Marine Stewardship Council (MSC) Pre-Assessment Report

Transcription

1 Marine Stewardship Council (MSC) Pre-Assessment Report The Gambian artisanal fishery for Senegalese tonguesole (Cynoglossus senegalensis) & Guinean sole (Dagetichthys cadenati) On behalf of the Client The University of Rhode Island, Coastal Resources Centre Prepared by the Conformity Assessment Body (CAB) ME Certification Ltd MAY 2015 Authors: Bert Keus, Paul Medley, Chrissie Sieben Client Name: Client Contact Name: Client Address: The University of Rhode Island Karen Kent University of Rhode Island GSO Coastal Resources Center NBC, 20 Receiving Rd. Narragansett RI ME Certification Ltd 56 High Street, Lymington Hampshire SO41 9AH United Kingdom Tel: Fax: Website:

2 Contents CONTENTS... 1 GLOSSARY INTRODUCTION Aims/scope of pre-assessment Previous actions towards MSC The MSC programme Unit(s) of Assessment Catch Data DESCRIPTION OF THE FISHERY Scope of the fishery in relation to the MSC programme Overview of the fishery The Gambia General description of the fishery Fishing Gear Principle One: Target species background Biology and ecology Migrations Stock status Harvest strategy Harvest control rule Monitoring and stock assessment Some recommendations Principle Two: Ecosystem background Designation of species under Principle Retained and discarded bycatch Endangered, Threatened and Protected species (ETP) Habitats Ecosystem Principle Three: Management system background Institutional framework Fisheries regulations Management objectives Fishery Co-Management Plan for The Gambia Sole Complex Consultative process Monitoring, control and surveillance (MCS) Management Evaluation and Review EVALUATION PROCEDURE Assessment methodologies used Summary of site visits and meetings held during pre-assessment Stakeholders to be consulted during a full assessment Harmonisation with any overlapping MSC certified fisheries TRACEABILITY Eligibility of fishery products to enter further Chains of Custody R01B 1 ME Certification Ltd

3 5. PRELIMINARY EVALUATION OF THE FISHERY Applicability of the default assessment tree and use of the RBF Evaluation of the fishery Summary of likely PI scoring levels REFERENCES R01B 2 ME Certification Ltd

4 Glossary B 0 B current CAB CFC CITES CoC CPUE CSRP DoFish DPWM EEZ ERA ETP FAO F MSY GAMFIDA HCR LACOM LCCC MCS MEC MOU MSC MSY NAAFO NASCOM NEA NGO PI PRI PSA RBF SI Unfished biomass Average total biomass for recent years Conformity Assessment Body Community Fisheries Centre Convention on International Trade in Endangered Species of Wild Fauna and Flora Chain of Custody Catch per Unit Effort Sub-Regional Fisheries Commission Department of Fisheries Department of Parks and Wildlife Management Exclusive Economic Zone Ecological Risk Assessment Endangered, threatened or protected species Food and Agricultural Organization Fishing mortality resulting in maximum sustainable yield Gambian Artisanal Marine Fisheries Development Association Harvest Control Rule Landing Site Co-management Committee Length converted catch curve Monitoring, Control and Surveillance ME Certification Ltd. Memorandum of Understanding Marine Stewardship Council Maximum sustainable yield National Association of Artisanal Fishing Operators National Sole Fishery Co-management Committee National Environment Agency Non-Governmental Organisation Performance Indicator Point below which recruitment may be impaired Productivity Susceptibility Analysis Risk-Based Framework Scoring Issue 2909R01B 3 ME Certification Ltd

5 SICA SSBPR TAC TAGFC UoC USAID VME VMS WAMER WWF WWF-WAMPO YPR URI Scale Intensity Consequence Analysis Spawning stock biomass per recruit Total Allowable Catch The Association of Gambian Fishing Companies Unit of Certification U.S. Agency for International Development Vulnerable Marine Ecosystem Vessel Monitoring System West African Marine Ecoregion World Wildlife Fund WWF West Africa Marine Program Office Yield per recruit The University of Rhode Island 2909R01B 4 ME Certification Ltd

6 1. Introduction 1.1. Aims/scope of pre-assessment This report presents the results of a pre-assessment study for Marine Stewardship Council (MSC) certification of the Gambian artisanal fishery for Senegalese tonguesole (Cynoglossus senegalensis) and Guinean sole (Dagetichthys (or Synaptura) cadenati) fishery. The assessment was carried out by Bert Keus, Paul Medley and Chrissie Sieben on behalf of ME Certification Ltd. (MEC). The Client for this pre-assessment is the University of Rhode Island who act on behalf of NASCOM (National Sole Fishery Co-management Committee) which consists of representatives from the fishing communities, fish mongers and processors, LACOMS (Landing site co-management committees), the Gambian Artisanal Marine Fisheries Development Association (GAMFIDA), the National Association of Artisanal Fishing Operators (NAAFO), municipalities, the Department of Fisheries and the industrial sector (Advisors to the NASCOM include the Fisheries Advisory Committee and the BaNafaa Project). The pre-assessment was conducted in accordance with the MSC Fisheries Standard version 2.0 and pre-assessment reporting template version 2.0. The purpose of this report is twofold: To assess whether MSC certification of this fishery can be achieved under the present circumstances To identify any obstacles to MSC certification It should be noted that this report represents the views of the MEC pre-assessment team, not those of a Full MSC Assessment Team which is approved by the MSC and stakeholders. Any Full MSC Assessment should be considered a completely independent process, and would involve a formal public and stakeholder consultation process. A pre-assessment provides a provisional assessment of a fishery based on a limited set of information provided by the client. The outcome can therefore not be guaranteed to be the same as that predicted by this report Previous actions towards MSC This process was initiated by GAMFIDA (Gambian Artisanal Fisheries Development Association), which was interested in obtaining MSC certification of the artisanal-caught Gambian sole fisheries. An MSC pre-assessment was conducted in 2007 by Medley et al. (2008) who identified a number of obstacles to certification. Nine action items were identified that would improve the fishery and bring it to a level where it would meet the criteria established under the three MSC principles (sustainability, ecosystem management and effective management system) as specified in the then Fisheries Assessment Methodology v1. The nine action items were (URI-CRC, 2014): Incentives for sustainable fisheries Written research plan Retained by-catch management ETP management 2909R01B 5 ME Certification Ltd

7 Waste management Data collection Stock assessment Harvest control rules Sole management plan Following the pre-assessment, a Memorandum of Understanding (MOU) was signed among the Department of Fisheries, Ba Nafaa, Atlantic Seafood and GAMFIDA. The MOU provided a basis for an action plan to implement the nine points identified. The plan was subsequently executed by the USAID-funded Ba Nafaa Project implemented by The University of Rhode Island in partnership with the WWF West Africa Marine Program Office (WWF-WAMPO). The action plan and nine activities were implemented under three broad areas (for further details see URI CRC, 2014): a) Build a foundation and process for co-management (build and capacitate comanagement institutions; develop a sole management plan; define use rights and harvest controls) b) Build capacity for short- and long-term sustainability. c) Develop information for action items (Atlantic Seafood was essential in this process and was a source of data collection for improved stock assessments.). It took approximately three years to build capacity in the Directorate of Fisheries (DoFish) to conduct stock assessments, develop and adopt a co-management plan for the sole fishery and set up the co-management structure necessary for a more sustainably managed sole fishery. The key stakeholders in the process were the DoFish, local fishermen and the export processing plants. The following transformative changes in the Gambian sole fishery have been attributed to the USAID/BaNafaa project within its five-year timeframe: Table 1. Transformative changes in the Gambian sole fishery attributed to the USAID/BaNafaa project (USAID/BaNafaa, 2014) Start of the project End of the project No management plan Sole and catfish management plan developed, formally adopted and gazetted No co-management institution National (NASCOM) and landing site committees established and active No use rights No closed season Small mesh size (80mm) No stakeholder involvement in surveillance and enforcement No Stock assessments conducted Overfishing of the two primary species Exclusive use rights granted 6 month closed season instituted 1NM along the shoreline Mesh size increased to 92mm to prevent growth overfishing Co-Mgt. committee actively conducting surveillance and enforcement and collecting fines from offenders Annual stock assessments produced and used for management decision making (Castro et al., 2013, Ceesay et al., 2015) No / minimal overfishing occurring 2909R01B 6 ME Certification Ltd

8 No bilateral discussions on joint management of the sole fishery No discussion of managed access The Gambia and Senegal stakeholders actively discussing joint management of sole stocks in the region Mauritania access fee system being reviewed by Co-Mgt. committee for possible adoption in The Gambia Under advisement by MSC, a second pre-assessment was conducted to determine whether the fishery is ready to enter the formal MSC fishery in assessment process. In this context, it should be noted that since the completion of the initial pre-assessment, the MSC has undergone a Fisheries Standard Review, resulting in changes to the MSC assessment process and to the MSC default assessment tree. The new requirements are detailed in the MSC Certification Requirements v2.0 which come into force from the 1st April The MSC programme At the centre of the MSC is a set of Principles and Criteria for Sustainable Fishing which is used as a standard in a third party, independent and voluntary certification programme. These Principles reflect a recognition that a sustainable fishery should be based upon: The maintenance and re-establishment of healthy populations of targeted species; The maintenance of the integrity of ecosystems; The development and maintenance of effective fisheries management systems, taking into account all relevant biological, technological, economic, social, environmental and commercial aspects; and Compliance with relevant local and national local laws and standards and international understandings and agreements The Principles and Criteria are further designed to recognise and emphasise that management efforts are most likely to be successful in accomplishing the goals of conservation and sustainable use of marine resources when there is full co-operation among the full range of fisheries stakeholders, including those who are dependent on fishing for their food and livelihood. On a voluntary basis, fisheries which conform to these Principles and Criteria will be eligible for certification by independent MSC-accredited certifiers. Fish processors, traders and retailers will be encouraged to make public commitments to purchase fish products only from certified sources. This will allow consumers to select fish products with the confidence that they come from sustainable, well managed sources. It will also benefit the fishers and the fishing industry who depend on the abundance of fish stocks, by providing market incentives to work towards sustainable practices. Fish processors, traders and retailers who buy from certified sustainable sources will in turn benefit from the assurance of continuity of future supply and hence sustainability of their own businesses. The three MSC Principles are further explained below: Principle 1: A fishery must be conducted in a manner that does not lead to over-fishing or depletion of the exploited populations and, for those populations that are depleted, the fishery must be conducted in a manner that demonstrably leads to their recovery Principle 2: Fishing operations should allow for the maintenance of the structure, productivity, function and diversity of the ecosystem (including habitat and associated dependent and ecologically related species) on which the fishery depends. 2909R01B 7 ME Certification Ltd

9 Principle 3: The fishery is subject to an effective management system that respects local, national and international laws and standards and incorporates institutional and operational frameworks that require use of the resource to be responsible and sustainable. Each Principle comprises a number of Components which are each divided into performance indicators (PIs), listed in Annex 1. Each PI is scored for every separate Unit of Certification along three scoring guideposts (SGs): SG60, SG80 and SG100. SG60 represents the minimum standard for certification in the short term, but with a requirement to improve to the 80 level. SG80 represents the minimum long-term acceptable level for certification, while SG100 represents the ideal. A pre-assessment study does not attempt to predict scores at a high level of detail; it attempts instead to assign scores to a category associated with a traffic light system: Information suggests fishery is not likely to reach SG60 and therefore would fail on this PI Information suggests fishery will reach SG60 but may need a condition for this PI <60 Information suggests fishery is likely to exceed SG80 resulting in an unconditional pass for this PI 80 In order to pass an assessment, a fishery must: i) Have no single score below 60 ii) Have an average score of at least 80 for each of the three Principles. Any score <60 identified during the pre-assessment would lead to a pre-condition, i.e. an issue that needs to be resolved before MSC certification can be attempted. Any score of would lead to a condition, i.e. a successful certification but with requirements for the fishery to improve to the SG80 level within a specified timeframe. In practice, very few fisheries pass with no conditions Unit(s) of Assessment Note on MSC vocabulary: Unit of Certification (UoC) vs. Unit of Assessment (UoA) The UoA is defined as consisting of the target stock(s), fishing method or gear type(s), vessel type(s) and/or practices, fishing fleets or groups of vessels, or individual fishing operators pursuing that stock, including any other eligible fishers that are outside the unit of certification. The UoC is defined as consisting of the target stock(s), fishing method or gear type(s), vessel type(s) and/or practices, fishing fleets or groups of vessels, or individual fishing operators pursuing that stock including those client group members initially intended to be covered by the certificate In summary, the UoA = UoC + any other eligible fishers identified at the start of assessment. For the purposes of this pre-assessment, no other eligible fishers were identified; the UoA is therefore the same as the UoC. 2909R01B 8 ME Certification Ltd

