As an ex fisherman, I’m always ready to remind the people that seem to think that we are all dodgy criminals and even assassins, that as in any group of people in front of a set of rules your will have really hardcore dodgy, moderately or occasionally dodgy and totally straight and honest fishers.
so much investment in echo-sounder FADs and not using it while not one is looking… really?
Real dodgy and totally honest generally make up a small portion of a given population. The real assholes do undertake IUU activities no matter what, while the honest will not engage in IUU fishing under any condition. Hence any compliance-related scheme will have limited effectiveness in the dodgy group, but an affirmative impact in the honest ones.
But then, the moderately or occasionally dodgy (the biggest group), on the other hand, will only bypass regulations if the potential economic gain is high enough to cover the potential penalty they may face given the size of the penalty when caught, but more importantly, the probability of being caught.
Why am I saying this? Because today 1 July FAD closure at the WCPFC starts. I have written a lot on FADs and the fact that during FAD closure, the presence of observers is the key dissuasive stop for many people to take shortcuts… but without observers, the temptations are almost ridiculously high.
In my opinion, the tuna fishery survives because FADs…I’m no economist but I hang out in wharves and boats a lot! During FAD fishing a trip up to full boats would be around two weeks on a variable average (I’ve seen 7 days to 18-20) now during FAD closure we talking 20 to 40 days… with MASSIVE differences in fuel consumption (even if fuel is cheap now) and sometimes you see boast outside for 40 days and come 50% full.
And is not like they pick up all the eFADS during the closure, they still there operating and the vessels, vessels owners and traders still get the info, and with no one on board to give an independent oversight, the temptation is too big for the moderately dodgy and even for the hardcore honest. What is the point of maintaining a stand if you losing money?… but with those disincentives… being honest means also being stupid!
Under normal circumstances, FAD fishing during FAD closure does happen, even if observers act as a deterrence. The most common cause of observer denouncing they have been offered money is around FAD closures... And is important to note that observers which are also human, range like anyone else on theirs morals and approach to corruption, so is not hard to infer that if some denounce corruption attempts, some will take it and keep quiet. In any case, all that is out of the window at the moment, since there are no observers on board.
In Majuro during FAD closure, and as part of our Ports State Measures - Arriving Vessels Intelligence analysis (AVIR) we use manoeuvring analysis (speed pre-fishing set, time of the day, course changes, track shape and prior activity) and if we have doubts, when the vessel is in port and based on the loading log that most of the engineer keeps, we instruct the monitor to check the presence of species that aggregate and cannot be found in a free school set. e.i. the aptly named Triggerfish.
Others like Yellowtail, Wahoo, etc can be normally separated on deck, but the triggerfish is too small and gets frozen with the rest, so if we see it during the loading of the nets in the holds or on deck... alarms bell ring... Of course, we don't have monitors during transhipment either at the moment!
A couple of months ago pre-visioning this mess, we discussed with my RMI friends that a very good intelligence tool, that could help us lot (in RMI, but also in the rest of the members) would be an analysis on data available for the last 5 years (as an arbitrary number) during FAD closure of some parameters that can help boarding officers/MCS guys to see if the data provided prior arrival of the vessel for that period falls inside the normal distribution.
The initial parameters would be:
sets per day,
days at sea in between unloadings,
speed prior to the set (you normally chasing the school fast as it moves)
distance travelled at night (during FAD closure you drift at night -with some exemptions- yet on FAD fishing you go to the next)
sets before dawn, sets after sunset - (FAD free set only happen during the day, because you have to see the fish - the full moon can help.... but is very unusual)
and some more I keep quiet (so I can still have a job!)
To get these data, it would have required us to dive deep into SPC’s TUFMAN 2 database, that maintains vessel but also observer data. Yet nor we or SPC had the time and people available to help in compiling, analysing and presented the data in a risk evaluation friendly format… which was a pity and a lost opportunity.
Furthermore, very few vessels are coming to Majuro since it has some the most strict vessels arrival conditions in the region.
Most of the vessels are transhipping now in ports where very little PSM best practices are followed, no one does manoeuvring analysis or even intelligence analysis… and there are no observers.
With the present COVID reality…. I sadly believe that the 3 months WCPFC FAD closure would be a total failure this year.
I’m not a friend of the Ecolabels at the best of times, but the fact that they maintain a certification that is FAD free dependent, during these times is beyond disappointing and for me just adds to the long list of grievances I have against them.
And this is not just now… since there are no observers and monitors… the whole certification is just based on self-reporting. In Majuro, we have not monitored a single transhipment or offloading since March, yet they still are getting emails of vessels transhipping/unloading MSC fish in the lagoon.
Begs the question who is verifying these transhipments as a third party, or even when the vessel is making free school sets at sea for that matter. Seems that the “integrity” of some of the MSC unit of certification was the “official” monitor’s verification of the chain of custody, but now, who knows whats going on.
So yea… not cool… and not much we can do to from the regulatory perspective…
*Love in the Time of Cholera is a 1985 novel by Colombian author Gabriel García Márquez that earn him a Nobel price.
so much investment in echo-sounder FADs (around 3000USD each) and not using it while not one is looking… really?