 1999).
Overall, unless they are imposed, bycatch programs will not always be effective, in terms of fishery uptake, given the direct interaction with catch and efficiency in the fishery. This problem is enhanced because current approaches are relatively narrow in their scope, mainly based on changes to gear technology and the use of existing tools and approaches. Modelling systems have not yet developed to the stage where they can accommodate a range of alternative approaches that might achieve a similar set of outcomes for the fishery overall.
3.3 Impacts of Fishing on Habitats and Ecosystems
Fishing has a range of unintended consequences on habitats and ecosystems. These fall generally into two classes: direct effects and indirect effects.
3.3.1 Direct Effects
Gear that makes contact with benthic habitats (trawls, dredges) has the potential to create a major ecological impact. The nature and extent of that impact depends on the type of gear used, the way in which it is used, the frequency with which it makes contact with the habitat, and the sensitivity of the habitat to the removal of susceptible species or disturbance of the substrate. The importance of these types of effects can only be determined on a case-by-case basis, although some gear types are potentially more damaging than others. For example, baited traps are generally considered to be less damaging than demersal trawls. But this is a generalisation that is hard to sustain given the different ways in which these two gear types can be used. Setting traps on coral reefs may be more environmentally damaging than directed trawls that cover only small proportion of a habitat type like the open sandflats between coral reefs. Making judgements about such effects requires a detailed set of criteria, considering scales of space, time and impact, and ecological knowledge of the habitats. The consequence of this is that even apparently low impact gear types (such as hook and line) may have serious consequences for species that can withstand only minimal additional mortality (there may be excessive fishing effort with the gear type; or the species affected may be of low natural abundance, may be depressed by other activities, or by other components of the fishery sector). Conversely, non-selective gear if used in a very selective way can be reasonably non-destructive. This may even apply to gillnets and demersal trawling under certain conditions and circumstances.
Perhaps the most well publicised recent example of gear impact is the trawling of sea mounts. Here species of deepwater coral and other species that are considered to be endemic (localised to the region) and very slow growing appear to have been damaged by trawls that contact the surface of the seamounts. Given the relative uncertainty about recovery of the habitats, Environment Australia has recently declared a Marine Protected Area over a field of seamounts off Tasmania. While it is unclear about how effective this strategy is likely to be ('locking the door after the horse has bolted'), the implications of such issues for fisheries management is clear: where biodiversity is highly valued very great care will be expected from the fisheries management system. If well designed environmental systems are not put in place by a fishery, controls on access to the areas or resources may be imposed from outside the fishery management system, and such controls may not be as supportive of the fishery as they might otherwise expect.
3.3.2 Indirect Effects
Perhaps one of the most difficult and value-laden issues is the impact of fishing on dependent and associated species. In this context, dependent and associated species are those that are linked to the target species (or the habitats where the fishery operates) in any way. This includes for example, species that may prey on the target species, and effectively compete with the fishery for a share of the fish stock. But it also includes species that are eaten by the target species, or are otherwise affected by their presence. For example, fishing for reef fish changes the nature of reef ecosystems where they live, because the removal of fish changes the natural abundances of algae and urchins that also live on the reefs-an indirect effect known as the 'cascade' effect. While these effects are most studied in coastal reef habitats (Jennings and Lock 1996), they are also likely to occur in all habitats where a fishery operates. For example, gill nets and long lines will have indirect effects on pelagic ecosystems by removal of the target species, removal of bycatch species, and through the cascade effects on dependent and associated species.
The conundrum of the indirect effects issue is that to maintain all the ecosystems in their 'natural condition' would mean no fishing at all. Even determining what a natural condition is for any specific habitat (or species) is a daunting ecological challenge, because, inter alia, all such systems are dynamic, and change is normal and to be expected, and there are no robust benchmarks (see Jackson et al 2001). So, if fishing is to exist, some level of indirect effect has to be accepted by the community and stakeholders. The issues are intensely value-laden because there are no clear-cut benchmarks for the levels of acceptable change in habitats or ecosystems, there are few models that can be used to estimate what the nature and extent of such change might be, and lastly, there is an implication that finding out about such things is a hugely expensive task that fisheries might find themselves solely responsible for.
Despite these realities, there are precedents and initiatives in areas other than fisheries where similar types of problems confront managers. Given the many types of uncertainty (sensu US EPA, 1998) and errors that are associated with assessing the effects of human disturbances at a range of scales, managers have turned to risk-based models as an approach. In terms of constructing benchmarks and targets for ecosystems, habitats and species, there is a world-wide move to base judgements on the conditions in protected areas, and indeed proposals to dedicate protected areas for such purposes (see eg Ward et al. 2001). Using sanctuaries or historically unfished areas as benchmarks, and adaptive management procedures, it appears that fisheries may be able to adjust their activities to reflect the expectations of the public by incorporating environmental objectives and targets derived by estimation from areas that have no, or little, history of fishing.
In response to the perceived impact of fishing, and the public concern over fisheries management issues in general, jurisdictions have developed the following classes of management response.
4.1 Structural reform
This includes overhaul of fisheries legislation, and in some case environmental legislation to deal specifically with fisheries environmental issues. Examples include the Magnuson-Stevens Fishery Conservation and Management Act 1996, and the California Marine Life Management Act, of the USA; Australia's Fisheries Management Act 1991; and the Environment Protection and Biodiversity Conservation Act 1999 of Australia. The focus of these reforms has generally been to improve fisheries management by separating the functions of regulation and management of fisheries, and to improve their stock management, ecosystems focus and environmental protection aspects. Other (associated) changes are the creation of new agencies, such as the California Fisheries and Game Commission, and the Australian Fisheries Management Authority, charged with the responsibility of introducing and managing the environmental changes and obligations expressed in the respective Acts.
4.2 Functional integration and coordination
In recognition of the multidisciplinary nature of the issues surrounding the environmental impacts of fishing, and recognising the diverse responsibility for resolving the issues, jurisdictions are attempting to achieve better coordination and even integration across their activities and responsibilities. Amongst many other examples, the difficulties resolving issues in the Northwest Atlantic fisheries have highlighted the need for more integrated and systematic approach to managing fisheries (Halliday and Pinhorn 1997). A common theme in the natural resources management literature is the need for 'ecosystem management' (see for example Harwell et al. 1996). Nonetheless, it is also being now recognised that the solutions cannot be driven by science alone, and for management to be successful in such a complex working environment, it needs to be take full account of multiple sets of interests and values, involve stakeholders, and to shift incentive structures (Bissix and Rees 2001, Cortner and Moore 2001).
Australia is well advanced in this area: after a decade of debate surrounding a National Strategy for Ecologically Sustainable Development in fisheries and a National Strategy for Conservation of Australia's Biological Diversity, the federal government designed and in 1998 adopted Australia's Oceans Policy, expressly concerned with, inter alia, integration of environmental concerns and fisheries management (Ward et al. 1997). The Policy is now being implemented as a series of Regional Marine Plans, although as yet the process seems not highly effective or efficient. Following this, The EP+BC Act was designed and invoked in 1999 in order to bring fisheries (export fisheries, where the federal government has a clear jurisdictional role) to be assessed for their environmental sustainability. This Act requires assessment of each export fishery against principles and criteria similar to, and modelled on, those of the Marine Stewardship Council. Key initiatives in the EP+BC Act are performance assessment against various environmental requirements, public input to assessment criteria, and a public review phase for all fisheries seeking to be accredited under the Act.