10 For this assessment, the following UoCs were identified: UoC 1: Species: Senegalese tongue sole or red sole (Cynoglossus senegalensis) henceforth referred to as red sole. Geographical range of fishing operations: Method of capture: Stock: Gambia river upstream to its furthest tidal extent and Gambia coastal waters out to 9 nautical miles. Bottom set-nets (minimum mesh size 92 mm). Gambia sole stock (regional management unit of red sole that spawn along the Atlantic coast Management Client group The stock is managed by the National Sole Fishery Co-Management Committee (NASCOM) and National Authorities according to Gambia National fisheries management systems and regulations. Gambian and Senegalese artisanal canoes that land sole on Gambian recognized landing sites. (Registration of canoes is now planned and should be in place.) UoC 2: Species: Guinean sole or tiger or black sole (Dagetichthys cadenati) henceforth referred to as black sole. Geographical range of fishing operations: (note: this species is also referred to as Synaptura cadenati; see Fishbase) Gambia river upstream to its furthest tidal extent and Gambia coastal waters out to 9 nautical miles. Method of capture: Stock: Management Client group Bottom set-nets (minimum mesh size 92 mm). Gambia sole stock (regional management unit of black sole that spawn along the Atlantic coast The stock is managed by the National Sole Fishery Co-Management Committee (NASCOM) and National Authorities according to Gambia National fisheries management systems and regulations. Gambian and Senegalese artisanal canoes that land sole on Gambian recognized landing sites. (Registration of canoes is now planned and should be in place.) The management unit for the Gambian sole fishery is not clearly defined. However, for the purposes of this assessment a management unit covering Gambian waters inside the 9 mile nautical zone is assumed. Although it is recognised that in practice the stock as a genetic unit is almost certain to extend beyond this at the very least into southern Senegalese waters it may be appropriate and precautionary to advocate a management unit around what is likely to be an important spawning area within Gambian waters. This should not prejudice management negotiations at a regional level, which may ultimately prove more effective for the management of the regional stock. It is important that under the precautionary approach management action should not be delayed while research is conducted into stock structure (Medley et al., 2008). 2909R01B 9 ME Certification Ltd

11 Based on fishermen s knowledge, Drammeh et al. (2011) suggest migration such that there is a larger biological stock complex shared between countries. A decision needs to be made based on the available science and expert knowledge, on what would constitute a management unit, such that effective control can be applied to limit and reduce exploitation. If it is determined that this includes fisheries in Senegal, then the Gambia fishery cannot be certified alone, but the Senegal fishery must be addressed in the harvest strategy. Figure 1. Fishermen s knowledge. Fish also travel south from Senegal to the Gambia River estuary to spawn. This level of detail is not available in the scientific literature (from Drammeh et al., 2011) Catch Data With the rise in the number of fishermen and motorized canoes (see Section 2.2.2), the overall catches of all species by the artisanal fleet increased from around 15,000 tonnes in the early 1980s to nearly 46,000 tonnes in In recent years the catches have decreased again to around 27,000 tonnes in 2012 (see Figure 2). Catches of pelagics (bonga, sardinella, mackerel, horse mackerel and scad) increased from around 4,000 tonnes in 1981 to over 25,000 tonnes in In 2012 the landings of pelagics were just over 12,000 tonnes again. Catches of demersal fish (catfish, croakers, snappers, grunts, soles, etc.) increased from around 9,000 tonnes in 1981 to over 15,000 tonnes in Since then these landings have remained around that same level (see Figure 3). 2909R01B 10 ME Certification Ltd

12 Landings in 1000 tons Artisanal and industrial fisheries production Year artisanal landings industrial landings Figure 2. Total artisanal and industrial fisheries production ( ) (Source: DoFish) Figure 3. Total pelagic and demersal landings of the artisanal fleet (Source: DoFish) Typical sole catches by a single canoe may range from kg a day in the low season to kg a day in the high season. Artisanal fishing for sole started in The Gambia in the 1980s. In this period a new fishing factory (MP Trading) started to purchase sole for export to the European market. The sole landings of the artisanal fleet then gradually increased to 2,285 tonnes in 2002 after which they fluctuated between 608 tonnes (2008) and 2,630 tonnes (2011) (see Figure 4). As the artisanal fishermen will operate different fishing techniques and target the species that are most profitable at the time, it is likely that the fluctuation in sole landings reflects more on sole prices and overall demand than stock status. 2909R01B 11 ME Certification Ltd

13 Figure 4. Artisanal landings of sole (both species). The green triangles are the total volumes exported by Atlantic Seafood. (Source: DoFish and Atlantic Seafood) 2909R01B 12 ME Certification Ltd

14 2. Description of the fishery 2.1. Scope of the fishery in relation to the MSC programme The assessment team confirms that the fishery under assessment is within the scope of the MSC fisheries standard (as per Section 7.4 of the MSC Fisheries Certification Requirements v2.0): The target species is not an amphibian, reptile, bird or mammal; The fishery does not use poisons or explosives; The fishery is not conducted under a controversial unilateral exemption to an international agreement; The client or client group does not include an entity that has been successfully prosecuted for a forced labour violation in the last 2 years The fishery has in place a mechanism for resolving disputes, and disputes do not overwhelm the fishery The fishery is not an enhanced fishery The fishery is not an introduced species-based fishery 2.2. Overview of the fishery The Gambia The Gambia is the smallest country in continental Africa, situated in West Africa along the Gambia River, completely surrounded by Senegal except for a 60 km border on the Atlantic Ocean (see Figure 5). The Gambia has a population of 1.7 million, of which an estimated 400,000 are Senegalese (World Bank, 2007). Figure 5. Map of The Gambia. The Gambia territorial sea extends to 12 nautical miles and it has an Exclusive Economic Zone (EEZ) of 200 nautical miles from the geographical baseline. The coastline, from Banjul point to Kartong, a southern border village of The Gambia with Senegal, is approximately 70 km long. The country claims a total maritime area of 4000km 2 and 10,500km 2 of continental shelf and EEZ respectively. 2909R01B 13 ME Certification Ltd

15 General description of the fishery The artisanal sole fishery under pre-assessment is carried out by artisanal canoes with a length of up to 15 meters, launched from the beaches of The Gambia or from upriver fishing villages. The fishery is prosecuted all along the coast, and also occurs up to the furthest tidal extent of the River Gambia. The best time to fish for sole on the river is in the months May- June-July. This coincides with the increased salinity due to low water runoff. In the ocean, catches are best in southern waters (note that there is another river complex in the Casamance region, just to the south of the Gambia / Senegal border). This pre-assessment covers the Gambian artisanal sub-sector. This is a highly diverse fleet sector incorporating marine, estuarine and freshwater fishing operations. The common form of fishing vessel in the artisanal sub sector is the canoe. About half of the boats are dug-out canoes, just over a third are planked dug-out canoes and the remaining small percentage are made from other material like fibreglass. More and more vessels are being motorised and by now the majority of canoes operating on the Atlantic coast are motorised typically with a length between 8 and 15 meters, and with outboard engines of around 15 HP, although examples up to around 40 HP can be seen. The last 2 significant fleet surveys (frame surveys) were conducted in 1997 and These indicate that in 2006 there were 1,410 artisanal fishermen operating in The Gambia a slight decrease compared with the early 1990s. The overall number of canoes has also begun to drop from a peak around the time of the 1997 fleet survey. The majority (three-quarters) of fishermen are vessel owner / operators, although there are perhaps as many as 500 assistant fishermen, most of whom are paid, but some comprise unpaid family members. A significant proportion of the fishermen operating in The Gambia are Senegalese, or from other West African countries. The 2006 FRAME survey results revealed that of the 1,410 head fishermen operating in the artisanal fisheries, 805 are Gambian nationals and 605 foreign but in the coastal area foreign nationals, mainly Senegalese form the majority with 249 head fishermen compared to 167 Gambians (Gambia DOF, 2006). In spite of the large proportion of foreign nationals, it is a requirement of Gambian law that all fish caught in Gambian waters are landed in the country. The exact number of artisanal fishermen that target sole, using sole nets, is not known, since such information was not specifically collected as part of the fleet survey. It is, however, estimated that between 100 and 200 canoes target sole along the Atlantic Coast, and perhaps another canoes along the river. These figures suggest that a relatively small proportion of the overall fleet targets sole Fishing Gear There are several types of fishing gear used by the Gambian artisanal fleet. Encircling and drift gill nets are used to catch mainly bonga and sardinella (small pelagic species), and stow nets are used on the River Gambia to catch shrimp. Hooklines are used to catch catfish (Arius spp.) and other demersal fish. Bottom-set gill nets are used to catch demersal fish like croakers, snappers, barracudas and sole. According to the latest frame survey, bottom-set gill nets are used by 475 head-fishermen (191 on the Atlantic coast) using 6,413 nets (average of 13 nets per boat). The gear used to target sole which is the focus of this pre-assessment is a bottom-set net. The nets are monofilament, with a legal minimum mesh size of 92 mm (although the former legally required mesh size of 80mm is still in use). The nets are weighted along the footrope, with floats along the headline. Net height is between 1.5 and 2m. Nets are typically made up of 20m sections, and these are joined together to make nets up to m long. Nets are typically set for 24 hours and hauled each morning. The working life of the monofilament net is between 3 and 6 months, although the ropes, weights and floats will be salvaged and re-used many times (see Figure 6 and Figure 7). 2909R01B 14 ME Certification Ltd

16 Figure 6. Sole caught in bottom-set gillnet (Gabis et al., 2012b) Figure 7. Schematic of generic bottom-set gillnet showing the anchors, marker buoys, floatline and leadline (Courtesy of Juan Chuy Sociedad de Historia Natural Niparajá, 2007) 2909R01B 15 ME Certification Ltd

17 2.3. Principle One: Target species background Biology and ecology The red sole (Cynoglossus senegalensis, Figure 8) is a member of the family Cynoglossidae (tonguefishes). Tonguefishes are flatfishes (Pleuronectiformes) with a small curved mouth and united caudal, dorsal, and anal fins. The relatively small eyes are located on the left side and their general shape is elongated and drop-like. The ground colours of the West-African species are light brown on the eyed side and whitish on the blind side. The species can reach a maximum length of 66 cm ( but the maximum observed length so far in Gambia waters has been around 60cm. Figure 8. Red sole (photo taken by Tristan Southall during initial pre-assessment) The black sole (Dagetichthys cadenati (also referred to as Synaptura cadenati), Figure 9), also known in the Gambia as Guinean sole or tiger sole is a member of the family Soleidae. The eyes are located on the right side. The species is found to a depth of 50 m on sandy and muddy bottoms and is an important part of the catch composition along the Gambian Atlantic coast fishery, with catches peaking in October and November and accounting for up to 30% of sole purchased by the processing factories. The maximum length for this species in Gambia waters is found to be around 50cm. 2909R01B 16 ME Certification Ltd

