The case of the Star Shrimper XXV

Private sustainability endorsement may not always mean a lot (or even less legality). I think I been quite clear in the past on my views on eco-labels. I still believe that is better to support the responsible authorities in the Flag, Port and Coastal States than a private certification, which at the end of the day responds to a business model. 

The man with the gun seems to be the real "friend of the sea"...  (Image by Sea Shepherd

Here is a Nigerian flagged shrimp vessel with Dutch beneficial ownership, arrested in Liberia for fishing without a license, not using turtle exclusion devices, and other charges. Yet is certified as "Sustainable Seafood" by "Friends of the Sea" an eco-label based in Italy, that claims in most tuna meetings I have been, they are the best... and invariably finish in a cat fight with MSC and others.

Furthermore, the vessels are authorised to export to the EU, so is to be assumed that catch certificates must be signed by the Nigerian Fisheries authority and the vessel is in compliance with EU seafood safety requirements, both requested by EU market access requirements.

Recently I voiced my concerns under the assumptions for Principle 3 in many of the tuna vessels under certification from MSC, which at least tackles the fishery as a whole and does not just provide certification to individual companies or vessels. 

But this case is blatantly wrong, and it amazes me that the company still certified as you can see in this page

We always hear when the authority of a least developed country does not have control, yet when there is a clear lack of oversight by this eco-label that charge a lot of money for their logo use, not much info goes around.

Remember this news when they want to sell you their certification.

Image by Sea Shepherd

Global analysis of depletion and recovery of seabed biota after bottom trawling disturbance

A bulk of the criticism to commercial fisheries comes from the assumption that all fishing activities are based on trawling. The arguments are that all trawling caused an irreparable impact on the benthic communities, that trawlers are the "bulldozers or the sea", and so on. Of course, as with most things in life (including fisheries), nothing is totally dichotomic... while there is impact (as with any human activity) the extent depends on the specific benthos, the type of gear, the target species and so on.

Impacting the benthos on a trawler in late 80s/early 90s

While there is semi-pelagic trawling (meaning does not touch the bottom), this gear is not used for tuna, (not if you were to believe this terrible post!) Yet having started my fisheries life in trawlers in the south Atlantic, I was quite interested in reading this paper, as it will become the reference for any further studies or claims of the real impacts of trawling.  

Is a thorough job, done by a quite amazing number of very well know scientists from 10 different universities and organisations (including FAO). 

I quote the abstract here, but as always advised, go to the original! 

Abstract
Bottom trawling is the most widespread human activity affecting seabed habitats. Here, we collate all available data for experimental and comparative studies of trawling impacts on whole communities of seabed macroinvertebrates on sedimentary habitats and develop widely applicable methods to estimate depletion and recovery rates of biota after trawling. Depletion of biota and trawl penetration into the seabed are highly correlated. Otter trawls caused the least depletion, removing 6% of biota per pass and penetrating the seabed on average down to 2.4 cm, whereas hydraulic dredges caused the most depletion, removing 41% of biota and penetrating the seabed on average 16.1 cm. Median recovery times post-trawling (from 50 to 95% of unimpacted biomass) ranged between 1.9 and 6.4 y. By accounting for the effects of penetration depth, environmental variation, and uncertainty, the models explained much of the variability of depletion and recovery estimates from single studies. Coupled with large-scale, high-resolution maps of trawling frequency and habitat, our estimates of depletion and recovery rates enable the assessment of trawling impacts on unprecedented spatial scales.

e-Pacific: the array of Apps for fisheries data acquisition we use in the WCPO

For a part of the world that has had a lot of difficulties regarding connectivity due to its remoteness, low critical mass concerning population, expensive services and not a lot of money in the population. The Pacific has been a remarkable early adopter of mobile technologies and the development of Apps exclusively dedicated to fisheries data collection for science, management and increasingly, compliance purposes.

Happy to work with all of them, the guys catching fish and the ones catching data

In the Apps developments and fisheries related data fields management there are 3 players in the Pacific: FIMS, SPC and FFA. As an independent contractor to all of them, I see my self as a very lucky man working (and more important having friends) with each group. In fact, the one above is a screenshot of my tablet with all the Apps presently being used in the region.

The 1st guys off the block were the iFIMS crew. When I meet Mark (a boss there) for first time many 6-7 years ago at a meeting where I was presenting on the need of data (“catch once use always” was the title) and he was introducing FIMS. The connection was immediately we both were thinking in very similar ways, yet coming from very different backgrounds. 

The FIMS project started as a PNG commissioned fisheries data management than the later was taken by PNA. The FIMS “constellation” is a product of Quick Access Computing and remains a privately own product and services provider. 

I liked that Mark and its crew were not “fisheries people” hence their thinking was fresh and original, I been collaborating with them since that first meeting and we have most of the tools needed for a full CDS system. Besides that Mark became a friend (a rare commodity in the consulting world), we stayed at each other houses, and we know each other families… which in my worldview means way more than having just business together only.

And while FIMS is an integrated database / universe that does a lot things, from assets management to the administration of the VDS, here I just gonna focus on the present Apps that integrate with their online platform and web interface.