4.3 Fishery level activities
The most important fishery-level initiative in Australia has been the development of Management Advisory Committees (MAC) for designated fisheries. The MACs are the main vehicle for "a partnership approach which actively involves a range of interested parties, including fisheries managers, scientists, industry, environment/conservation agencies and other stakeholders, in the process of developing and implementing fisheries management arrangements through the establishment and continued operation of Management Advisory Committees (MACs) for each major Commonwealth fishery" (see <www.afma.gov.au>). While the MACs are primarily for Commonwealth and joint Commonwealth-State managed fisheries, the concept is increasingly being introduced into State managed fisheries as well. The basic intent is to constructively engage the various interests in the fishing community to improve the decision-making within the fishery management system. Recently the MACs have also begun to appoint conservation stakeholders in an effort to broaden out the basis for the strategic planning for the fishery, and to secure reliable input on conservation and environment issues. Similarly, the MSC has required the Western Rock Lobster fishery to provide increased participation of the conservation community in its internal decision making processes at a range of levels in the fishery. Both initiatives appear to be functioning well, although it is as yet early. Other activities include the implementation of Fisheries Environmental Reviews (in Western Australia) and accompanying management plans to identify and address key environmental issues within a region. Many jurisdictions have fisheries powers to declare areas as reserves for fisheries purposes, and this is being actively considered, although the strategic basis for reserve design and implementation is lagging (Ward et al. 2001).
4.4 Fishing gear and practices
Some environmental issues have prompted a number of specific corrective responses. These typically involve design of gear, or modification to fishing practices. Examples include TEDS, Torey poles, the environmentally friendly scallop dredge, and a range of gear modifications known generically as Bycatch Reduction Devices (BRDs). However, these responses are generally implemented as modification to existing practices, and, typically take a narrow view of the possible options to, for example, reduce bycatch of an important species. Because such responses are rarely revised or revisited, and they are typically a reductionist and not holistic response, they risk becoming redundant. If this happens, such tools may be imposing unnecessary incremental cost burdens on a fishery that may be able to meet a number of necessary environmental objectives by taking a different view of the bycatch issues (for example by introducing closed areas, or closed seasons, to reduce impact on bycatch populations to an acceptable level).
Fisheries Environmental Management Strategies, where they operate, are conducted at the level of a fishery. The direction and elements of such strategies are usually constructed to reflect national policies and initiatives, and the requirements of other levels of government. Many countries have identified the need for environmental policies and initiatives to apply to fisheries, and some have been able to carry these into fishery operations. The implementation of such policies is usually carried out in a unique way in each country, reflecting their institutional and cultural context and history.
5.1 Australia
National Level
In Australia, there is a long history (decades) of concern about fishery environmental issues. Amongst others, this resulted in the formulation of several national-level policies and strategies (such as the National Strategy for the Conservation of Australia's Biological Diversity; the National Strategy for Ecologically Sustainable Development). Implementation of these strategies (amongst others) was covered by the Intergovernmental Agreement on the Environment, a commitment by National, State and Local government jurisdictions to implement a range of environmental policies and strategies at the operational level. In general, the implementation of these strategies has not proceeded in an effective manner in coastal and marine systems because, amongst other problems, the exact nature of the operational objectives were not specified, and implementation procedures were unclear and confounded with jurisdictional overlaps and inconsistencies.
More recently Australia has moved to a more uniform national approach to management of fisheries resources based on the provisions of two Acts-the Environmental Protection and Biodiversity Conservation Act, and the Wildlife Protection Act. Together, these two national Acts operate to enforce each fishery wishing to export to comply with a specific set of environmental guidelines. These guidelines, modelled closely on the Principles and Criteria of the Marine Stewardship Council (see below), have the effect of requiring each fishery to demonstrate their activities are conducted in a sustainable manner. This is assessed by the Department of Environment and Heritage against a set of specific requirements in terms of stock and environmental issues. Each fishery seeking to export product is required to demonstrate that it meets the Act's requirements. This in some senses reverses the burden of proof, and requires each fishery to meet minimum requirements for a management system, and meet the criteria within two broad principles relating to maintenance of the stocks, and minimising any impacts on ecosystems.
The broad policy for national fisheries management, and specifically for Commonwealth fisheries, is the responsibility of the national agency-Agriculture, Fisheries and Forestry - Australia (AFFA). There are no specific environmental management streams of activity in AFFA for capture fisheries but AFFA is responsible for development and promulgation of national policy initiatives (such as the National Bycatch Policy, and Action Plans for specific purposes - currently sharks and seabirds) in conjunction with Environment Australia. The Australian Fisheries Management Authority (AFMA) is responsible for managing Commonwealth fisheries, and has specific policy development and management systems for (mainly) Commonwealth fisheries. Other than policy coordination, there are no specific management activities of AFMA that deal with environmental issues-these are incorporated into general management activities. Although AFMA has a mandatory responsibility to incorporate and manage environmental issues in Commonwealth fisheries, audits of AFMA performance have criticised the failure of these responsibilities to be properly implemented. National fisheries legislation is presently under review, and the environmental performance of national fisheries management will likely be the subject of significant attention and revision.
A further recent development is Australia's Oceans Policy, a national strategy designed and delivered through Regional Marine Plans (RMP). The intention of these plans is to achieve an integration across the full range of management concerns in a region (including conservation and natural resource management) but initial progress is limited, and concerns are widely held for the efficiency and effectiveness an of the RMPs (Alder and Ward 2001). The Oceans Policy has subsumed a number of pre-existing initiatives of importance for fisheries. Perhaps the most crucial is the National System of Marine Protected Areas, which is expected to conserve representative samples of all marine biodiversity within Marine Protected Areas (MPAs). The MPAs are expected to cover a range of levels of protection, and include reserves classified as 'multiple use'. The best recent example of this is an MPA established around a field of seamounts in deepwater off Tasmania-the bottom waters are fully protected from any exploitation, while the surface waters (500 m in depth, but above the tops of the seamounts) are open for fishing. This seamount MPA is expected to make a significant contribution to protection of seamount biodiversity. Elsewhere, the orange roughy fishery has been criticised for damage of the rare seamount fauna, and the MPA is a move to prevent ongoing seamount degradation. The declaration of the seamount MPA required extensive negotiation with the fishing industry, and was initiated jointly by AFMA and Environment Australia.
State Jurisdictions
In each State and Territory, the relevant Fisheries Department has management responsibility for fisheries that fall into their spatial jurisdiction or by agreement with the Commonwealth, fisheries that overlap State and Commonwealth jurisdictions. State agencies all operate within different legislative basis, and most with different institutional structures, with varied levels of research support. Generally, their environmental management systems have been ad hoc, and not highly effective. The effect of the national EP+BC Act now means that, because of the reciprocal arrangements established within this Act, there will be a measure of consistency developed across the state agencies, at least in terms of functional outcomes (compliance with the EP+BC guidelines).
As one example, in Western Australia, fisheries management is largely 'cost recovery': much of the cost of fisheries management by Fisheries WA (FWA) is recovered from the fisheries themselves. As a result of this alone, there are significant obstacles in meeting environmental obligations, and management operations in support of environmental matters are not easily endorsed for funding, except to the extent that they may affect future productivity in the fishery. This greatly constrains the nature and priority that can be accorded to environmental activities beyond stock management issues. In order to address environmental issues, FWA has adopted a strategy of stakeholder consultation (an advisory group of external stakeholders), with a process of review of environmental issues in a region followed by development of a management plan that addresses any specific matters. The single review and plan produced so far (for the Gascoyne region) is primarily focused on a range of external matters that affect the fisheries of that region (such as the effects of coastal developments on key habitats, resource allocation between commercial and recreational sectors). Although there is only a weak link between these plans and the operations of a specific fishery (for example there are as yet no operational objectives, targets, monitoring or reporting measures), the process has considerable merit and the capacity for further development into an operational strategy for dealing with fisheries environmental issues in WA regions.