18 Figure 9. Black sole (photo taken by Tristan Southall during initial pre-assessment) These sole species are found in brackish and marine waters. Both species are demersal. Smallmouthed species, like tonguefishes and true soles (Soleidae), feed on a broad spectrum of smaller epifaunal and infaunal organisms. Their diet includes shrimps, decapods and other crustaceans, molluscs, polychaete worms, and many other types of small invertebrates, as well as echinoderms, fishes, and cephalopods. Most flatfishes produce planktonic eggs that float freely in the water column. Larval stages vary in duration from a few days to a couple of months; the duration of larval stages is influenced greatly by ambient water temperatures. Following eye migration and metamorphosis, young flatfish settle out of the water column and become benthic, with many species utilising shallowwater habitats as nursery areas. However, Drammeh et al. (2011) reports that red sole may be a demersal spawner, laying eggs in the substrate when they burrow beneath the surface. Other biological information on these species is limited. Some growth model parameter estimates are available. The growth rate (K) has been estimated for female C. senegalensis as 0.32 year -1 and 0.36 year -1 for males (Chauvet, 1972). Gabis et al. (2011) collected otoliths and attempted to estimate growth parameters, but report such estimates were unreliable,but they do suggest that estimates used in the stock assessment from Chauvet (1972) are close to the correct values Migrations Information on movement primarily comes from reports from fishers (Drammeh et al., 2011).There is no independent confirmation of the movements which could also depend on availability to the fishing gear, fishing activity and market requirements. Fishermen have observed that sole respond to the amount of rainfall/changes in temperature. Sole habitat is found offshore in about 60 m of water, where sole stay from November to January. With the January upwelling, they begin to migrate. During the rainy season, fish migrate towards the coastal areas because of the increased water temperatures, and they are most plentiful in coastal areas between June and September. Normally, sole bury themselves, but in warmer water, they spend more time on the sediment surface. From August, the fish begin to move back to deeper waters, completing migration by November. 2909R01B 17 ME Certification Ltd

19 Figure 10. Red and black sole abundance and distribution according to local knowledge (Drammeh et al., 2011) Stock status Five stock assessments have been completed on red and black sole since 2008 (Table ). All assessments have used length-converted catch curves to estimate average fishing mortality over the previous 6 or so years, and have generated reference points using yield-per-recruit and spawning biomass per recruit methods. They have used data from different sources and have made different assumptions with respect to key parameters. In some cases, F MAX (fishing mortality at the maximum point of the yield-per-recruit curve) was used as a reference point. However, it is not compatible with MSY and therefore not appropriate for use in determining status with respect to MSC requirements. A stock recruitment relationship must be assumed to estimate MSY reference points. Except for the 2014 assessment, the fishing mortality was estimated to be above the PRI level. Any indication that the stocks are being exploited above the PRI fishing mortality would lead to failure of the certification. Therefore, the stock status has not been determined in relation to a MSY based target reference point. It is likely that the length-based models would suggest that the spawning stocks would be below this point. The stock biomass is likely above proxies for the PRI (SPR 20%), but this is not confirmed. It has not been made clear why different estimates are being obtained, or which estimate should be used. For example, a final summary reports the different estimates (Anon, 2013), but not a final definitive outcome. No argument is presented why the 2014 assessment might be more accurate than previous ones. There does not appear to have been an attempt yet to estimate stock status consistent with all the available data (size, catch and CPUE). No stock status in terms of biomass or biomass proxies has been reported. Although the stocks are determined as at risk, their status is still uncertain. While management has taken action to limit exploitation, this does not amount to rebuilding because the estimate of status is not precise enough to monitor rebuilding or determine when such rebuilding might be 2909R01B 18 ME Certification Ltd

20 complete. Anecdotal evidence from fishers reports the sole being landed are larger than they were before the recent seasonal closure, so the level of exploitation may well have decreased. Table 2. Stock status from various stock assessments Red Sole F/F MSY F/F LIM (PRI) Medley et al. (2008) (updated so M=0.4 yr -1 ) F/F40% =1.67 F/F20%=0.70 DeAlteris et al. (2012) NA F/F20%=1.88 Cessay et al. (2013) NA F/F30%=1.57 Jallow et al. (2013) NA F/F30%=1.47 Ceesay et al. (2014) F/F30%=0.98 F/F20%=0.63 Black Sole F/F MSY F/F LIM (PRI) DeAlteris et al. (2012) NA F/F20%=1.5 Cessay et al.. (2013) NA F/F30%=1.96 Jallow et al. (2013) NA F/F30%=1.37 Ceesay et al. (2014) F/F30%=1.03 F/F20%= Harvest strategy The National Sole Co-Management Committee (NASCOM) and its associated Community Based Sole Committees (LACOMS) were established under the umbrella of Ba Nafaa in Through the Community Fisheries Centre Management Committees they have exclusive use rights to sole fisheries within the sole fisheries zone (from the Atlantic shoreline and shorelines adjacent to the estuarine areas of the Gambia River to 9 nautical miles offshore) and are responsible for their local management. The National Association of Artisanal Fisheries Operators (NAAFO), the Gambia Artisanal Fisheries Development Association (GAMFIDA) and The Association of Gambian Fishing Companies (TAGFC) have stakeholder representation within NASCOM. The Fishery Co-Management Plan for The Gambia Sole Complex grants NASCOM exclusive use rights to the fishing of sole within a 121,245 ha zone and specifies a seasonal closure for all fishing within 1 nautical mile (nm) of the coastline from 1 st May through to 31 st October (spawning period). The plan also includes a minimum fish size (25cm total length), minimum mesh size (previously 80mm, increased to 92mm as of December 2013), and a prohibition on the use of drift nets in the Gambia River. While the mesh size has been raised to 92 mm (see MOU 16 Dec 2013), an 80 mm mesh remains in use as the appropriate net mesh is as yet unavailable. A closed area has been established from 1 st May to 31 st October, as a zone up to 1 nautical mile from the shore along the coast from Kartong on the Senegal border in the South to Denton Bridge, just south of Banjul. The closed area was introduced in 2013 and is being enforced. The effect of the closed area has been partially evaluated in There is a general limit on access to the fishery through traditional use rights and number of suitable vessels. There is no formal vessel registry and there are no effort limits, however. Fishing effort can be estimated using landing site sampling and a frame survey (DoFish, 2006). There are no catch limits. However, the open entry for both Gambian and Senegalese 2909R01B 19 ME Certification Ltd

21 fishermen will need to be addressed (Ceesay et al., 2015), probably through joint vessel registration and fishermen licensing agreements. There has been an attempt to evaluate the harvest strategy, but results have so far been inconclusive. Initial results suggest that larger sole are being landed (Ceesay et al., 2015). The management system considers that the stock is shared between Gambia and Senegal. A workshop was conducted in 2011 on co-management initiatives on fisheries issues of importance to Senegal and The Gambia and to promote cooperative arrangements for fisheries science, technology and management. Of the workshop s final recommendations and action plan, the following were most relevant to the sole fishery harvest strategy: Establishment of a bilateral committee and annual workshop. Include fisher representatives in the national delegations in future meetings on the bilateral fishing agreement between The Gambia and Senegal. Harmonise policies, regulations, between countries and combat IUU fishing. This recognises that fishers migrate between the two countries. Harmonisation should take account of technical measures, seasonal closed areas and MPAs. Joint data collection and research, recognising that the stock is most likely shared. In terms of a harvest control rule, there have been some developments, but the process is incomplete. The co-management plan (NASCOM, 2012) refers to SPR 40% and SPR 20% as suggested by Medley et al. (2008), but these were not necessarily used by stock assessments since 2008 and justification for these reference points is not strong. The stock assessments refer to F MAX and SPR 30%, with the latter suggested presumably as a more precautionary limit reference point. However, it is not clear how precautionary any of these reference points might be in quantitative terms (although F MAX is certainly not precautionary), nor have any been clearly linked in quantitative terms to the available management controls. Stock assessments have been conducted regularly since 2012, and have been used to evaluate the exploitation rate, which has been in turn to advise on stock status. In response, management has sought to reduce exploitation rates by implementing a seasonal closed area and mesh size regulation. However, the 2014 assessment summary noted that the open entry for both Gambian and Senegalese fishermen to the sole fishery will need to be addressed, and some sort of restriction on access is required. There is an annual review of management measures by NASCOM. This review has resulted in a recommendation to increase the mesh size to 92 mm (which has already been implemented) and discussions on increasing the 1 mile zone to 2 mile Harvest control rule There are a number of controls being implemented which have the objective of improving the status of the resource and reduce risks to the fishery. A one-nautical mile area from the shore is closed for 6 months of the year since This closure may have improved the size of fish and lobsters caught and receives some support from fishers. These controls, together with a limit of overall fishing effort (e.g. limited entry), should be able to limit the exploitation rate to a normal target level, which forms part of the harvest control rule. This level of exploitation still needs to be well defined in relation to MSY and limited entry needs to be implemented. If the management and scientific authorities have decided that the stock is most likely shared with Senegal, the harvest strategy and harvest control rule will need to encompass fisheries on 2909R01B 20 ME Certification Ltd

22 both sides of the international border. This adds considerably to the complexity of the management, but bilateral meetings and negotiations as have already been conducted should help provide a solution. It can be argued that a generally understood, rather than well-defined, HCR is in place that is expected to reduce the exploitation rate as the point of recruitment impairment (PRI) is approached. This is demonstrated by recent management action in terms of a seasonal closure and to implement larger mesh size for gillnets. There is some evidence that tools used or available to implement HCRs are appropriate and effective in controlling exploitation (Ceesay et al., 2015). However, inconsistent sampling may prevent quantifying the effects, and information may not be available and in any case has not been used to determine whether controls have improved selectivity or reduced fishing mortality, or both. Without limited entry, it might be argued that tools being used are not fully effective. There are only available controls to reduce effort further if the stock approached any designated PRI Monitoring and stock assessment Monitoring has largely relied upon weight measurements taken from the processor and sampling lengths from the landings. In length and weight measurements were conducted every month at Atlantic Seafood fish factory and at 4 landing sites. In 2014, such sampling was conducted twice, before and after closure of the 1 mile zone, but only at 4 landing sites. There are overall three potential sources of information from routine data collection: Artisanal landings data are collected from the main landing sites based on a frame survey of vessels. The objective of this is primarily to estimate total catches of the fisheries sector across all fisheries. Although this provides a complete picture, the information specific to the sole fishery is not precise. The last report of the catch survey was in 2009 (DoFish, 2009), but total catch estimates have continued. The industrial catch and effort is fully reported for each vessel. The exporter collects information on production by commercial category (weight category) and species for purchases that are destined for export. The measurements themselves are valid and these data formed the basis for initial stock assessments. However, relationships between length and weight are not accurately determined, suggesting that the relationship between weight and age may also not be accurate. Sufficient length samples have been collected in some periods from some landing sites, which have been used in recent stock assessments. These sources of information are available to estimate an indicator of stock status. Length and weight data have been used to estimate fishing mortality, but landings and associated CPUE data have not yet been used. A CPUE abundance index may, if correctly estimated in particular, be useful. It should be possible to calculate an index for each fleet (e.g. artisanal gill nets and industrial trawl) and review whether any might be proportional to abundance. A relative abundance index would allow the monitoring of biomass trends and could allow stock assessment if the index time series is long enough. The CPUE may need to be standardised based on month caught, gear and vessel or landing location. However, it is not clear that these data do provide a reliable abundance index, and this approach has not been used. Review of 2909R01B 21 ME Certification Ltd

