I have been dealing with National Plans of Action to Prevent, Deter and Eliminate Illegal, Unreported and Unregulated Fishing (NPOA-IUU) for a while now…
let me see that plan
I started in 2003 and 2004 when I participated while I was still working with industry in the consultations for New Zealand’s NPOA-IUU, one of the first ones prepared worldwide. During 2009/10, when serving as a Fishery Officer at FAO in Rome, among other tasks, he was involved in the evaluation of the operational impacts of the deposited IUU-NPOAs. During 2012-14 as part of his work for FFA’s Devfish II, I got involved in the development of various NPOA-IUU in the region as I worked across all aspects of fisheries MCS and regulatory compliance delivery, strengthening the operational aspects in EU yellow-carded countries, including capacity building in intelligence analysis, and the development of SOPs to assist with boardings, inspections and investigations.
And even after all this, I still wonder what their real role in the operational side is…
Let go through their “reason of being”…
National Plans of Action to Prevent, Deter and Eliminate Illegal, Unreported and Unregulated Fishing (NPOA-IUU) are developed following the International Plan of Action to prevent, deter and eliminate IUU fishing (IPOA-IUU) adopted in 2001 by the Committee on Fisheries of the Food and Agriculture Organisation of the United Nations (FAO).
The IPOA-IUU is a voluntary instrument and is one of four IPOAs (Seabirds, Sharks, Fishing Capacity and IUU) that fit within the framework of the FAO Code of Conduct for Responsible Fisheries, also adopted by COFI in 1995, and it describes the broadly accepted principles and measures to prevent and counter IUU fishing at the level of states, regional economic integration organisations and regional fisheries management organisations (RFMOs).
In light of the already existing measures to combat IUU fishing (i.e. policy, laws, institutional setup, working processes and law enforcement framework), and on the basis of principles and measures articulated in the IPOA-IUU, the objective of all NPOA-IUU is to formulate pertinent and achievable, additional measures, necessary to close gaps in the existing framework addressing IUU fishing, and to reduce in a planned and concerted manner the incidence of marine IUU fishing in a county to a minimum.
Which is all good… yet in all these years I’ve seen them gathering dust and not really being used by the frontline people… so they always fill to me as one of those things that you need to have because is expected that if you have one you a mature fishing nation… but the reality is that most of the ones I’ve seen are way too “wordy” and overcommit.
My experience is that no one really reads a report that is more than 30 pages or has the capacity to implement more than 15 recommendations in the short term.
And from my industry days, I’m very aware that: “there is only one thing worst than not having a piece of paper and is having one that you don't comply with”… so if you go overboard because is what is expected to be done… you are putting yourself to fail
NPOA-IUU have a long history in the Pacific, yet their presence has not always been noticeable. In 2005 the late Colin Brown (a good man gone to early) authored the FAO document “Model plan for a Pacific Island country - National Plan of Action to Prevent, Deter and Eliminate Illegal, Unreported and Unregulated Fishing”.
This “Model Plan” for the elaboration of an NPOA-IUU was designed to assist Pacific Island States to give effect to the IPOA-IUU. The model incorporated the essential aspects and features of the IPOA-IUU, demonstrating how an NPOA-IUU might be drafted.
In seeking to address IUU fishing the model provides an introduction (with an important focus on the fisheries situation in the model country) followed by measures that might be adopted under the headings of all State responsibilities at the time (Flag, Coastal and State) as well as internationally agreed market-related measures, research, regional fisheries management organizations and the special requirements of developing countries. Many FFA members date their NPOA-IUU back to that document.
Then in between 2012 to 2014 and as a consequence of the EU Yellow Cards, FFA’s DevFISH II programme supported the update and redevelopment of many of these early NPOA-IUU, as to be able to facilitate FFA members to respond when questioned by the EU.
Yet, while the earlier versions lacked depth in coverage of key MCS issues and capacities we have today, the newer versions are voluminous (i.e. 60 pages 38 action points for example), user-unfriendly and very complex, which turned off the target user groups from using it regularly. As a consequence, the documents stayed unused by officers in the compliance section, whom in principle should be using it as a working reference document.
These problems were exemplified in the words of a good friend and fisheries officer, saying that their NPOA-IUU seems to have been designed “more to be read by other countries, than to be used by us”.
So as part of my work with MIMRA in RMI, I have re-structured their “old” NPOA-IUU, as to produce a more user-friendly document adapted to the needs and capacities of the operational users while incorporating the most updated information on the prevalence and extent of IUU in the region and our high level of collaboration with FFA, plus our cooperation with SPC, PNA, WCPFC market states and industry organisations.
So our new one has 30 pages and 15 action points while maintaining full compliance with the internationally accepted minimal components and format of FAO’s IPOA-IUU.
I personally live up to maxim that “the perfect should not get on the way of the good” and is better to start with 15 that you know you can achieve and not 38 that you can’t… once we get this 15 done, let’s bring the next 15.
That more modest approach helped us with PSM… so let me tell you in a couple of years how with did with this one!!!