Other initiatives have not been successful in Australia, most notably the structural efforts to combine (either formally or informally) the expertise of fisheries and conservation agencies to deal with fisheries environmental issues. For more than 20 years every effort in several jurisdictions to achieve satisfactory outcomes using this approach has failed. These have not worked because of a lack of strategic focus, no clear and agreed outcome-based objectives, institutional interaction failure, and a lack of appropriate leadership.
Fishery Level
Individual fisheries in Australia are moving gradually to development and implementation of procedures to minimise environmental impacts at a range of levels. There are many drivers for these shifts, some are optional but most are structurally required by national legislation. Some initiatives are about processes, while others are specific in their content and delivery.
As an example, control in Commonwealth-managed fisheries is (in practice) delegated to the Management Advisory Committee (MAC) where stakeholders consider required actions and agree on outcomes for such matters as stock assessments, TACs, and research projects. The information for MAC decisions is provided by a specialist Fisheries Assessment Group for each fishery. In recent years the MACs have admitted conservation interests as members to bring to the discussions various aspects of environmental concern. Benefits accruing from this strategy have been more agreement about the nature and role of specific environmental initiatives (such as gear designs to minimise bycatch, trials and adoption of Turtle Excluder Devices, support for research targeted at environmental concerns), and an improved communication between the different perspectives on fisheries management. The role of MACs is established in the Fisheries Act.
On a voluntary basis, the Western Rock Lobster has been certified by the Marine Stewardship Council (MSC) as well-managed and sustainable, based on world's best practice in fisheries management and compliance with the MSC Principles and Criteria. Consistent with the principles of continuous improvement, the MSC certification carries with it a range of environmental requirements that have to be implemented if the fishery wishes to maintain its MSC certification. A number of other Australian fisheries are also considering their capacity for MSC certification. A decision to proceed to MSC certification is voluntary, but the MSC certification involves compliance with a series of criteria that are similar to those of the national EP+BC Act. The WRL has also recently adopted a code of practice in order to avoid adverse effects of bait discarding in the fishery.
Other initiatives include matters such as State of the Fishery reports, State of the Environment Reporting, annual review of Australian fisheries, and annual stock assessment/review procedures.
5.2 USA
The US has a multi-tier set of arrangements for managing fisheries, in concept not unlike those in Australia. At the national level, specific environmental initiatives are developed and promulgated by Congress and a lead national agency usually has responsibility for implementation. A recent review of the fisheries sector has led to a major revision of fisheries management, and the Magnuson-Stevens Fishery Conservation and Management Act 1996 and the Sustainable Fisheries Act 1996, implemented by the National Marine Fisheries Service, are now the driving force for environmental management in fisheries systems. While both Acts have important environmental aspects, such as identification and protection of habitat considered critical for fisheries, progress is slow, in part because of the technical difficulties, but also because of the comprehensive nature of their ambit (Fluharty 2000). The US has also recently commenced implementation of its Oceans Act, but it is as yet unclear how this will affect fisheries management (Alder and Ward 2001).
Other recent initiatives include the analysis and report to Congress of the US Ecosystems Principles Advisory Panel on Ecosystem-Based Fishery Management. This report identifies the emerging issues for fisheries management in the US, and identifies a series of principles that should underpin fisheries management in the future, the primary goal, and a series of policies to govern the future management of US fisheries. While the report adopts and endorses many of the now well-known suggestions for ecosystem-based management-supporting for example, much greater use of ecologically-defined boundaries for fisheries management systems-the main instrument used for implementation is the provision of guidance and recommendations to the NMFS and to the US Regional Fishery Management Councils. The report covers research needs and proposes that the Councils introduce Fisheries Environmental Plans-an apparently new instrument that would operate in parallel, or in some other unspecified manner, with the existing fishery management plans. But otherwise, the Principles Advisory Panel guidance does not extend to the fishery level, and there are few practical implementation measures developed. Much of the actual implementation of such national policy is presumably to be conducted at the State level and under the guidance of the NMFS.
At the State level in the US, California has introduced a new management act for management of all marine life, including fisheries. This act (Marine Life Management Act 1999) attempts to take an ecosystem approach, is intended to cover all marine species, and considers fisheries as on aspect of the ecosystem to be managed. Environmental considerations (stock, habitats) are considered explicitly in the plan of management prepared for each fishery. The California Act is recent, and it is not yet clear how effective it will be in considering specific environmental issues and addressing them within the fisheries management system. However, in structural terms, the Act is a useful approach to the matter of incorporating environmental issues into fishery management. Working within the ambit of the recent national initiatives, there are important fishery level activities and opportunities that presumably will arise, but as yet it is too early for the impacts of these initiatives to be expressed.
5.3 Europe
The fisheries of the European Community are managed in a complex web of national and regional fishery arrangements. Given the intensely international nature of the management systems, the highly interconnected nature of many of the relevant marine ecosystems, and the many fisheries crashes and environmental issues experienced in Europe, the imperative for better marine ecosystem management, including fisheries, is extreme.
In recognition of these issues, the EU is proposing a major review of the broad umbrella policy for European fisheries- the Common Fisheries Policy. The review is intended to bring a very strong environmental and ecosystem-based focus to fisheries management, and there are numerous regional and national activities underway that are supporting this direction. Recent very high profile fishery crashes-such as the demise of the Iceland cod fishery, arguably until 2001 considered to be one of the best managed Northern Hemisphere fisheries-demonstrate the fragility of the ecology and politics of 'best practice' conventional fisheries management systems. These, together with the many profound environmental issues, are the basis for a vast number of regional, national and local attempts to identify and solve problems. The Common Fisheries Policy is an attempt to bring these many activities into an integrated theme, with common principles and goals all directed at improving the environmental performance of the many European fisheries.
The key issues intended to be addressed by a revised CFP include many familiar problems:
Classical fisheries management is based on managing fishing characteristics (effort and catch) in relation to the target species, rather then aspects of the environment or ecosystems in which target species may live. In principle, such approaches are designed to permit a large enough portion of the stock to escape capture long enough to reproduce sufficiently to ensure that there is adequate recruitment to sustain the population and desired level of fishing.
Fisheries management based on these approaches and using single-species models has been successful for many decades, but in recent years the over-exploitation and crashes of many fisheries (references in Jamieson 1993, Wilson et al. 1994, Ault et al. 1997, Garcia & Newton 1997), the changing nature of fish yields caused by serial over-fishing and 'trophic fish-down' (Pauly et al. 1998), and the losses of biodiversity and environmental damage caused by fishing (e.g. Russ 1991, Alverson et al. 1994, Dayton et al. 1995, Roberts 1995, Jennings & Lock 1996, Jennings & Kaiser 1998, Thrush et al. 1998, Hall 1999), have alerted fisheries managers, scientists and NGOs worldwide to the weaknesses of traditional fisheries resource assessment and management systems (Sainsbury 1998, Pitcher 2001). This problem is exacerbated by the fact that the oceans are reaching their productivity capacity, and that many (most in some regions) stocks are now fully- or over-exploited resulting in unsustainable levels of exploitation (Jamieson, 1993, Ludwig et al. 1993, NMFS 1993, FAO 1994, Botsford et al. 1997, Garcia & Newton 1997, Mace 1997, Buckworth 1998), a fact that is often masked by technological improvements (Clark 1996), geographic expansion of fisheries and trophic fish-down (Pauly et al. 1998).