23 the data and index could at least provide a way to improve data collection so that such an index could be developed. Non-routine data have also been collected for various purposes: Mbye and Jatta (2012) report a demersal fish survey conducted in May 2012 estimating the biomass by depth strata within the Gambia zone. Cynoglossus senegalensis (red sole, called Solea senegalensis in the report) was estimated to be 2.5t and Synaptura cadenati (black sole) was estimated to be 13.4t. These clearly underestimate the total biomass of these species, since the catches greatly exceed these values. Unfortunately if any size sampling of the survey catch of these species was done, it is not reported. A significantly large proportion of S. cadenati biomass (63%) was found at depths greater than 50m, where access may be more limited (gillnets may not routinely operate at this depth). All C. senegalensis was caught at depths less than 50m. Otherwise the smallcatches of sole implies that the low sole catchability for the trawl survey makes this information of limited value. Some preliminary work has been completed reading ages from otoliths (Gabis et al., 2011). The work had limited data. Although results did suggest that the age reading was valid, there was an insufficiently wide range in size to estimate the growth curve accurately. However, the assessment tried to estimate all three von Bertalanffy growth parameters. As this was not possible, fixing (or placing stiff Bayesian priors) on t 0 and/or L may have still provided a better estimate of the growth rate (K), which would have been useful. Without some sort of formal technical review process, it may be difficult to conclude that any of these assessments are appropriate for the stock at this stage. Some sort of internal review (e.g. a scientific workshop) making key decisions on various assumptions, stock model structure and use of the data would provide good evidence to support the stock assessment. It would be much better for the assessment to make use of all available data rather than just length in determining status (e.g. separate stock assessments for each dataset or a single assessment combining all data). The fishery information provided appears to be data poor. The fishery scientists will need to develop robust methods to deal with the problems they encounter. In particular, clearer assessments of risks and uncertainty will help show whether the management decisions and any HCR is precautionary or not. Further progress with a stock assessment might be made with the information already available, but until this is complete, it is not clear whether this information is sufficient for the harvest control rule Some recommendations A clear working definition of the management units (stocks) is required. The stock assessment needs to address uncertainties, and, in its current form, particularly those related to selectivity, growth rates and natural mortality rates. It will be necessary to develop and agree one or more stock status monitoring indices and associated reference points. Candidate indices could be standardised CPUE by gear, or indices estimated from the processor weight composition and the scientific sampling length composition. All information will be required to be routinely collected and uncertainty of the estimates should be addressed. 2909R01B 22 ME Certification Ltd

24 Agreed precautionary reference points for MSY (or a proxy) and PRI will need to be established and linked to standard MSC requirements (MSY and PRI) on the basis of risk. Support for the approaches used should be obtained through a formal review process. The review should take into account the scale and context of the fishery, and balance this with the precaution being applied in management to ensure that the fishery remains stable. Some data have been provided in spreadsheets. Data may generally not be well organised, and some review of the data collection system and support for resulting recommendations may be warranted. 2909R01B 23 ME Certification Ltd

25 2.4. Principle Two: Ecosystem background Designation of species under Principle 2 Primary species (MSC Component 2.1) are defined as follows: Species in the catch that are not covered under P1; Species that are within scope of the MSC program, i.e. no amphibians, reptiles, birds or mammals; Species where management tools and measures are in place, intended to achieve stock management objectives reflected in either limit (LRP) or target reference points (TRP). Primary species can therefore also be referred to as managed species. Secondary species (MSC Component 2.2) are defined as follows: Species that are not managed in accordance with limit or target reference points, i.e. do not meet the primary species criteria; Species that are out of scope of the programme, but where the definition of ETP species is not applicable (see below) ETP (Endangered, Threatened or Protected) species (MSC Component 2.3) are assigned as follows: Species that are recognised by national ETP legislation Species listed in binding international agreements (e.g. CITES, Convention on Migratory Species (CMS), ACAP, etc.) Species classified as out-of scope (amphibians, reptiles, birds and mammals) that are listed in the IUCN Redlist as vulnerable (VU), endangered (EN) or critically endangered (CE). Both primary and secondary species are defined as main if they meet the following criteria: The catch comprises 5% or more by weight of the total catch of all species by the UoC; The species is classified as Less resilient and comprises 2% or more by weight of the total catch of all species by the UoC. Less resilient is defined here as having low to medium productivity, or species for which resilience has been lowered due to anthropogenic or natural changes to its life-history The species is out of scope but is not considered an ETP species (secondary species only) Exceptions to the rule may apply in the case of exceptionally large catches of bycatch species Retained and discarded bycatch During the initial MSC pre-assessment in September 2008, the lack of information on retained bycatch and ETP species was identified as a weakness for future management actions (Medley et al., 2008). 92 potential non-target species had been identified but insufficient data were available to allow for use of the default assessment tree. 11 species were designated as high risk including catfish species, sharks and guitarfish and the captainfish (Giant African threadfin, 2909R01B 24 ME Certification Ltd

26 Polydactylus quadrifilis). A simple risk evaluation of bycatch using attributes referring to species productivity and susceptibility (Risk-Based Framework) was applied. Overall it was determined that a medium level of risk of causing serious or irreversible harm as a result of the sole fishery was present. However, more catch-specific information would allow for a better understanding, especially if minimum sizes were to be used in management (Gabis et al., 2012a). As part of the USAID/BaNafaa Gambia-Senegal Sustainable Fisheries Project, Gabis et al. (2012a) carried out a bycatch assessment of the Gambian sole bottom gillnet fishery. The findings of this study remain to date the key source of quantitative information on bycatch in this fishery as no logbooks are completed and no observer records exist. The bycatch surveys were carried out in the landing sites of Gunjur, Sanyang, Brufut and Kartong (see Figure 11) which collectively harvest over 50% of the artisanal fishery sole landings. Encounters with ETP species were also recorded. A minimum of three trips/month were recorded corresponding to an average of 95 sampling trips per landing site (Gabis et al., 2012a). Note that by law, Gambian fishermen are not permitted to discard. All catch is landed regardless of its value, size or quantity (Gabis et al., 2012a). Cymbium spp. represented on average 21.3% of the total catch per site. The percentage composition of the other bycatch species and their likely designation under Principle 2 is shown in Table. No primary species, apart from the two sole stocks scored under Principle 1, were identified all species listed would therefore be assessed under either the Secondary Species component (2.2) or the ETP Species component (2.3). Figure 11. Location of fishing sites for bycatch characterization study (from Gabis et al., 2012a) 2909R01B 25 ME Certification Ltd

27 Gabis, et al. (2012b) note that over the last few years, there has been a change in the gillnet characteristics and fishing methods as fishermen place more emphasis on catching high value demersal fish such as catfish, grunts and croakers leading to higher nets and a looser hanging ratio albeit inconsistent over the overall length of the net. The hanging ratio of a gillnet has the potential to influence the mechanism for fish capture by changing the shape of the mesh size. A net hung with a slack hanging ratio (HR of 0) would be expected to catch fish primarily through entanglement catching a large range of sizes and shapes, thus reducing the selectivity of the gear (Gabis et al., 2012b). The authors of the study concluded that although some improvement to selection was possible, the additional work of attaching the net to the hanging lines, the difficulty of enforcement and the loss of fish makes improving the selectivity of the nets via the hanging ratio unattractive as a management measure. The National Sole Fishery Co- Management Committee (NASCOM) therefore opted instead for an increased mesh size as a management option (Gabis et al., 2013). From the 1st May 2014, the minimum mesh size for gillnets (stretched) for sole and catfish has been set at 92mm (see Fishery Co-Management Plan for the Gambia Sole Complex Amendment 1, December 2013). This increase is likely to lead to catches of significantly larger sole, catfish, sompat grunt, bigeye grunt, lesser African threadfin and butterfish according to Gabis et al. (2013). 2909R01B 26 ME Certification Ltd

28 Table 3. % catch composition of key species (not including Cymbium species) by site and risk index (as determined by Productivity Susceptibility Analysis (PSA) carried out by Medley et al., 2008). Designation under Productivity Principle 2 Common name Scientific name Kartong Sanyang Brufut Gunjur Average risk level* Main / Component Minor Red sole Cynoglossus senegalensis Primary Main Black sole Synaptura cadenati Primary Main Catfish Arius spp Secondary Main Sompat grunt Pomadasys jubelini Secondary Main Ladyfish Pseudotolithus typus Secondary Main Spanish mackerel Scomberomorus tritor Secondary Minor Cassava croaker Pseudotolithus senegalensis Secondary Main Law croaker Pseudotolithus brachynathus Secondary Main Bobo croaker Pseudotolithus elongatus Medium Secondary Main Rubberlip grunt Plectorhynchus mediterraneous Secondary Minor Giant African threadfin Polydactylus quadrifilis Secondary Minor Elegant cuttlefish Sepia elegans Secondary Minor Lesser African threadfin Galeoides decadactylus Low Secondary Minor Murax Murax duplex Secondary Minor Angolan dentax Dentax angolensis Secondary Minor Prickly puffer Ephippion guttifer Secondary Minor African sicklefish Drepane africana Secondary Minor Round stringray Taeniura grabata Secondary Minor Lusitanian cownose ray Rhinoptera marginata Secondary Minor Total % Total volume (kg) 4,103 5,035 10,641 6,649 6,607 * Based on Producitivity part of PSA. Only conducted for those species which made up less between 2 and 5% of the catch. Less resilient species are those with a medium to high risk productivity score (>1.5). 2909R01B 27 ME Certification Ltd

29 Primary species On the basis of the bycatch study conducted by Gabis et al. (2012a), no primary species were identified (see Table ), other than black sole and red sole for the red sole and black sole UoCs respectively. Both these species have been discussed in detail under Principle Secondary species The following species in Table were identified as likely main secondary species: Catfish Catfish (Arius spp.) Sompat grunt (Pomadasys jubelini) Ladyfish (Pseudotolithus typus) Cassava croaker (Pseudotolithus senegalensis) Law croaker (Pseudotolithus brachynathus) Bobo croaker (Pseudotolithus elongatus) Catfish are an important bycatch in the Gambian sole fishery, with landed volumes similar to that of the main target species. In terms of value, catfish can often exceed that of sole when sold locally and regionally as it is important to the local and West Africa market and for local food security (URI-CRC, 2014). Catfish are characterised by low productivity due to their slow growth, long lifespan, small number of eggs spawned and long incubation time, which makes them potentially vulnerable to overexploitation. There are several species of catfish harvested from Gambian waters. Recent interviews with local fishermen indicate that up to 8 species are found in saltwater while 6 are identified in estuary/freshwater environment, with species presence varying seasonally: although catfish are caught year-round, the peak is in the rainy season (April-June) (Gabis et al., 2012a). Investigation by Gabis et al. (2012 bycatch) at the beach landing sites, positively identified three species: Arius latiscutatus (black kong or rough head sea catfish), Arius parkii (white kong) and Arius heudelot (Ngunja or smooth head sea catfish), the latter being found further offshore most of the year except during the rainy season (Gabis et al., 2012a). The Gambian Department of Fisheries maintains annual landings information on catfish and landings for all species combined have increased since 2005 to levels exceeding 3,500 tonnes (see Figure 12) (Castro et al., 2013). In the Gambia, catfish are caught with several gear types: hook and line, bottom gillnet, purse seine and longlines. Gillnets are considered particularly effective when catfish are schooling and up to 2008, the majority of A. latiscutatus and A. heudelot catches were made with gillnets (see Table and Table 5). According to Gabis et al. (2012a) this changed from 2008 when fishermen started using more longlines to catch catfish (however no data are available to demonstrate this). 2909R01B 28 ME Certification Ltd

30 Figure 12. Gambian Department of Fisheries landings data for marine catfish (combined species) from (From Castro et al., 2013). Table 4. Gambian Department of Fisheries catch data for rough head sea catfish (Arius latiscutatus) by gear type from 2006 to 2008 in kg and % total catch (between brackets). Note that no data were available after From Gabis et al. (2012). 2909R01B 29 ME Certification Ltd

