I had a very “brainy” 10 days of work so far, that challenged my big picture thinking about the integration of Catch Certification, Fisheries Information Management Systems, Monitoring, Control and Surveillance, Port State Measures, and administrative burden.
The week started with a trip to Eureka, an aptly named area in the hills inland from Byron Bay in the north of NSW (Australia) at the farm that host the development and training “centre” (a.k.a. pukpuk haus) of the Integrated Fisheries Information Management System (iFIMS) crew.
We have known each other for a while now, I remember the fist time I presented my “fish accountancy” vision, they got it instantly and their database was able to provide the results… so we been collaboration since then, but I have not been to the “iFIMS central” as yet.
It was great… as I got to understand some of the architecture of the system, besides contributing some “fish and regulatory" insides to their really incredible set up. Moreover, what was more interesting for me, was to get to know some of them at a “human” level and confirm that what I expected; they are “believers” in the data as transparency conduit. Is more than just a job that pays the bills for them.
Data does not lie…. And the tool they have developed is the best tool I know (and is my job to know!) that can guarantee transparency around fisheries. However (as any tool), it only helps the people that handles them… it does not replace them.
From there, we flew to Nadi in Fiji for the Pacific Islands Fisheries Forum Agency (FFA) Catch Certification Schemes (CCS) Workshop, following up on a initial talk we had in PNG some months ago. It was a full house with all of the FFA and PNA member countries.
Figure by Gilles
The idea is to move ahead with pacific wide CDS, hopefully under the umbrella of the WCPFC. We had the presence of my friend and colleague Gilles Hosch from the FAO/ABNJ programme that put his “vision” based on his year long work analysing all the present CCS and CDS (Catch Documentation Schemes) that exist.
The view of almost all of the present schemes is the one of a Fishery led scheme (from the fishery to the market), they represent a shared concern among fishing States (both flag and coastal) port States and market States to identify legal and authorised fish and provide market access only for such fish.
In a nutshell Gilles key views are:
- A CDS is a global traceability system
- A competent authority certifies a batch of legal catch by issuing a catch certificate (CC)
- The CDS traces the movement of this certified batch from unloading, through processing and trade, into the end market
- In essence, lots are traced by linking catch certificates to resulting trade certificate(s)
- CDS detects “non-originating” fish inside the system and nullifies its value
The ideal CDS work on mass balances for the fish that is traded in between countries. Each country in the chain takes care of what happens inside its borders, if the mass balance does not add up (more fish out than in), then the export is not authorised. The overall view for this system is as below:
Gilles masterplan
When I understood his “macro” view, I found that my work around the Fish Unloading Authorization Code and the “Fish Accountability” inside a country (which is actually possible by using a tool like the prior mentioned iFIMS), fitted nicely inside each the countries “black boxes”, as you see below:
If it only was soo easy :-)
The 1st step is to prove that the fish was caught legally, and my concept is based in the simple fact that “Fish does not become IUU during processing, but is either caught or landed illegally”, so it “mixes” two basic elements, the requirements of Port State Measures Agreement (PSMA) and a Key Data Element (KDE) needed to follow a landing through the value chain.
No doubt all these CCS/CDS discussions where catalysed by the EU’s IUU regulation. And perhaps this is a good occasion to make my views clear in this regard: 6 years ago the concept of IUU was only known to people working on it, today the IUU issue is at the forefront of the public attention, all this is no small measure a result of the EU IUU regulation.
My reservations and criticism has always been directed to the Catch Certification Scheme itself, and not to the aims of the regulation.
My views are about the practicalities arising from its design and the later implementation of the “weight in notes” in August 2010, making it a export certificate raised by the exporters instead of a catch certificate raised by the vessels (as it was originally intended).
The EU system is a market based system as you see on the left. It looks “backwards” to the vessel from the exporters to the authorities based 3 countries away in the value chain, for operations that happened months or years ago.
A big part of my work is to facilitate the understanding and implementation of the EU CCS system to non EU countries countries, so I know the complexities of the CCS from their perspectives. Therefore my views are always intended to make it more sustainable in the long term by twinning on its implementation (hence facilitating adoption) without diluting its objectives.
As an example, I’m in a Pacific Island Country since yesterday, evaluating the implementation of the procedures they have generated to validate their Catch Certs for the EU, while we work on the implementation of a e-system under iFIMS that is being designed. I just went over a CC for product exported this week out of transhipments in port and landings done in February 2014. The paper trail is 38 pages long for 50 tons of product... dealing with this has a massive impact in terms of the administrative burden it puts on the fishery administration of this developing country, specially because is not web-based.
We know that the EU is not going to change the implementation of system at all over the next years, so what we trying to do is to create our own internal system as to be able to limit the paper and time involvement by "coding" all the events from the catch onwards and have a “forwards” looking system. And when the product is going to the EU, we can trace back electronically all the events and “fish accountancy” as to print the paper certificate they request, until the day a e-system is in place (as the EU has on the sanitary side under TRACES) so then the e-certs can be “pushed” into their system.
The Pacific has been talking about a WCPFC CDS for a few years now, but complexities on the understanding, the fear of disproportionate burden, the interference of some DWFN, plus the costs associated to the development of an electronic system had made advances very slow.
But all that is changing, thanks to the advances provided by iFIMS and the stewardship of some island countries that actually own the fish that the markets need.
What the space!