Fisheries in Australia and New Zealand are, generally speaking, well managed by world standards. Some have been used as 'models' of best practice. However, here, as elsewhere, in fisheries management, surprises happen. There are many local examples where fisheries have been considered to be performing creditably, only to find a surprising year when unpredicted things have happened . A dispassionate analysis of fisheries performance in Australia and New Zealand would find that there have been a number of fishery crashes that could have been avoided with better knowledge or more commitment (for example Eastern Gemfish; Southern Bluefin Tuna) and many examples of intense overfishing from which stocks have recovered but that could have been avoided with better management. Overseas experience is that fisheries crash because of surprises (such as a key ecosystem link that was previously unknown; or technology creep gradually eliminating de facto reserves where fishers could not previously fish). The resilience of a fishery to surprise is a key attribute of a more precautionary system of management, and while the nature of surprises can never be anticipated, experience from other fisheries in responding to surprises should be adopted into all modern fisheries management practice. Beyond stock management, even the 'best practice' models for fisheries management (such as MSC certified fisheries) have been found to be lacking in their environmental performance, mainly in respect of the effects of fishing on habitats and dependent species. Dealing with surprise and taking reasonable account of interactions with non-target species and habitats are the most important hurdles in moving fisheries management to a more ecologically responsible management system that can produce fisheries that are agreed to be 'sustainable'.
Solving the problem of unsustainable exploitation is difficult in many countries because of several seemingly intractable sociological, political and economic problems, such as:
Modern, scientific fisheries management, developed in the 50s (see references in Smith 1998) and based on concepts such as 'surplus production' and 'maximum sustainable yield' (MSY), held great hope for the sustainable exploitation of marine living resources. However, as long ago as the 70's the promises of MSY were thoroughly debunked (Larkin 1977), and since then numerous workers have pointed to these and other problems that have prevented, and will continue to prevent, fisheries scientists and managers from achieving sustainable exploitation using the methods of the 50s. Some of the more important scientific problems are:
Precautionary fisheries management involves several components, including the use of risk-averse approaches to the defining of optimum yields, the setting of management targets, and in developing control rules (FAO 1995, Roughgarden & Smith 1996). A critical component of the precautionary approach is the implementation of management strategies and actions that minimise the likelihood of producing irreversible impacts such as the extirpation of local populations, permanent community-structure shifts, or species extinctions in the face of pressures from fishing or environmental changes (Agardy 1994, Roy 1996). Where there is uncertainty, history shows that those in control of fisheries will almost always maintain or raise the current level of catch (as catch limits), unless there is convincing evidence that those limits are unsustainable (Ludwig et al. 1993, Hilborn 1997). And when the biological basis of the stock management interacts with the socio-economic and institutional issues, and with a shifting benchmark of conditions (the 'rachets' of Pitcher 2001) fisheries seem doomed to an unsustainable future unless managers move forward in a precautionary manner. However, Hilborn (1997) cautions that effective application of the precautionary approach depends on the situation. While the approach would be appropriate for a developing fishery, if applied to a fully developed fishery it could result in an increased risk of its economic collapse. In the latter situation the approach would be precautionary with respect to biological risk, but not so with respect to socio-economic risk. Although risk-averse management is likely to greatly improve the basis of fisheries management, models and approaches will need to also integrate the socio-economic aspects of fisher behaviour, an area poorly researched or understood (Rosenberg et al. 1993).
Some fisheries scientists consider that the classical fishery management tools, augmented with modern risk management procedures, can overcome the existing fisheries-management problems experienced in the past (Rosenberg et al. 1993, Mace 1997). But, in contrast, there is a growing consensus amongst fisheries scientists about the need for a 'paradigm shift' in the way marine fisheries are managed (e.g. Botsford et al. 1997, Sharp 1997, Sutton 1997, Johannes 1998, Pauly et al. 1998, Pitcher & Pauly 1998, Sainsbury 1998, Walters 1998, Williams 1998, Fogarty et al. 2000, Pitcher 2001). This paradigm shift is towards ecosystem-based management, where the fish stocks are seen as one element in an environment where many aspects need to be managed using more precautionary approaches, and where more risk-based approaches are used in decision-making. The ongoing litany of crashes of fisheries that have been considered to be model fisheries in terms of their management systems is testament to the difficulty of existing narrow fisheries management models and systems.
There appear to have been no successful attempts to construct detailed fishery-environment models to predict the impacts of changing fishery activities on specific environmental concerns, despite considerable current work in this area. From the limited attempts so far, it seems clear that, no matter what science support and models are used, as a fishery progresses towards assessment and then resolution of environmental issues, the management system must be solidly grounded in formal decision analysis procedures (Lane and Stephenson 1997). At least one of the important issues is that, to a fisheries scientist, a fisheries-environment model is focused on how shifts in environmental conditions affect stock parameters (such as recruitment levels), but not necessarily how specific options in a fishery may affect particular attributes of the environment. This reversal of the usual problem for a fisheries scientist means, effectively, that a whole new class of models is needed, and perhaps as important, very different types of data.
Scientific support for fisheries management is primarily for stock assessment. In moving to expand this science-base most fisheries science approaches are focused on identifying issues that are susceptible to scientific analysis and existing tools (primarily production models). Much of the existing effort is attempting to use classical fisheries science tools and science base to also deal with environmental issues. The unfortunate consequence of this is that it constrains the types of approaches that most fisheries agencies are prepared to apply to the common environmental issues. For example, it is not surprising that bycatch has been adopted as a key focus (in Australia and US for example) because it is a problem that fisheries scientists can analyse and begin to address using their existing tools and knowledge, much of which is focused on single species population dynamics. So bycatch issues are generally considered to be a multiple of single-species type problems. Taking a more holistic and synthetic, as opposed to a reductionist view, would suggest that bycatch issues (other than for rare or icon species) can be better addressed using a strategic and synthetic risk-based framework. But such approaches are not based in fisheries science-they arise from environmental science and risk assessment. In these fields, complexity and uncertainty are the norm, and are accepted as the basis for scientific investigation, and problems are only rarely assessed using the fine-scale deterministic models so common in fisheries assessments.
In contrast to fisheries models, the emerging approaches to environmental modelling are based on the use of increasingly simple models in terms of ecosystem parameters, but with an emphasis on spatial and temporal resolution, and on representing the ecological and social dynamics to enable an exploration of management options (e.g. Carpenter et al 1999, Van den Belt et al 1998). Such modelling approaches are contributing to the 'science of integration' (Holling 1999) and when used with risk assessment, adaptive management and when set in a formal decision analysis context (Lane and Stephenson 1997) are likely to be the most productive approaches to assessing and resolving fisheries environmental issues. For the management of natural resources, new forms of models designed to address potentially competing objectives that are difficult to evaluate in numeric form and may be highly subjective, such as maintaining harvesting levels, maintaining safe levels of stock biomass, and constraining the environmental effects of fishing, are increasingly being used to resolve these complex optimisation problems. These models, based on optimising an objective function that combines various objectives to be achieved (see for example Day et al in press, Possingham et al 2000) are well suited to dealing with objectives that are of a very different nature, and probably offer the best prospects for new models to use in fisheries management systems to deal with the complexities of environmental sustainability.
6.1 Cause-Effect Models
Predicting the way in which a fishery will affect an aspect of the environment relies critically on information and knowledge of relevant cause-effect relationships. For example, given an increase (or decrease) in fishing effort, how will the seafloor benthos respond? Will the fishing be of sufficiently low intensity that recovery of benthos could occur if the fishing was eliminated, or would the benthos be gradually eliminated over time, or be unable to withstand a large climatic event? Given the space and time scales inherent in attempting to answer such questions, or develop cause-effect relationships, approaching the issue at an individual species level is never likely to be practical. Landscape ecology is an emerging field of ecology (Picket and Cadenasso 1995) that is sensitive to spatial heterogeneity and dynamics, and attempts to consider and incorporate issues of scale, and concepts as difficult as biological diversity. Cause-effect relationships based on the concepts of landscape ecology will potentially assist in providing appropriate levels of data and knowledge for fisheries assessments, but as yet there has been little development in this area. Without defendable links between fishery activities and resulting environmental changes, management models are not likely to make useful assessments, or develop useful levels of predictability.