31 Table 5. Gambian Department of Fisheries catch data for smooth mouth sea catfish (Arius heudelot) by gear type from 2006 to 2008 in kg and % total catch (between brackets). Note that no data were available after From Gabis et al. (2012). Castro et al. (2013) carried out a stock assessment of catfish in The Gambia, based on A. latisculatus and A. parkii length frequency data collected by Gabis et al. (2013) and estimated YPR and SSBPR reference points which were then compared with length-based catch curve (LCCC) estimates of the fishing mortality rate (F). The analysis suggested that catfish experienced growth and recruitment overfishing in Catfish was included in the amended Fishery Co-Management Plan for the Gambia Sole Complex, following endorsement by NASCOM, DoFish and the Ministry of Fisheries, Water Resources and National Assembly Matters on December 17th 2013 (URI-CRC, 2014). Management measures that are likely to affect catfish catches are: Minimum mesh size for gillnets (stretched) for sole and catfish: 92mm. This mesh size revision took effect on May 1, 2014; A no take zone one nautical mile from the coastline for all fishing from May 1 through October 31 for all fish species and all gear types; Other main secondary species Other than catfish, the following main secondary species were identified based on the Gabis et al. (2012a) data: Sompat grunt (Pomadasys jubelini) Ladyfish (Pseudotolithus typus) Cassava croaker (Pseudotolithus senegalensis) Law croaker (Pseudotolithus brachynathus) Bobo croaker (Pseudotolithus elongatus) There is no recent information on stock status in Gambian waters for any of these species. It is therefore highly likely that the Risk-Based Framework (RBF) will be used in scoring the Outcome PI (PI 2.2.1) for these species. For this PI, the RBF approach consists of a PSA alone (the SICA step is no longer conducted under the CRv2.0). The PSA results for these species are presented below (as per Medley et al., 2008): Table 6. Main secondary species (other than catfish) and their PSA risk level (as per Medley et al., 2008) and corresponding MSC score for PI (Secondary Species Outcome). Species PSA risk level Likely MSC score Sompat grunt (Pomadasys jubelini) Low R01B 30 ME Certification Ltd

32 Ladyfish (Pseudotolithus typus) Medium Croakers (Pseudotolithus spp.) Medium Endangered, Threatened and Protected species (ETP) The Gambia is centrally located within the West African Marine Ecoregion (WAMER), one of the world's most biologically outstanding marine habitats. The stretch from the Saloum Delta in Senegal, The Gambia River and the entire coastline of the Gambia, as well as the Casamance river system is one contiguous area that has regional biodiversity significance (Lee et al., 2009). The region is home to a number of ETP species which may interact with the fishery under assessment, as listed in Table. The main law covering nature conservation in The Gambia is the Wildlife Conservation Act (1977) which is administered by the Department of Parks and Wildlife Management (DPWM). The Gambia has ratified the Convention on Biological Diversity, CITES, the African Eurasian Waterbird Agreement, the World Heritage Convention, the Convention to Combat Desertification, the Convention on Climate Change and the Ramsar Convention. The Gambia also participates in UNESCO s Man and Biosphere (MAB) Programme and has ratified the African Convention on the Conservation of Nature and Natural Resources and the Convention for Cooperation in the Protection and Development of the Marine and Coastal Environment of the West and Central African Region (WACAF) (Robinson, 2001). The ETP species likely to be considered during full assessment are listed in Table. This also includes the ETP species identified in the retained bycatch (Table ). Table 7. ETP species likely to be considered during full assessment of the Gambian sole gillnet fishery Species ETP status Turtles Green turtle Loggerhead turtle Olive ridley Hawksbill turtle Leatherback turtle Chelonia mydas Caretta caretta Lepidochelys olivacea Eretmochelys imbricata Dermochelys coriacea Wildlife Conservation Act of 1977, Biodiversity/Wildlife Policy and Regulation of 1999 and 2003 IUCN endangered Wildlife Conservation Act of 1977, Biodiversity/Wildlife Policy and Regulation of 1999 and 2003 IUCN endangered Wildlife Conservation Act of 1977, Biodiversity/Wildlife Policy and Regulation of 1999 and 2003 IUCN vulnerable Wildlife Conservation Act of 1977, Biodiversity/Wildlife Policy and Regulation of 1999 and 2003 IUCN critically endangered Wildlife Conservation Act of 1977, Biodiversity/Wildlife Policy and Regulation of 1999 and 2003 IUCN vulnerable Marine mammals 2909R01B 31 ME Certification Ltd

33 short-beaked common dolphin long-beaked common dolphin bottlenose dolphin Atlantic humpback dolphin Clymene dolphin harbour porpoise Bryde s whale short finned pilot whale West African manatee Delphinus delphis Delphinus capensis Tursiops truncatus Sousa teuszii Stenella clymene Phocoena phocoena Balaenoptera brydei Globicephala macrorhynchus Trichechus senegalensis All fully protected by Gambian Wildlife Conservation Act 1977 (Lee et al., 2009) Wildlife Conservation Act 1977 and the Biodiversity/Wildlife Act of 2003 IUCN vulnerable CITES Appendix II While the following sections explore the fishery s interactions with ETP species in more detail, the nature of gear (i.e. bottom-set gillnets) suggests that any interactions with birds are likely to be rare. Birds are therefore not considered further Marine turtles At least four species of marine turtles occur in The Gambia including the green, leatherback, hawksbill and olive ridley turtle. Green turtles are by far the most common and abundant, laying eggs along the remote beaches of Guinea Bissau and traveling northwards through Senegalese and Gambian waters to graze in the rich sea grasses of Mauritania (WWF- WAMER, 2003 in Lee et al., 2009). The latter three turtles are rarely recorded. While the loggerhead turtle (Caretta caretta) may also occur, its presence has yet to be confirmed (Lee et al., 2009). It has been acknowledged, however, that at present little is known about the biology and conservation status of marine turtle populations in The Gambia (Lee et al., 2009). Although a monitoring programme was set up as part of The Gambia Integrated Coastal and Marine Biodiversity Management (ICAM) Project, the most recent progress report dates from 2010 and it is unclear whether monitoring activities continue. The 2010 surveys (WWF-WAMER, 2010) coupled with reports from fishermen indicate an overall decline in the population of marine turtles using the Gambian coast for nesting, feeding, and nursery grounds. There are several possible causes for the decline in marine turtle tracks and sittings, nesting attempts, and dead or stranded turtles. Reports of interactions between juvenile marine turtles and fishermen show that turtles captured in fishing nets are typically not released alive. Either because they have died in the fishing 2909R01B 32 ME Certification Ltd

34 nets, or they are of sufficient size to be slaughtered for consumption. While there is no widescale harvesting of marine turtles, it appears incidental capture may be having an effect on resident populations (WWF-WAMER, 2010). Furthermore, artisanal fishermen have been known to purposefully capture adult turtles in known foraging grounds on days when their fishing captures are low (Lee et al., 2009). In addition to the incidental capture of marine turtles, poaching of eggs from nesting sites is also thought to have an impact on the populations. Other anthropogenic actions having a significant effect on the marine turtle population include pollution and habitat loss (WWF-WAMER, 2010). In their initial pre-assessment of this fishery, Medley et al. (2008) determined that interactions between the Gambian sole gillnet fishery and marine turtles are likely to be low, on the basis that turtles in The Gambia feed on algae that grow on the laterite reefs in shallow waters which are generally not fished by the UoA (which instead fishes on sandy substrate). However, during interviews with Gambian sole fishermen, Drammeh et al. (2011) identified several hotspots (i.e. the rocky areas of Bakau, Herr Lampabi and Berre Kunto) where interactions with marine turtles may occur. Considering the paucity of independent data on marine turtle interactions in this fishery, it is highly likely that the RBF approach will be used during full assessment unless more information becomes available. For ETP species, the RBF approach consists of a PSA alone (the SICA no longer being conducted under the CR v2.0). The results of the PSA for marine turtles in general are shown below. It should be noted, however that the susceptibility part of the analysis will require input from stakeholders during full assessment this is therefore very difficult to predict at this stage, but precautionary scoring has been applied. Table 8. Productivity analysis for marine turtles (see MSC Certification Requirements v2.0, Table PF4 for risk levels) ETP Species Age at Maturity Max. Age Fecundity Max. Size Size at Maturity Reproductive Strategy Trophic Level Produc tivity Score Marine turtles > 15 yrs (score of 3) > 25 years (score of 3) ,000 eggs per year (score of 2) cm (score of 2) cm (score of 2) Demersal egg layer - Egg clutches on beaches (score of 2) Score of 1 for green turtles; score of 3 for others (green) 2.14 (others ) 2.43 Table 9. Susceptibility analysis for marine turtles (see MSC Certification Requirements v2.0, Table PF5 for risk levels) ETP species Areal overlap (availability): Overlap of the fishing effort (UoA only) with a species concentration of the stock Encounterability: The position of the stock/species within the water column relative to the fishing gear, and the position of the stock/species within the habitat relative to the position of the gear Selectivity of gear type: Potential of the gear to retain species Marine turtles Probably less than 10% overlap with wideranging turtle populations (score of 1) Turtles are highly mobile in the water column, but are often benthic feeders (especially leatherbacks) - high overlap with fishing gear (score of 3) Entanglement net due to low hanging ratio. Any turtle caught is unlikely to escape (score of 3) 2909R01B 33 ME Certification Ltd

35 Post-capture mortality (PCM) : The chance that, if captured, a species would be released and that it would be in a condition permitting subsequent survival Susceptibility score 1.65 There may be instances where turtles are released alive, but some direct evidence of this will be required (score of 3) Table 10. PSA result for marine turtles and corresponding MSC score PSA Score MSC PSA-derived score Risk Name Category MSC scoring guidepost Green turtle Other turtles Medium Medium Marine mammals The West African manatee is a rare, elusive and low-productivity aquatic mammal widely distributed along coastal creeks, mangroves, brackish and fresh waters from Mauritania to Angola. Fewer than 10,000 individuals are thought to remain, however, and this number is known to be declining from direct hunting pressure, indirect take in fishing operations, habitat conversion, loss of mangroves, dams and pollution (IUCN 2007 in Lee et al., 2009). Considering that this is a fresh water species that can live in brackish waters where fresh water holes exist (i.e. mainly lagoons and swamps), it is unlikely that there is a significant overlap between the species distribution and the Gambian sole fishery which only takes place in coastal waters and in the main channel of the river. This species is therefore not considered further. In terms of the other marine mammals, the bottlenose dolphin is the most commonly sighted dolphin in Gambian waters and there may be a resident population in the river (Lee et al., 2009). While dolphins are present every month of the year, they are more frequently observed from September to December (Leeney et al., 2007). Both drift nets for pelagic species and set bottom gill nets for demersal fish are known to have dolphins as a bycatch (Medley et al., 2008). Although their legal status requires that dolphins are released alive, it is likely that this is not always the case based on the findings of Leeney et al., (2007): as part of the GEF-funded ICAM project, Leeney et al. (2007) carried out an assessment of dolphins in The Gambia which involved interviews with Gambian fishermen (although not specifically for the fishery under assessment). The authors found that: 31% admitted to having accidentally caught a dolphin in their fishing gear at some time; 58% suggested that other fishermen accidentally caught dolphins sometimes; 68% would keep an accidentally-caught dolphin to eat; 15% would discard the bycatch; 4% replied that they would try to release the dolphin before it died; 10% claimed they did not have any bycatch in the kind of nets they used, or that they had never witnessed any incidence of bycatch; and 60% admitted to having eaten dolphin meat at least once, suggesting that this is not an unusual occurrence. 2909R01B 34 ME Certification Ltd