6.2 Fisheries-environment models
Quantitative fisheries models typically attempt to estimate fishing mortalities (and other characteristics of fishing effort) that will deliver a yield that satisfies the criteria of the specific fishery (maximum, optimal, continuous, sustainable, etc) within the nominated time frame. To achieve this, models typically become more complex, and although there are recent trends to more simple models they still make large assumptions that are only testable within the context of the fishery experience. Whether the trend to simple models will actually improvement stock management within the context of ecosystem-based management is as yet unclear. But no matter which models are used, effective prediction of fishery environmental impacts has four key requirements:
Considering the effect of fishing on habitats, just one of the key areas of interaction between fisheries and ecosystems, fishery models need to consider the impacts on non-target species that comprise the habitats (such as sponge assemblages on rubble or pavement reefs). Classical models rapidly become constrained by the lack of quantitative data on responses of such species to the fishing disturbance, and so predicting responses by such biological assemblages across the space and time domains of the fishery becomes very problematical. Beyond this problem, estimating the dynamics of assemblages of species affected by fishing, and their responses and interactions with non-fishing disturbances such as storms or large-scale climate shifts, is exceptionally difficult. And further, resolving such matters by altering harvest strategies (the main tool that a fishery manager has to exert control in a fishery) will usually invoke questions about resource allocation, tenure and security of access where a single stock is fished by commercial, recreational and indigenous sectors. Together with typical issues applying to all modelling endeavours (such as problems of over-parameterisation), when taken together, these difficulties mean that extending classical fisheries assessment models to take account of constraints imposed by environmental interactions is unlikely to be a successful strategy. There is no significant body of evidence that indicates that single-species models and tools like those commonly used in fishery stock assessments are able to adequately contribute to the assessment and management of ecological impacts of a fishery, except for stock-specific issues.
Other popular approaches to considering environment and ecological issues in fisheries management are based on the ready availability of the modelling tools from the Ecopath/EcoSim/EcoSpace family (developed at the University of British Columbia, Canada). These models are powerful tools for exploring the responses of biomass to fishing impacts, and in other biomass/productivity related explorations and simulations. At this stage, they offer only simple representations of ecosystems and their values, and do not deal, for example, with species diversity issues or with the more complex elements of ecosystem dynamics, including feedbacks and complex spatio-temporal variability. These models therefore offer managers only a limited capacity to explore the impacts of fishing in any specific fishery, and are not suitable as a routine modelling system that would support the ongoing evaluation of environmental issues in a fishery in a way that parallels stock assessment models. As simple tools they offer an effective mechanism to easily explore a range of hypotheses about biomass issues in marine ecosystems, and play a very important role in hypothesis building and testing. The Eco-family of models are very valuable, but they are not comprehensive ecosystem models, and will not easily adapt to the needs of ecosystem modelling for use in fisheries management systems. More holistic tools and approaches appear to offer a more effective approach to these problems, and are derived from new ecological approaches to synthesis and analysis that includes stakeholder participation (see for example Van den Belt et al. 1998). Such approaches do not as yet offer the same level of resolution as single-species stock assessment models, or the Eco- family of models, but deal more comprehensively with the range of ecological issues that have to be managed within a modern sustainable fishery.
Overall, the prospects for extending fishery models to take proper account of a typical set of environmental issues is bleak. The modelling tools, the models, the nature of the data and the development of the management interface, where activities in the fishery are linked to model outcomes, are all very demanding aspects of attempting to develop fishery-environment models in order to predict the impact of fishing. Beyond their likelihood of success, such models will be very data-intensive and require large amounts of information at scales that may well beyond the capacity of most fisheries to provide. The challenge for fisheries management for the future is to develop modelling systems that will contain all three types of models discussed above, and the develop the appropriate interfaces or nested sub-models.
One strategy for dealing with this complexity is to incrementally build modelling sub-components into single species stock modelling systems to deal with known environmental issues that can be modelled. This is a reactive strategy, and is a weak approach to the overall problem because it fails first, to recognise that there may be environmental impacts of the fishery that cannot be modelled with existing fishery management tools, and second, it offers no proactive strategy for identifying, prioritising and responding effectively to emerging environmental issues in the fishery-the fishery system will always be operating in a reactive and defending mode. Perhaps even more importantly, it is highly unlikely that data requirements of such models could be satisfied for many fisheries, if any, and so following this strategy is not likely to be useful in the short term as a broad basis for assessing and resolving environmental issues in NZ fisheries. This is not to suggest that single-species models should not be used for specific issues that are susceptible to such modelling, such as seabird or mammal issues. Here better models supported by better data are needed to be able to more effectively inform the sustainability debate, and the might level models used for integrating a range of interests and positions into suitable harvest strategies for the fishery to employ.
An alternative, and more promising, strategy for dealing with this complexity in a fishery management system is the use of optimisation models, where objectives of differnet kinds are expressed as targets to be achieved within an objective function. The models seek to optimise the objective function using various alternative procedures of achieving the targets for each objective. These models have only recently been used for marine management purposes (see Day et al in press), but have been used in other natural resource management systems, and could be readily developed for use in fisheries management systems.
In summary, much of the predictive element of fisheries science is based on a very extensive history of research and knowledge over many decades. In contrast, environmental science is a more recent field of endeavour, and with funds for research highly constrained. The effect of this is that the knowledge needed to build adequate models to incorporate environmental issues into stock assessment models and harvest strategies is unlikely to be available at any reasonable level of detail. But further, even if considerable environmental data were available, the likelihood of using such models to develop harvest strategies that reasonably reflected environmental constraints is limited. Management of single-species fisheries is difficult and expensive with current models and technologies; management of multiple-species fisheries is yet to be achieved in a systematic manner; inclusion of additional complexities such as the dynamics of icon species, and the effects of fishing on sensitive habitats and endemic species and assemblages are unlikely to be achievable in the near future using current-generation models and modelling tools. Although new approaches are constantly developing it seems highly unlikely that models that match the needed 'paradigm shift' will be available in the short term for use in an environmental management strategy that is effective and efficient. The most promising areas for future development are risk-based approaches and strategic evaluations, and conceptual models, and it is in this direction that most fisheries should now be headed.
None of this should be interpreted as decrying the utility of stock assessment modelling as a discipline, nor the need to improve the robustness and utility of stock assessment, through reducing uncertainties in parameter estimates etc. The thrust of the comments above is that stock assessment models on their own will not deal with ecological and environmental issues that are being experienced in modern fisheries. If these issues are to be dealt with effectively, new approaches to models and modelling will need to be developed to interface to stock models and provide appropriate information for inclusion into the processes for setting of TACs and defining appropriate harvest strategies. Without appropriate models decisions may be made on the grounds of poor data and knowledge, producing outcomes that are unreliable, leading to unsustainable fisheries.
6.3 Rapid Assessment Tools
In recent years there has been a resurgence in the popularity (at least in the technical literature) of rapid assessment tools. Some (e.g. Garcia and Grainger 1997) consider these are 'quick-fix' solutions with only temporary roles, but many would consider them an appropriate and achievable, if minimum, step in the correct direction. Publications are most prolific on such tools from North America (RapFish, EcoPath) although environmental assessment techniques are also in this class (the Amoeba from Netherlands; Marine BioRap from Australia-Ward et al. 1998). Most such approaches are based on generic approaches to fisheries assessment, and they often, despite the claims of their advocates, are heavily model dependent (eg RapFish). Overall, such tools can make a significant broad contribution to fishery assessments, but they provide little in the way of solutions or strategies to resolve environmental issues-they mainly identify the problems.
6.4 Strategic Risk-Based Assessment
Risk based approaches to management of environmental issues is a new and rapidly developing area of science. Precedents and models are limited, and there are no examples where a fishery has adequately assessed and responded to environmental matters in this way. However, there is a broad acknowledgement that such approaches are necessary (see MSC report on the Western Rock Lobster) and some fisheries, such as Australia's Northern Prawn Fishery, are already moving in this direction with an active program of research. In land use, watershed and protected area management, such risk-based management approaches are more common, mainly because these disciplines have long worked within highly complex systems (in resource, social and economic senses), and always have to work within the major constraint of very limited available data. Such increasing awareness is reflected in the report of the Ministry for the Environment analysis for the Risk Assessment Project.
"The practice of post-normal science is held to comprise a dialogue between all stakeholders in the policy development process regardless of their qualifications or affiliations. When dealing with indeterminacy, experts have no more comparative understanding of the problem than lay-people. Thus, there is a need for extended peer review which draws on anecdotal evidence and community opinion as well as scientific knowledge."
"….even when uncertainty is low, if the decision stakes are high enough, applied science and professional consultancy may still be inadequate environmental problem?solving strategies. Whenever an interest or lobby group finds its values or position threatened it can usually find contradictory scientific evidence to refute the position threatening its interests. These debates extend beyond conflicting technical or scientific evidence to a defence of values and vested interests. When this occurs the problem-solving process leaves the realm of scientific discourse and enters one of social debate."
" The work of Wynne, and Ravetz and Funtowicz leads to the conclusion that environmental science, and related reductionist problem-solving processes, while rapidly expanding our knowledge of natural systems and their interaction with human systems, can only go so far in informing environmental policy development. The challenge facing environmental policy makers is to broaden a reliance on science and experts by tapping into a wider pool of social knowledge and skills. The increasingly rapid dissemination of formal and informal knowledge means that it is now possible to accelerate the democratisation of policy making by developing institutions and problem?solving methodologies that enhance participatory policy development." (NZ MFE Comparative Risk Assessment Project)
Responding to the emerging recognition of the need for 'integration science', environmental decision systems are increasingly turning to risk-based tools, on the formal procedures of decision analysis, and on broader stakeholder involvement in decision making.
Fisheries models and tools are typically well structured to include uncertainty, in the sense of errors in parameter identification, measurement error, and model uncertainty. But the classical fisheries models are also heavily focused on the single target species, and often can be only legitimately applied to single stocks of a such species. Or they may be a multiple of such models where more than one species has to be managed. However, environmental issues come in many forms, and the classical approach to fisheries modelling is not always appropriate-although it is exactly what is needed in some cases. For example, fisheries-type models may be helpful in the management of the bycatch mortality of individual, highly valued icon species, such as albatrosses. But in general, environmental issues that do not directly involve the stock (such as habitat degradation, ecosystem changes, cascade effects on dependent species) are most difficult to model and predict the impact of effects, and classical fishery modelling approaches are not effective. The distinction as to utility is generally considered to revolve around the use of single species models, although there are other issues as well such as stock (or population) delineation, spatial resolution, data availability, and the formulation of objectives, targets and criteria. Where the environmental problem can be addressed using a single species approach, then fisheries models can be applied. However, where there are many species, many different spatial scales, and confounding non-linear responses, the problem rapidly becomes too complex, and the outcomes too uncertain to be of value. Uncertainty in environmental issues can based on one or more of:
In the near future it is unlikely that models and modelling will advance sufficiently to be able to adequately deal with the complexities of fisheries issues such as the cascading impacts of a fishery on a suite of dependent species. Specific modelling tools (such as EcoPath) can assist to address strategic questions relating to biomass, but real ecological effects require much more complex analysis. Then linking this to a change that can be achieved in the fishery to predict how the ecosystem will respond is even more difficult.
Currently, these issues of environmental impact are being addressed in some fisheries using a combination of strategic assessment tools to identify the matters most urgently in need of attention, and then with a focus agreed, using classical experimental, investigative, observational and modelling tools to further address the high priority areas.
Probably the most effective of these approaches is the current activities in Australia flowing from the Marine Stewardship Council certification of the Western Rock Lobster fishery and the concurrent requirements of the EP+BC Act. Section 10 of the EP+BC Act requires that fisheries undergo a strategic assessment for their sustainability, and they must meet the requirements of Schedule 4 of the Wildlife Protection (Regulation of Imports and Exports) Act 1982. The guidelines for assessments for these two requirements are modelled on the MSC Principles and Criteria, and now are generally known as the 'ESD requirements' because they have been accepted by fisheries agencies as a process that is consistent with earlier efforts to establish a system of reporting for Australia's ESD process. The main difference now is that the EP+BC Act requires a performance-based assessment, and judgements about achievements are required, such as in the MSC process.
A strategic evaluation process is now being trialled and implemented in Western Australia. Generally speaking it is intended to operate in the following way, although some of these steps are yet to be developed and properly implemented:
The Comparative Risk Assessment methodology has been developed by the US EPA for assessment and management of issues in human health, watershed management, and chemical pollution issues. (see <http://www.epa.gov/nceawww1/ecologic.htm> and Appendix 1 for a general overview of ERA activities in the US EPA and the EPA definition for Comparative Risk Assessment). This CRA approach has been trialled in various classes of problem and jurisdictions in North America, and while it is not a universal success, has made major advances in some key areas. While there have been, and continue to be, many difficulties in the implementation of this approach, many of the problems appear to be unique to the US policy and institutional environment, and looking beyond those difficulties there are good opportunities for use of CRA to assist with fisheries environmental issues. These include development of a common understanding of the problems/issues, engaging stakeholders in constructive debate, agreeing on the common ground between positions, and creating a focus for further detailed evaluation. Data and knowledge can be used to underpin much of the process, and particularly in framing the uncertainties and their boundaries, and in specifying where further data/analysis can be beneficial. The more detailed level of technical support for a CRA is provided by an Ecological Risk Assessment, which is a more complete and quantitative assessment of the risks that, typically, would be based on empirical data and measurements rather than opinions and judgements.
The ESD process as now being developed in Western Australia is being shadowed by similar work in other Australian states, but in WA at least, after some further development in conjunction with the MSC requirements for continued certification of the WRL, it is likely to be a successful strategy for initiating a constructive and workable approach to environmental issues in a fishery.
At this early stage the 'ESD Process' has not yet generated any new approaches to resolving the environmental issues in any fishery beyond the evaluation stage. New modelling and prediction tools that are based on these risk-assessment strategies will be needed to assist to resolve these issues. Specific tools that may well prove useful include structured modelling tools for estimating ecological risks, optimisation tools that can explicitly trade-off competing objectives, spatially structured environment models built into adaptive fisheries management regimes, and procedures for translating ecosystem constraints into revised TACs and harvest strategies for the fishery.
6.4.1 Assessment Levels
In a strategic risk-based decision analysis framework, a key problem is how to operationalise the concept of impacts of a fishery on biological diversity (given a limited information resource). A common obstacle is how to represent biodiversity. One effective solution is the use of a hierarchical classification approach and accepting an appropriate level of surrogacy to represent biological diversity at a range of levels. In other circumstances, the Great Barrier Reef Marine Park Authority has operationalised the concept of biological diversity at the level of biological assemblage, broad habitat classes, icon species, and biophysical classes of the environment defined within a given spatial scale by a group of independent experts (see <www.gbrmpa.gov.au> in the Representative Areas Program area.). On the Great Barrier Reef, this classification approach has been used to select priority areas for conservation action (Day et al in press), but the approach is equally relevant for classifying ecosystems to a scale of resolution that can be used to assess the impact of fisheries. The important point here is that whilst species and their populations are the ultimate focus of the environmental impacts of the fishery, and this is the appropriate assessment level for icon species, for many other issues, the level of assessment can be much higher in the hierarchy of biological diversity. Other fisheries are considering the use of 'indicator taxa' for the purpose of measuring and monitoring the impact of fishing on ecosystems more broadly. While this is a highly uncertain area of science, and such an approach brings with it a number of conceptual difficulties, it will probably improve assessments in the medium term, and result in the development of improved data, approaches and assessment tools to deal with environmental issues.