36 As for marine turtles, the paucity of independent data on interactions with marine mammals in the Gambian sole fishery suggests that the RBF may have to be used during full assessment. As previously mentioned, for ETP species, the RBF approach consists of a PSA alone (the SICA no longer being conducted under the CR v2.0). The results of the PSA for marine mammals in general are shown below. It should be noted, however that the susceptibility part of the analysis will require input from stakeholders during full assessment this is therefore very difficult to predict at this stage. Table 2. Productivity analysis for marine mammals (see MSC Certification Requirements v2.0, Table PF4 for risk levels) ETP Species Age at Maturity Max. Age Fecundity Max. Size Size at Maturity Reproducti ve Strategy Trophic Level Produ ctivity Score Marine mammals (e.g. bottlenose dolphin) 5-15 years (score of 2) years (score of 2) Equivalent to less than 100 eggs per year (score of 3) >300 cm (score of 3) >200 cm (score of 3) Livebearer (score of 3) >3.25 (score of 3) 2.71 Table 12. Susceptibility analysis for marine mammals (see MSC Certification Requirements v2.0, Table PF5 for risk levels) ETP species Areal overlap (availability): Overlap of the fishing effort (UoA only) with a species concentration of the stock Encounterability: The position of the stock/species within the water column relative to the fishing gear, and the position of the stock/species within the habitat relative to the position of the gear Selectivity of gear type: Potential of the gear to retain species Marine mammals Probably <10% overlap (score of 1) Marine mammals are highly mobile in the water column - medium overlap with fishing gear (score of 2) Entanglement net due to low hanging ratio. Marine mammals are large however and may break net if entangled (score of 2 likely) Post-capture mortality (PCM) : The chance that, if captured, a species would be released and that it would be in a condition permitting subsequent survival Susceptibility score 1.28 There may be instances where marine mammals are released alive, but some direct evidence for this is required (score of 3) Table 13. PSA result for marine mammals and corresponding MSC score PSA Score MSC PSA-derived score Risk Category Name MSC scoring guidepost Medium R01B 35 ME Certification Ltd

37 Habitats The Gambia is a flat country with little elevation (max is 50 m above sea level) situated on a vast plateau of sedimentary sandstone. The continental shelf widens as you move south from Dakar, and is mostly composed of sand and large outcrops of rock. The shelf break has been pushed offshore as a result of the deltaic outbuilding (Drammeh et al., 2011). Sediment has a major factor in sole distribution and spawning, with spawning grounds described as shallow sand areas interspersed in rocky areas (Drammeh et al., 2011) this is where the fishermen target the species. In gillnets, the gear components in contact with the seabed are the anchors and the leadline. Most benthic effects of gillnet fishing occur during retrieval of the gear. At this point, the nets and leadlines are more likely to snag bottom structures or the exposed sedentary benthos. If dragged along the bottom before ascent, the anchoring system can also affect bottom organisms and structure. In areas with strong tidal currents, the nets may be pushed down onto the seabed. When moved, either by the current or while being retrieved, the net can forcibly tear organisms from the sea bottom or overturn cobbles and small boulders to which organisms may be attached (Grieve et al., 2014). Gillnets may damage and remove branched biogenic structures including kelps, sponges, and corals. Impact on less prominent structures (e.g. seagrasses) would be less plausible however (Shester and Micheli, 2011) and the anchors are generally considered to have a minor impact on the seabed, with a penetration depth of 2 mm, whereas the leadline penetration of the seabed is negligible (Grieve et al., 2014). The risk of ghost fishing due to gear loss should also be taken into consideration here. As this fishery takes place in coastal waters, any lost nets are more likely to become quickly entangled due to tidal currents. Entanglement and increased fouling in these coastal areas are likely to prevent the net from continuing to fish. Although the Fisheries Act 2007 requires that any lost fishing gear is retrieved, it is unclear to what extent this is enforced. In the absence of habitat maps providing information on the commonly encountered habitats and sensitive habitats or VMEs (vulnerable marine ecosystems) present in Gambian coastal waters, it is likely that the RBF approach will be used to score PI (Habitat outcome). With the new CR v2.0, a new approach was introduced by the MSC, i.e. the CSA (Consequence Spatial Analysis). For further information please see the MSC CRv2.0 (Annex PF7.2). The CSA is a complex analysis requiring stakeholder input for the identification of habitats impacted by the fishery, in terms of the substratum, geomorphology and biota, and for the scoring of the consequence and spatial attributes within the CSA. The complexity of the CSA is such that its outcome cannot be predicted during a pre-assessment. However, considering the operation of the fishery (i.e. targeting sole on predominantly sandy bottoms) and the gear type, it is unlikely that any direct impacts will reduce habitat structure or function to a point where there would be serious or irreversible harm. Furthermore, due to the relatively fragile nature of the gear fishermen actively seek to avoid fishing in areas where there is an immediate risk of entanglement with seabed habitats (rocky habitats) or debris such as wreckage etc. The fishermen restrict their activities to areas where there is relatively little risk of entanglement (Medley et al., 2008). It is therefore likely that the analysis will lead to a score of above 60 although it cannot be predicted whether or not a condition will be imposed Ecosystem A detailed description of the Gambian marine ecosystem has been provided by Lee et al. (2009). Unless otherwise indicated, the below background has been extracted from this source. 2909R01B 36 ME Certification Ltd

38 The Gambia has an ocean coastline of 70 km and a relatively small continental shelf area of about 4000 km 2. There are two different eco-regions of coastal Gambia: the river estuary and the ocean coastal upwelling areas. The Gambia River Estuary is the only large estuary in the West African sub region not to have been affected by extensive human disturbance and still has a natural flood regime with no dams or weirs. Since most of the river in The Gambia has a level gradient from the ocean to 500 km inland, tidal effects are perceptible up to Yarboutenda at the border with Senegal. The lower 180 km are generally brackish. Salinity ranges from full seawater at Banjul to freshwater at Georgetown. The flow of the Gambia River is typical of the tropics, with freshwater flooding the river and the lower estuary during the rainy season (July-Sept) while seawater moves long distances up river during the dry season (October-May). The Gambian coastline is located where two major oceanic currents converge along the coast of West Africa, between the cold water Canary Current which moves offshore to the north and the warm water Guinea Current which flows toward the coast to the south. The effects of these currents together with the trade winds which blow dominantly from the Sahara Desert westerly out over the Atlantic create intermittent upwelling along the coast. These upwellings, combined with the outflow of the Gambia River provide the nutrients that fuel a bountiful marine ecosystem of remarkable abundance and diversity of marine fish, mammals, turtles, and birds. An Ecopath with Ecosim model was conducted for the Senegambian ecosystem by Samb et al. (2004) in The study characterised the trophic interactions of the main organism groups (marine birds, marine mammals, large pelagics, coastal tunas, sharks, skates and rays, cephalopods, coastal demersal fish, coastal pelagic species, zooplankton, benthos and phytoplankton) and found that the ecosystem was dominated by small pelagics (Sardinella spp.) which feed on the zooplankton that is in turn fuelled by the upwelling and river runoff. This would suggest that the ecosystem is influenced by bottom-up processes rather than top-down processes. Considering that neither of the targeted sole species play a key role in ecosystem functioning and structure, it is highly unlikely that the fishery under assessment would disrupt ecosystem function and structure to a point where there would be serious or irreversible harm. In 2002, a Regional Strategy for Marine Protected Areas was developed with the support of IUCN, the Fondation Internationale du Banc d'arguin (FIBA), WWF and Wetlands international, for a subset of six countries in this region (Mauritania, Senegal, The Gambia, Guinea-Bissau, Guinea, and Cape Verde). Its aim was to create an effective network of MPAs in the WAMER region with participatory management, led by strong institutions contributing to the sustainable development of the region by enhancing natural and cultural diversity. To implement the strategy, a five-year Regional Conservation Programme for the Coastal and Marine Zone of West Africa (PRCM) was developed and a seventh country, Sierra Leone, was included in the regional programme after joining the Sub-Regional Fisheries Commission (CSRP). The Regional Network of MPAs in West Africa (RAMPAO) was formally launched in April 2007 and comprises 23 MPAs in six countries, including 15 MPAs in four countries (Mauritania, Senegal, The Gambia and Guinea Bissau). The following MPAs currently exist in The Gambia (UNEP-WCMC, 2008): Parc National de Niumi Reserve des Rives de Tanji et de l Ile de Bijol Reserve de la Zone Humide de Bao Bolong Parc National de Tanbi The use of the ecosystem-based management approach to fisheries management (EBFM) that focuses on conserving the underlying health and resilience of the ecosystem, thus maintaining the system s goods and services and leading to increased productivity is defined 2909R01B 37 ME Certification Ltd

39 in the Fishery Co-Management Plan for The Gambia Sole Complex. It is unclear however to what extent this EBFM is being implemented in practice Principle Three: Management system background Institutional framework The fisheries management in The Gambia is the responsibility of the Ministry of Fisheries, Water Resources and National Assembly Matters and its Department of Fisheries (DoFish). The Fisheries Department is organized with the following structure of divisions: Directorate and Administration Division, Research and Development Division, Extension Services Division and Inspectorate Division. A considerable part of the DOF staff (the extension officers) are located at fish landing sites. The legal and management framework for fisheries in The Gambia is provided by the Fisheries Act 2007 and the Fisheries Regulations The Secretary of State (Minister) is responsible for the administration of the Fisheries Act and supervises the Director of Fisheries who is responsible for a broad range of matters including the conservation of fish stocks, the management and development of aquaculture and fisheries and the preparation and periodic review of fisheries management and development plans. Article 5 of the Fisheries Act 2007 established a Fisheries Advisory Committee. Among the tasks of the Committee is the provision of advice to the Secretary of State on policies, on fisheries management and development plans, and on the review of those plans. The Fisheries Act 2007 also lays down the framework for community-based fisheries management. The Secretary of State may establish Community Fisheries Centres (CFCs) and may declare Special Management Areas and give authority to the CFCs to manage the fisheries resources within them. CFCs had already been established in the 1980s. Up to the time of enactment of the Fisheries Act in 2007 the mandate of the management committees of the CFC however was limited to the management of fisheries infrastructural facilities at the landing sites such as individual lockers for fishermen to keep outboard motors, fishing nets and other gears; mechanical workshop; boat building yard; fish smoking houses; fish drying platforms; fish handling area; and office building. Nowadays the CFCs also manage additional facilities such as ice-making plants and chill rooms (Tobey et al., 2009). On 17 January 2012 however the Fishery Co-Management Plan for The Gambia Sole Complex was officially signed by the Minister and Director of Fisheries (and published in the Gambian Gazette) and for the purpose of this management plan, a special management area for the sustainable management of the sole fishery was designated. The National Sole Fishery Co-management Committee (NASCOM) and its associated landing site committees (LACOMS) through the Community Fisheries Centre s Management Committees were delegated the exclusive rights to the artisanal sole fishery and the responsibility for its sustainable management within this special management area. The NASCOM consists of representatives from the fishing communities, fish mongers and processors, LACOMS, the Gambian Artisanal Marine Fisheries Development Association (GAMFIDA), the National Association of Artisanal Fishing Operators (NAAFO), municipalities, the Department of Fisheries and the industrial sector. Advisors to the NASCOM include the Fisheries Advisory Committee and the BaNafaa Project. NASCOM has established its own Constitution and a Dispute Resolution Committee. Existence of this committee is formalized trough the Constitution of NASCOM. The purpose of the Committee is to solve disputes before they come to Court. The setup of the LACOMs and NASCOM was facilitated by the BaNafaa project, a five-year regional initiative supported by the U.S. Agency for International Development (USAID)/West Africa Regional Mission. This project was implemented through the University of Rhode 2909R01B 38 ME Certification Ltd