In this section I suggest the elements of a Fisheries Environmental Management Strategy that will assist the Ministry of Fisheries to meet their obligations arising from the Fisheries Act 1996. I rely heavily on the interpretations of the Act (as provided to me by MFish) as a basis for this analysis. The key aspect of this Act's interpretation is the breadth of the term 'sustainability'. The Act uses this term in a manner that, consistent with other common interpretations in modern fisheries management regimes, means the sustained harvests of target species in the long term as well as of avoidance of adverse impacts on associated and dependent species, habitats and ecosystems.
In proposing this form of strategy, I have drawn on the most promising elements from those reviewed in the earlier text. In particular, these aspects have been drawn from the intent of the EU Common Fisheries Policy, California's Marine Life Act, Australia's Fisheries and EP+BC Acts, and Western Australia's Fisheries Act. These elements are set within a modern environmental management systems approach that is common in the private, and increasingly found in the public, sectors.
The strategy I propose rests on three key propositions.
First, a modern fisheries management regime needs to ensure that fishery impacts are acceptable within the broader community of stakeholders (where this includes fishers, fishing groups, conservation interests, researchers, and community interests) and covers cultural concerns and socio-economic matters. The fishery needs to demonstrate that the benefits of continued fishing are not outweighed by the environmental consequences. In this sense, fisheries management should seek to actively involve stakeholders with any legitimate interest in the health of fish stocks and their ecosystems, the impacts of fishing on habitats, ecosystems and non-target species, and on any associated or dependent species, and seek to provide a technically robust understanding of the relevant issues for these stakeholders.
Second, the system that manages the fishery and the activities of fishers themselves needs to be responsive to new knowledge and new requirements for improvements, so that such changes can be implemented in an effective manner as the information base changes. In this sense, fisheries management needs to be strongly supported by science and technical research that contributes in an effective way to developing and integrating such new knowledge into the fishery practices.
Third, the central process that should be utilised to bring these many disparate concepts and issues together, in a way that can be used to provide guidance and control, is an ecological risk assessment conducted with the participation of stakeholders as part of a formal management plan for each fishery. Within the framework of developing, implementing and reviewing the management plan, the key process for including environmental concerns and issues, and if necessary converting them into suitable actions in the fishery, is the development of quantitative outcome-based objectives for the environmental attributes, with attendant targets and activities. Where they are of an appropriate type (such as a control on fishing effort), such objectives will link to the stock assessment process and harvest strategy as inputs, or constraints. The relative importance of putative impacts in the fishery should be assessed using the Comparative Risk Assessment procedures, supported as necessary by an ecological risk assessment.
The links between the environmental management system and the stock assessment processes are crucial, because, inter alia, acting on environmental objectives may mean that changes in fishing effort, gear types, fishing grounds, or times of the year, need to be explored, and these may have an important impact on stock assessment, on models and processes used, and on TAC outcomes. The linkages must be clear and explicit; they may require further development of different stock assessment procedures (such as new forms of the existing models) and the development of suitable sub-models to take the environmental issues and actions adequately into account. This may involve, for example, models that permit determination of an ecological or environmental quota, or a safe minimum biomass (Sumaila and Watson 2001), to be allocated for each species in the ecosystem before other quota is distributed.
The basic approach I take here is to consider the NZFEMS as a tool to assist the Ministry to facilitate the sustainable utilisation of fish resources, in a manner that is consistent with responsibilities arising from the Act, and as a major contribution to the establishment of an Environmental Management System (EMS) within MFish. The EMS would be used as a framework within MFish to conceptualise the role and uses of environmental information, to manage the data needs and operational requirements, and specifically to provide for input to and output from a broadly-based and high-level advisory group (an Environmental Management Advisory Group - EMAG- see below) as one aspect of the NZFEMS. The NZFEMS initiative could be used as a cross-cutting element of activity within MFish, operating across the existing programme or activity areas of MFish to ensure relevant policy responses, environmental analyses and monitoring systems operate in an efficient and effective manner within each managed fishery.
The elements of this proposed strategy are consistent with the implementation of an agency-wide Environmental Management System (EMS). The NZFEMS would include many of the key aspects of an agency-wide strategy that would be required for MFish to meet the requirements of an international accreditation system such as the ISO 14000 series Environmental Management System.
The concepts behind this proposed strategy are derived from existing activities in various jurisdictions, mainly in Australia, and although none of these jurisdictions operate a strategy like that proposed here, there are similarities. For example, within Commonwealth managed fisheries in Australia, the AFMA Management Advisory Committees form a high level advisory management group that include some of the key stakeholders and make strong (and often effective) recommendations on environmental issues in their fisheries. In Western Australia, an ESD Reference Group of stakeholders has been formed by Fisheries WA to provide detailed advisory input and guidance on fisheries environmental review and environmental plans, and specifically to guide their implementation at the fishery level of the implications of the national EP+BC Act.
I propose here that the MFish adopt a formal structure for a Fisheries Environmental Management Strategy, and that this comprise at least the elements listed and discussed below. The elements are not comprehensive because there are aspects of implementation that need detailed evaluation, and I cannot recommend on those in this brief scoping review. Some additional elements of the implementation will be best determined with a close working knowledge of the New Zealand institutional environment, and will depend on a history of interactions and experience within New Zealand environment and fisheries management.
There will be new costs associated with implementing a structural solution like the one I outline here, but in the medium term such costs should be offset by increased certainty of fisheries procedures, and increased security of resource allocation. In addition, public confidence in fisheries management should increase, and factionalised community concern and destructive debate should be reduced, all of which will contribute to a reduced whole-of-community cost and more stable operating environment for fisheries management. In promoting a more ecologically-responsible implementation of fisheries management in the EU, the Commission considers "…there is a reasonable amount of technical knowledge to base action on;…there is a broad consensus that the long-term cost of no-action would be unaffordable;… short-term difficulties may arise, these will be largely compensated by long term benefits" (Commission of the European Communities 2001). Estimating the real cost of such new proposals, as with all cost and benefit assessments involving natural resources that have a major public interest components, is fraught with difficulty. Amongst many problems, classical economic models underpinning costs and benefits rely on discount rates to estimate the long term values of present-day decisions and action, but real discounts are not necessarily well represented in such models, and may lead to poor policy decisions in managing ecosystem issues (Sumaila 2001). Ultimately, calculating the true costs and benefits will rely on pilot or demonstration projects, and on careful analysis of initiatives as they are implemented.
7.1 Objectives
An efficient and effective Environmental Management System will enable an organisation to:
The key objective of the NZFEMS is to ensure that objectives and targets in relation to environmental issues are explored, determined and agreed amongst key stakeholders, are based on best available information, and corrective action is implemented in a timely and effective manner. Where information or data is lacking, the NZFEMS will identify the nature of the gaps and the data/knowledge needed to resolve the issue.. The NZFEMS should aim to deliver outcomes in respect of the following objectives:
Within MFish, programmes, linkages and procedures need to be established to ensure that:
The central structural component of the proposed NZFEMS is an Environmental Management Advisory Group (EMAG) that has responsibility to identify environmental issues, advise on objectives and targets, and report on progress at achieving those targets. The EMAG is modelled broadly on the Australian MACs, although in the New Zealand context, the main focus would be on environmental issues that affect the fishery. The EMAG should be supported by specific capacity in Comparative Risk Assessment that (at least initially) should be developed within MFish, and by an annual State of the Fishery Report focussing on environmental conditions in the fishery. Development of the NZFEMS should be guided by a small executive group of key specialists, appointed as a NZFEMS Steering Committee.