40 Island (URI)-USAID cooperative agreement on Sustainable Coastal Communities and Ecosystems (SUCCESS). The World Wide Fund West Africa Marine Eco Regional Program was a regional implementing partner (CRC, 2014) Fisheries regulations The fisheries in The Gambia are governed by a well-developed set of regulations. In 1977, the Government enacted the first Fisheries Act as the legal basis for fisheries management. The Act was revised in 1991 giving rise to the Fisheries Act The issues addressed in the Fisheries Act 1991 concern territorial and zonal boundaries, nationality criteria for Gambian vessels, appointment of agents, control over the import of fishing vessels, requirement for storage of fishing gear and associated penalties. Fisheries access agreements are also treated in the act and, in addition to being subject to normal conditions of license, foreign fishing vessels may be subjected to other controls and conditions aimed at the protection and conservation of resources and the promotion of infrastructural development, training and research. In 2007 the fisheries act was revised again and the Fisheries Act (2007) is now in force. The 2007 act introduced very high fines for illegal fishing and illegal exporting of fish. The Fisheries Act empowers the Minister of Fisheries, Water Resources and National Assembly Matters and the Director of Fisheries to declare Special Management Areas for purposes of community-based fisheries management; establish open or closed seasons for specified areas and fish stocks; define minimum fish size regulations; and impose gear and fish method restrictions. In 2008 the Fisheries Regulations 2008 came into force. The Fisheries Regulations 2008 contain several new licensing provisions and conservation measures. Under the new regulations fishing trawlers less than 250 GRT shall not fish within 12 nautical miles of the low water mark. Fishing trawlers above 250 GRT shall fish outside the 15 nautical mile zone. The requirement for trawlers less than 250 GRT has been amended to 9 miles in February 2009 (Tobey, 2009). So since then the artisanal fleet has the exclusive fishing rights within this 9 mile zone. The Fisheries Regulations 2008 also (for the first time since the 1980s) contain licence requirements for the artisanal fleet. A commercial fishing canoe which is entered in the Register of Commercial Fishing Canoes shall be given a number and a permit signifying that it is registered as a commercial fishing canoe. A person whose name is entered in the Register of Commercial Fishing Canoes shall, on payment of the fee prescribed in Schedule II, be given a registration card and number signifying that he or she is registered as a master or an owner of a commercial fishing canoe. The licence fee for registration as a commercial fishing canoe is prescribed in Shedule II of the Fisheries Regulations and amounts to 750 Dalasies per annum for a motorized commercial fishing canoe. Although the Fisheries Regulations prescribe the registration of all commercial fishing canoes it has not been until very recently that the fisheries authorities have announced the implementation of this registration system. On a press conference held on 11 December 2014 the permanent secretary of the Ministry of Fisheries has stated that canoe registration will start in January However due to special circumstances the implementation of the license system has been delayed until further notice. In the Fisheries Regulations a list of minimum mesh sizes for different fisheries and gear types is included (Shedule XXVII). The minimum mesh sizes for bottom gill nets targeting sole is defined at 80 mm. This was increased to 92mm in December 2013, but the increase has not yet been fully implemented. The Regulations also contain a list of Minimum Fish Length Limitations (Shedule XXVIII). The minimum size limit for sole is set at 30 cm. Bilateral Fisheries Agreement with Senegal. 2909R01B 39 ME Certification Ltd

41 An important feature of fisheries management in The Gambia is its bilateral agreement with Senegal (The Senegal-Gambian Agreement on Maritime Fisheries, 1982). According to the agreement, fishers can fish in either country provided they abide by the laws of the country where they are fishing. For industrial fishing vessels there is a limit on the total maximum tonnage of fishing catch capacity. The bilateral fisheries agreement was due to be renegotiated in 2010 but it has not been renewed. Nevertheless Senegalese canoes have continued fishing in Gambian waters and form the larger part of the fleet targeting sole in Gambian waters. Department of Parks and Wildlife Management (DPWM) The responsibility to develop, manage and conserve Gambia s biological resources in wildlife protected areas is vested in the hands of the Department of Parks and Wildlife Management (DPWM). Created in 1981, the DPWM currently manages seven wildlife protected areas. These protected areas cover almost five percent of the total land area of the Gambia, and include a range of designations (e.g. national parks, nature reserves, wetland reserves). For the purpose of implementing the Convention on Biological Diversity it is the lead government institution. There are five functional units: Directorate; Conservation, Education and Extension Unit; Parks and Protected Area Management Unit; Research, Crop damage Assessment and Control Unit; Surveillance Unit Management objectives Management objectives for the fisheries in The Gambia are formulated in the Fisheries Act 2007, the Fisheries Regulations 2008, The Fisheries Policy 2007 and The Gambia National Strategic Plan for the Fisheries Sector Further objectives are formulated in the Fishery Co-Management Plan for The Gambia Sole Complex. The Fisheries Policy 2007, stipulates the following policy objectives: To effect a rational and long-term utilization of the marine and inland fisheries resources; To use fish as a means of improving nutritional standards of the population; To increase employment opportunities in the sector; To increase the net foreign exchange earnings; To increase and expand the participation of Gambians in the fisheries sector; To develop aquaculture; To improve institutional linkages with other relevant sectors; To improve the institutional capacity and legal framework for the management of the fisheries sector, and; To strengthen regional and international collaboration in the sustainable exploitation, management and conservation of shared stocks and shared water bodies, promote bio-diversity maintenance and enhancement and prevent environmental degradation. The Fisheries Act 2007 contains the following guiding principles to which consideration and priority shall be given in the exercise of any powers and functions under this Act: a) ensuring the long-term conservation and sustainable utilization of the aquatic living resources to meet the needs and aspirations of present and future generations; b) avoiding, minimizing and mitigating the adverse effects of fishing and aquaculture on the aquatic environment; 2909R01B 40 ME Certification Ltd

42 c) application of precautionary approaches to the conservation, management and development of fisheries and aquaculture; d) conserving the biodiversity of the aquatic living resources, their ecosystems and habitats; e) conserving the aquatic ecosystems as a whole, including the species targeted and non-targeted for exploitation and their associated or dependent species; f) minimizing pollution, waste, discards, by-catch toss or abandoned gear and impacts on associated or dependent species, through measures, including, to the extent practicable, the development and use of selective environmentally safe and cost effective fishing gear and techniques; g) application of management practices based on sound management principles and the best scientific information available, to be gained through national and international research programmes; h) collecting and sharing in a timely manner and in accordance with fisheries management agreements and international law, complete and accurate data concerning fisheries and aquaculture as well as information from national and international research programmes; i) preventing or eliminating over-fishing and ensuring that levels of fishing effort do not exceed those commensurate with sustainable utilization of fisheries resources; j) taking into account the interests of artisanal and subsistence fishing and minimising, to the extent practicable, fishing conflicts among users; k) implementing and enforcing conservation and management measures through effective monitoring, control and surveillance; l) promotion of broad and accountable participation in the conservation, management and sustainable development of fisheries and aquaculture The Fishery Co-Management Plan for The Gambia Sole Complex contains another set of specific objectives of the management for the sole fishery: Economic Increase yield of catch (size of fish and number of fish) Increase profit to fishermen and processers Improve quality of fish landed Increase market demand (MSC) Biological Decrease catch of undersize fish (bycatch and discards) Decrease catch of a bycatch species that is overfished Allow more fish to spawn and grow Social Increase safety at sea Reduce conflict between fishermen Increase compliance Capacity building, education and training for fishermen Behavioral changes to act responsibly Ecological To conserve the integrity and resilience of the aquatic ecosystem for continued productivity and sustained livelihoods for people dependent on the ecosystem. 2909R01B 41 ME Certification Ltd

43 Fishery Co-Management Plan for The Gambia Sole Complex As already mentioned in Section a co-management system for the Gambian sole fishery has been developed in recent years in the framework of the BaNafaa project. The goal of this five-year project (May 2009 /April 2014) was to build further on the efforts of the Department of Fisheries to involve fishers in the management of fisheries resources through the community fisheries centers (CFCs) and their management committees. The project sought (among other goals) to increase social and economic benefits to artisanal fishing communities, and strengthen institutional capacity to implement an ecosystem-based, comanagement approach to sustainable fisheries (CRC, 2014). The project facilitated and funded the establishment of management institutions (NASCOM and LACOMs), as well as research (discard studies, sole and catfish stock assessments, mesh size studies). The project also supported the development of the sole co-management plan through workshops on co-management, directed trainings, collaborative research and capacitybuilding activities. Much of the knowledge about sole was provided by the fishermen and the industry using local knowledge data gathering methods and confirmed through collaborative research techniques. The development of the co-management plan benefitted from the fact that a strong legal basis for the implementation of a co-management regime was already in place (see Section 2.5.2). In the sole management plan NASCOM and its associated LACOMs through the Community Fisheries Centre Management Committees are designated as having exclusive use rights to the sole fishery in the sole fisheries zone from the Atlantic shoreline and shorelines adjacent to the estuarine areas of The Gambia River out to 9 nautical miles. The plan defines the following principles for management of the sole fishery: the use of traditional and local knowledge in the data poor systems that characterize The Gambian fisheries the use of the precautionary approach which states that the absence of adequate scientific information should not be used as a reason for postponing or failing to take conservation and management measures, the use of the adaptive management approach that requires that decisions be made quickly and actions adjusted accordingly the use of the ecosystem-based management approach to fisheries management (EBFM) that focuses on conserving the underlying health and resilience of the ecosystem, thus maintaining the system s goods and services and leading to increased productivity. The plan includes an overview description of the fishery, status of the fish stocks, describes the legal basis for management, and details the management objectives and related measures to achieve those objectives and means for enforcement monitoring and evaluation of the plan. A number of key technical supporting documents are mentioned in the plan as part of the Appendix and these can be downloaded from The plan also describes how management responsibilities are shared within the sole fisheries co-management system between NASCOM, the Department of Fisheries and the LACOMs. The NASCOM will take the lead to establish a sole national co-management committee. The committee will have authority to jointly (with Government): Set management objectives Establish fishing rights based approaches to management 2909R01B 42 ME Certification Ltd

44 Assist and be involved in enforcement Update management plan Assist in communication with all stakeholders Assist in research In cooperation with the Department of Fisheries NASCOM will: Establish harvest rules appropriate to management objectives Participate in international fishing agreements Management measures The co-management plan has been signed by the Minister and Director of Fisheries in January 2012 and has been officially gazetted in December The following management measures for the sole fishery have been established by the plan: 1) Minimum fish size: 25 cm total length. 2) Minimum mesh size (stretched): 80 mm, increased to 92mm in December ) Prohibition on use of drift nets in the Gambia River. Additionally a one nautical mile zone has been closed (during the spawning time) for all fisheries from May through October. In December 2013 the Minister of Fisheries, the Director of Fisheries and the President of NASCOM have agreed to a formal amendment to the co-management agreement for the sole fishery. With the signing of a Memorandum of Understanding on 16 December 2013 the exclusive use right to the catfish stocks in the Special Management Area were also given to NASCOM. The MoU states that sole and marine catfish must be managed jointly as a multispecies fishery. In the MoU it is further stated that the minimum mesh size for the sole fishery is increased from 80 to 92 mm. Research priorities The co-management plan also describes the research needs that have been developed through discussions with NASCOM and the Department of Fisheries. Guidance on the research needs have been identified based on the initial MSC pre-assessment for this fishery (Medley et al., 2008). It is stated that research needs will be updated on an annual basis and that several of the research items have already been initiated. In the MoU of December 2013 additional research priorities for marine catfish are described Consultative process The Fisheries Act 2007 states as one of the guiding principles of fisheries management the promotion of broad and accountable participation in the conservation, management and sustainable development of fisheries and aquaculture. As described in previous sections, systems for stakeholder involvement in the decision-making process are well developed and as it concerns the sole and catfish fishery management responsibilities are given to the fisheries sector. The management of the sole fishery through NASCOM and the LACOMs involves elaborate consultation processes. All stakeholders in the fishery are represented in either community fisheries centres (CFCs), LACOMs or NASCOM. Before any management measure is adopted it will be discussed in order to reach consensus on adoption and implementation. One of the formal management principles of the sole co-management plan is the use of local knowledge in the management process and of course this will require the consultation of people with field experience in the fishery. 2909R01B 43 ME Certification Ltd

45 The Fisheries Act 2007 states that the Director of Fisheries shall prepare and keep under continual review plans for the management and development of fisheries and aquaculture. In the preparation and review of each plan, the Director shall consult, as appropriate, with: Other Departments of State and other Government agencies concerned or affected by the plan; Community Fisheries Centres concerned or affected by the plan; Fishermen cooperatives and associations and other bodies representing fishermen, fish processors or aquaculture producers; Fisheries management bodies of other States in the region and sub-region and regional or sub-regional fisheries organizations, with a view to ensuring the harmonization of their respective fisheries management and development Plans; Other persons or groups of persons affected by the plan Monitoring, control and surveillance (MCS) Inspection at sea is carried out by the Gambian Navy. The Gambian Navy has 2 inspection vessels. It has however been stated (Tobey et al., 2009) that The Gambia lacks the capacity to effectively monitor and control the activities of industrial vessels operating illegally. In spite of restrictions, industrial fishing vessels, equipped with echosounders and fish finding devices follow fish and encroach on more productive artisanal fishing grounds usually by night, causing considerable damage to artisanal fishing gears and violating fisheries regulations. Although a VMS system is mandatory through the Fisheries Regulations 2008 the requirement is not implemented. The inspection vessels of the Gambian Navy do not inspect the activities or artisanal canoes at sea. Inspections are only carried out by extension officers when canoes land their fish at the fish landing sites. Mesh size of nets and sizes of fish landed can be controlled there. Since the closure of the one nautical mile zone NASCOM operates 3 fibre boats with 15 hp outboard engines that can carry out inspections. These boats are now based in Gunjur, Tanji and Bakau and are used for surveillance during the time the 1 mile nautical zone is closed. Inspections are carried out with officers of the fire service (rescue) stations on board. The inspections at sea also control on mesh size used. The 1 mile zone was closed for the first time in May Both in 2013 and 2014 inspections have taken place and in total around 20 boats have been arrested and fined. Considering the minimum mesh size of sole nets the MoU of December 2013 has increased the minimum mesh size of sole nets to 92 mm. Nets of 80 mm mesh size are however still in use. The minimum landing size (MLS) for sole is 30 cm according to the Fisheries Regulations The Fisheries Regulations state that any under-sized or unlawfully caught fish shall be immediately returned to the fisheries waters if the fish can live. But there is another statement in the regulation that says that any dead or dying under-sized or unlawfully caught fish shall be landed. In practice the artisanal fleet lands all fish that is caught except maybe a few species that are not considered edible. In the sole co-management plan it is recognized that all fish caught are landed and the MLS for sole is set at 25 cm. Figure 13 shows that most sole landed are above the minimum landing size of 25 cm. 2909R01B 44 ME Certification Ltd

46 Figure 13. Sub-sample of Length frequency of red and black sole captured by gillnet in four main landing sites for a one year period (Kartong, Sanyang, Brufut and Gunjur).Source: sole co-management plan. Catch registration At all fish landing sites in The Gambia extension officers of the Department of Fisheries carry out the catch registration. For every canoe sampled Engine HP, fishing time and number of crew are noted on a Catch Assessment Survey form together with the number of kilos in the unit used for measurement. The total kg of fish per species is noted on the form. Since not all canoes can be sampled the number of samples is noted together with a raising factor. Data are sent to the Statistical Unit of the Department of Fisheries Management Evaluation and Review The regular review of management is formally established in the Fisheries Act The Act states that the Director of Fisheries shall, under the supervision of the Secretary of State, be responsible for the preparation and periodic review of fishery management and development plans. As described in Section the Director shall when preparing or reviewing a management plan consult with all stakeholders described in the Act and also with any other persons or groups of persons affected by the plan. Section 13 of the Act states that there may be a management committee that will be primarily responsible for the implementation and review of the management plan. Concerning the co-management plan for the sole fishery NASCOM is established as the management committee. The co-management plan states that the fisheries measures in the plan should be evaluated on an annual basis and reviewed as outlined in section 8.5 of the plan. Section 8.5 requires that there will be an annual meeting between the Department of Fisheries and NASCOM and other interested stakeholders to review progress on meeting the objectives of this management plan. These reviews should: 2909R01B 45 ME Certification Ltd

47 (1) Respond to any changes in stock assessment and stock status, If overfishing is occurring: The Department of Fisheries will inform NASCOM of assessment results and suggest appropriate reduction in fishing that needs to occur. NASCOM will work with LACOMs and instigate immediate action to reduce fishing effort. This may involve closing the fishery or prohibition of gear types, or restrictions on fishing time, area and possibly quotas. (2) Evaluate degree of compliance with management measures and rules including spawning areas. Enforcement reports should be prepared and presented quarterly to the NASCOM and the Department of Fisheries for review by LACOMs, Fisheries Officers, and the Department of Fire and Rescue Services. If infractions are occurring, there may be a need to better inform the fishing community of the management measures in place and/or education about conservation of the resource. This will be discussed at annual meetings of NASCOM. (3) Evaluate enforcement actions and penalties: Enforcement reports should be prepared and presented quarterly as above to the NASCOM and the Department of Fisheries for review. If infractions are occurring, there may be a need to adjust fishing penalties. Update on status of funds from fines. Amount collected and disbursed. (4) Evaluate committee structure and membership, if changes needed. (5) Degree to which biological, ecological, social and economic management objectives outlined in the plan are being met. Discussion at annual meeting. (6) Reassess research priorities at annual meeting between Department of Fisheries and NASCOM. 2909R01B 46 ME Certification Ltd

48 3. Evaluation Procedure 3.1. Assessment methodologies used The pre-assessment was conducted in accordance with the MSC Fisheries Standard v2.0 and pre-assessment reporting template version Summary of site visits and meetings held during pre-assessment A pre-assessment site visit was held from the 9 until 12 February 2015 in The Gambia. Meetings were organized by the client s representative Dawda Saine. The meetings held are listed in Table 3. Table 3. Meetings held during the pre-assessment site visit Date/time Organisation Name Position 9 Feb AM Ministry of Fisheries Fatimah Jallow Momonu Kanyi Sosseh Nfamara K. Dampha Dawda Saine Deputy Permanent Secretary Senior Assistant Secretary Assistant Secretary NASCOM excecutive secretary AM Fisheries Department Dawda Saine NASCOM excecutive secretary Salifu Ceesay Fisheries Assistent Statistical Unit Amadou Jallow Fisheries Assistent Statistical Unit 10 Feb AM Department of Parks and Wildlife Management Ousainou Touray Dawda Saine Assistant Director PM Atlantic Seafood Michel Huijser CEO Ndene Jallow Factory Manager Lamin Sanyang Assistant manager Dawda Saine NASCOM excecutive secretary 11 Feb AM NASCOM (Figure 14) Eliman Sarr President Kadijatou Jallow Vice-president Dawda Saine NASCOM excecutive secretary Nyma Coibba Assistant Secretary Ousman Bojang Treasurer & president GAMFIDA Isatou Ndeng Assistant treasurer Momoudou L. Sanneh Auditor Mustapha Yarbou Assistant auditor 2909R01B 47 ME Certification Ltd

49 12 Feb AM LACOM Brufut Amie Jallow Fisheries Department Brufut Momodou Sanneh Kadijatou Jallow Eliman Sarr Ousman Bojang Kajali Jarjou Kebba Bojang Ismaela Jagne Auditor NASCOM president LACOM Brufut, vice president NASCOM president NASCOM Treasurer NASCOM & president GAMFIDA Fisheries Department Brufut LACOM Brufut LACOM Brufut Figure 14. Meeting with NASCOM (11 February 2015) After the meeting with LACOM in Brufut at the office of the Fisheries department the Brufut and Tanji landings sites were visited (see Figure 15). 2909R01B 48 ME Certification Ltd

50 Figure 15. View of the landing site at Tanji Stakeholders to be consulted during a full assessment During full assessment, the following stakeholders should be consulted. Note however that this is not an exhaustive list: Ministry of Fisheries Directorate of Fisheries (DoFish) Gambian Navy (Inspection at Sea) National Environment Agency (NEA) WWF (office closed) Ministry of the Environment Department of Parks and Wildlife Management (DPWM) LACOMs The Association of Gambian Fishing Companies (TAGFC) Harmonisation with any overlapping MSC certified fisheries No overlapping fisheries (in terms of Principles 1, 2 or 3) are currently MSC certified or in assessment. No harmonisation would therefore be required. 2909R01B 49 ME Certification Ltd

51 4. Traceability 4.1. Eligibility of fishery products to enter further Chains of Custody Landing sites for sole on the coast are (from North to South) Barra, Banjul, Bakau, Brufut, Tanji, Bato Kunku, Sanyang, Gunjur, Kartong (O. Bojang, pers.comm.). On the River Gambia sole is landed at the Lower River North Bank (Albreda, Kerewan, Ballingho) and at the Lower River South Bank (Mandinary, Bintang, Tendaba). The main sole landing sites in Gambia are located at the coast and these are Kartong, Gunjur, Sanyang and Brufut. Sole is also imported from Senegal (Kafuntine landing site south of Gambia). In the Gambia most landings of the high value fish species (such as octopus, cuttlefish, shrimp and sole) are exported to markets abroad and the final main destination of the fish is Europe. The only company currently exporting processed sole to Europe (Atlantic Seafood) purchases 100% of its supply from the artisanal sector. Other companies may also purchase sole from the industrial fleet (Medley et al., 2008). The following risks to traceability were identified during the pre-assessment: - Vessels in the UoC may fish in both Gambian and Senegalese waters under the bilateral agreement. There are no provisions in place that ensure that any red and black sole landed stem from Gambian waters (i.e. those included in the UoC); - Senegalese vessels may fish and land sole in The Gambia. There are no processes in place which would prevent substitution of MSC and non-msc sole at the point of landing; - There is no traceability system in place which links MSC sole landings to a specific vessel. Catch Assessment Survey forms do provide these details, but these are only available for a subsample of vessels that land sole; - Weakness of the MCS system: no inspections are carried out at sea and it is not clear to what extent the regulations are consistently enforced. Sole may thus be caught with gear types other than as specified in the UoC, and outside Gambian waters. - From URI-CRC (2014) the assessment team understands that some landings of industrially caught sole may also take place at the recently opened commercial fishing port in Banjul. Traceability and segregation systems would therefore have to be in place at the port to ensure certified artisanal sole cannot be substituted with non-certified industrially caught sole. - Any MSC fisheries certificate is likely to only cover the fishery up to the point of landing. All subsequent steps in the supply chain would therefore be subject to separate Chain of Custody certification. This is of particular concern as sole are also imported from outside the UoC. 5. Preliminary evaluation of the fishery 5.1. Applicability of the default assessment tree and use of the RBF No revisions to the default assessment tree as specified in Annex SA of the MSC Certification Requirements v2.0 are likely to be required. The risk-based framework (RBF) is an alternative evaluation system for some Performance Indicators (PI), based on an acknowledgement by the MSC that in some cases quantitative data and formal stock assessments may not be available. In this case, the use of the default assessment tree becomes difficult and the RBF is triggered. 2909R01B 50 ME Certification Ltd

52 The RBF can be used for outcome PIs (PIs which are scored on the basis of the actual situation as opposed to the management system or the information available). These PIs are shown in Table 45 together with the criteria that trigger use of the RBF. Table 4. Criteria for triggering the use of the RBF (from MSC CR v2.0) (PISG: performance indicator scoring guidepost) In this case, it is anticipated that the RBF may be used for the PI (Secondary species outcome), PI (ETP species outcome) and PI (Habitats outcome). An explanation of the data-deficiencies for each PI is provided in the relevant sections under Principle Evaluation of the fishery The fishery has made progress against the MSC standard since the last pre-assessment with a number of initiatives improving the fishery management. By its very nature, an MSC pre-assessment tends to focus on the negative aspects of a fishery, rather than more positive aspects, so the fishery should persevere with its improvements since there has been clear progress in addressing gaps. 2909R01B 51 ME Certification Ltd