The main component of the NZFEMS strategy is a process and structure to facilitate the development of environmental objectives and targets for the fishery, and the linkage of these to the stock assessment process, and hence to the harvest strategy for each fishery. The proposed EMAG would have the central integrating responsibility for assessing environmental issues, and although it should sit outside MFish, and is not itself responsible for managing a fishery, it would have a key role in supporting MFish to deliver the environmental outcomes that are required of MFish under the Fisheries Act (see Figure 1).
7.2.1 Environmental Management Advisory Group (EMAG)
For each identified (and managed) fishery or natural group of fisheries, an Environmental Management Advisory Group (EMAG) should be established to guide the further definition and implementation of the environmental objectives in the context of the specific fishery.
Role and Responsibilities: The EMAG would provide advice to MFish (see below) on matters of specific concern. However, the main role of EMAG would be to provide advice in relation to a nominated fishery or fishery group, in particular on specific environmental matters, but not constrained to these. EMAG will be the main forum within which environmental issues will be discussed and agreed by stakeholders and fisheries managers. This advice from EMAG would be used by MFish as one input to the process of formulating the harvest the TAC for each year in the fishery and for determining a set of environmental requirements (see below).
Standing: The EMAG should be jointly appointed by the Minister for Fisheries and the Minister for Environment, or at least with concurrence of the Minister for Environment, and be considered as a high level Advisory body that operates under management from MFish and reports publicly to MFish. MFish should provide logistics, a secretariat and meeting support services.
Composition: The EMAG would be formed from a specified range of interests in the fishery and relevant stakeholders, and would include (where appropriate) fishers, fishing industry, fish processors, community at large, technical/science experts, conservation representatives, local government, and MFish. A key aspect of the EMAG is its independence; in order to ensure this the Chair should be independent, have high community standing, and be recognised for expertise in one or more areas of relevance to EMAG.
Outputs: The role of EMAG would be to provide advice to MFish in terms of:
The functional engine for addressing environmental issues is the activities of the EMAG in defining sets of objectives for incorporation into a plan of management for each fishery. The objectives may take many forms, but actions required to achieve the outcomes will most likely involve aspects of fishing effort, gear design and use, and at-sea practices in relation to environmental issues. To ensure that any such recommendations from the EMAG are implemented in the fishery, each objective and respective set of actions should be addressed within the stock assessment process to the extent that they can be managed within a stock assessment framework. The nature of the issues and response required should be determined using Comparative Risk Assessment, and include scoping of possible responses within the fishery using Ecological Risk Assessment. Some issues may require new forms of assessment, using risk-based methodologies and optimisation tools (discussed in the science section above), to achieve agreed actions in the fishery (such as a change to harvest strategies) that can meet environmental objectives.
During the initiation phase of the EMAG and development of the risk assessment and modelling procedures, it will be necessary to establish a Steering Committee of reputable scientists and strategists with experience in the areas of decision analysis, risk assessment, environmental management and the effects of fishing to guide the development of the NZFEMS initiative. This Steering Committee should be a small executive group of experts appointed jointly by the Minister for Fisheries and Minister for Conservation against a clearly framed TOR that relates directly to the NZFEMS objectives.
7.2.2 Comparative Risk Assessment
MFish should invest in developing its internal capacity for conducting comparative risk assessments focused on environmental issues in key fisheries. This should build on existing internal capacity, and be strategically developed to provide guidance and support for the operations of EMAG and to other relevant MFish programs/activities. Priority areas would include the development of conceptual models of fisheries environmental issues, identification and trials of risk assessment tools, developing the interfaces to optimisation tools and to the stock assessment process, and selection of performance indicators and criteria.
7.2.3 Annual State of the Fisheries Report
Each managed fishery or a natural grouping of fisheries (such as, say, all mid-water trawl fisheries) should publicly report on the environmental conditions and issues in the fisheries on an annual basis. This annual report should give special attention to controversial issues, conditions that have changed substantially since the previous year, and significant fishery achievements. This report would be derived from a monitoring system for the fishery that was based on key environmental indicators and criteria, and assist to meet MFish reporting obligations. The public report would include, inter alia, summary information on stock status, catch patterns, and the key environmental information. Such a status report could build on existing reporting measures for stocks, but would need to clearly identify progress and achievements against environmental objectives and targets. The reports should be peer reviewed and verified by independent third party expert assessors appointed by MFish in conjunction with the relevant EMAG.
7.2.4 MFish Fisheries Environmental Manager
The managed fisheries should have a formally identified environmental manager within MFish. The role of the fishery environmental manager would be to ensure that the NZFEMS is properly implemented with respect to each fishery, and that NZFEMS outcomes are properly embedded within the overall MFish fisheries management system, including such matters as stock assessments, liaison with other agencies and NGOs. The environmental manager would not be responsible for actually implementing the environmental aspects of each fishery (or group of fisheries), but would have a design and oversighting role in working in close conjunction with the MFish designated fishery managers.
Given the importance of the NZFEMS, the environmental manager will need to be supported by a small group of staff who would assist to overview and maintain the focus of the relevant EMAGs, and provide an appropriate level of technical advice and support, as well as an interface to other agencies and data, and external science support structures.
The environment manager would be responsible for managing the process of the cross-cutting activity of incorporating environment concerns into fishery management throughout MFish, and be responsible for providing inputs to and outputs from EMAG, and in managing selection and establishment issues, funds and meeting processes.
The provision of a single-point of responsibility for an environmental management strategy is an important component of an ISO 14000 compliant EMS.
7.2.5 Science Support
New Zealand has a substantial (world renowned) capacity in marine, environmental and fisheries science. The expertise needed to support the new approaches suggested here, and specifically Comparative Risk Assessment, Ecological Risk Assessment and new models that use ecological risk estimates within stock assessment procedures, will probably be largely available, or could be easily developed, within the New Zealand science community. However, initially, it is prudent for MFish to build an internal capacity within these areas, given the innovative nature of the NZFEMS. After procedures have matured, and directions of technical development are clear, it will be then appropriate to use the competitive contract procedures for delivery of science support to the MFish activities in the usual way. A key area where additional effort should be devoted is the development of optimisation models that are coherent with existing stock assessment approaches but can be used to deal more effectively with environmental issues.
7.3 Possible Areas for MFish Internal Review and Development
In preparation for implementation of the proposed NZFEMS, MFish should consider commencing these activities (not in any specific order). Of these, points 4 to 9 inclusive should be assisted by external consultants-this is to ensure that a broad base is maintained for each of these activities, and that experience and lessons from other disciplines and sectors can be used where appropriate.
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A major theme of the guidelines is the interaction among risk assessors,
risk managers, and interested parties at the beginning (planning and problem
formulation) and end (risk characterization) of the risk assessment process.
In problem formulation, the guidelines emphasize the complementary roles
of each in determining the scope and boundaries of the assessment, selecting
ecological entities that will be the focus of the assessment, and ensuring
that the product of the assessment will support environmental decision
making. The risk characterization section discusses estimating, interpreting,
and reporting risks and applies an ecological perspective to recent Agency
policy encouraging clear, transparent, reasonable, and consistent risk
characterizations. The Guidelines emphasize that the interface between
risk assessors, risk managers, and interested parties is critical for ensuring
that the results of the assessment can be used to support a management
decision.
Comparative Risk Assessment
In other situations, a comparative risk assessment is conducted more like a preliminary risk assessment. For example, EPA's Science Advisory Board used professional judgment and an ecological risk assessment approach to analyze future ecological risk scenarios and risk management alternatives (U.S. EPA, 1995e).