At present they have 2 “products” that are used very extensively:

eForms, is an electronic logsheet application for PS and LL vessels, which is used by fishers, and data sent to the server either by the vessels internet or via an Iridium enabled two-way communication device. The App provides industry with a platform to manage and eLodge data near real time, hence Catch Reporting and other functions available for any country, its operation in all Purse Seine Vessels currently registered in PNA water and quite a few longliners in some of the countries

eObs, that is an Electronic observer data application for PS vessels and is used by observers, the data is uploaded to national and regional databases at SPC via an Iridium enabled two-way communication device (which provides additional observer safety measures). 

The Iridium based communication these Apps use, is enabled via the use two-way, satellite communicator devices are about the size and weight of a smartphone, which have bandwidth limited yet effective data transmission, and using that guaranteed independence and reliability 

The data sent has GPS marking included beyond the fact that overlaps with the VMS, so we know where the data was loaded and sent, and the systems have all sort of alarms and notifications included (EEZ and port entry/exit for example).

These two tools provide the regulators at port with the opportunity to assess a lot of info (volumes per species, effort per day, zones fished, observer notes, etc.) before the vessels arriving in port, allowing then the Port state to decide the level of inspection needed. Furthermore, both Apps become the basis of not only PSM but also the CDS.

There are other Apps on the pipeline such as Factory eForms, landing/transhipment monitoring forms as well as online modules (eCDS and port) just to name a few (but can say too much yet)

Their database connects to TUFMAN2 the SPC regional database (see below for more info) assuring data interoperability and future potential interaction with whatever the EU comes up with for the promised upgrade of their the catch certification scheme. As well the International Trade Data System (ITDS), the U.S. government’s single-window data portal for all import and export reporting.

Obviously being the 1rst of the block they set the pace, but most importantly, being private company instead of an institution allows them to be product and results focused, without haven to depend on bureaucracy and budgeting authorization to get the results. On the other hand being a private company has issues concerning the ownership and controls of the information. (Another example of my favourite fisheries mantra “everything has advantages and disadvantages.”)

In any case, what they have done so far is beyond admirable, and I have not seen anything even remotely similar anywhere else in the world.

The other crew that has been long in the database game yet a bit newer in the App game is the data management section in the Oceanic Fisheries Programme of SPC (Secretariat of the Pacific Community) based out of Noumea in New Caledonia.

Their main focus for many years now has been data acquisition and management from a science perspective (they had a small compliance sector too) and the evolution from their TUFMAN (Tuna Fisheries Database Management System) to TUFMAN2 to the expansion to TUFMAN “family” has been fantastic, gaining strengths and flexibility over the time.

It deals with Logsheet, Unloadings, Port sampling, Artisanal fisheries and other bits and pieces, is a data, receiving and checking tool. Is a Web-based hosted at SPC. Private, secure and powerful (you still own your data), Connected to OFP with centralised credentials platform. Low bandwidth requirement (if you can send an email, you can use TUFMAN2). And as they have been spearheading issues around video on board (aka e-monitoring)  then e-reporting capabilities was a logic consequence. 

And they have come up with two very cool Apps:
OnBoard, which is an Electronic logsheet application for collecting Catch and Effort Data and is to be used by fishers on longliners . It has a dynamic user interface and data validation capabilities (range checks and the lot). It does upload directly to TUFMAN2 and to DORADO, which is a data reporting module.

Tails, which is a Fisheries monitoring application for collecting: Commercial LongLining Port Sampling Data and Artisanal Fisheries Data and is used to be used by national fisheries staff (officers, unloading monitors, port samplers, etc)

And as On Board It does upload directly to TUFMAN2 and to DORADO for reporting.

Both are operational, and they have an observer App on the pipeline as well.

Their data streams while oriented for fisheries science cover most of what you need for anything in fisheries, and with a bit of tweaking via an external module that integrates with TUFMAN2 (and becomes part of the TUFMAN family) it could easily run a CDS. 

Over the years I have dealt with various aspects of their work and had very good rapport with many in the data team, such as Malo, Bruno and Andrew, while they are much younger than me, thankfully the relationship goes beyond work, as they are really cool and clever people.

FFA (Pacific Islands Fisheries Forum Agency) is the most recent App provider, has been as well in the database and information management game for a while since the regional tools such as the VMS, the vessels compliance index, the vessels in good standing list just to name few, rely on data management capabilities. 

Their RIMF (Regional Information Management Facility) App integrates with the countries IMS portal, and offers the Boarding Officer’s Job Aid Kit (BOJAK), with access to Vessel Monitoring, Reference List, License List, Transshipment Monitoring Checklist and Departure Clearance.

The App provides a visual indication of many of the parameters colour coded icons (as you can see below) which facilitate the user interaction.

The users of the App are the fisheries officers in the FFA member countries that choose to use it and are testing them as we speak

Luckily again, I go beyond just work with  Ano and Kenneth the key data guys at FFA.

All these Apps from my perspective is fantastic, since data is the basis of a CDS.

The issue with CDS is that brings in one compliance (PSM, VMS, VCI, etc) and volumes (per species and areas of capture), but the 1st is the realm of FFA and the 2nd of SPC, even if there is complementarity in many of data fields that are collected by both.

In many cases, the compliance elements and in particular issues around “fish laundering” are just the need of “time” and “key traceable elements” markers in the data streams entering TUFMAN2 and added to that is an extension of the “mass balance capabilities” already existing there 

SPC and FFA work collaboratively in many areas and they will keep doing so, yet SPC has much bigger data team and more acquainted to the volumes calculations that FFA.

In my ideal world, there should be an FFA compliance module working integrated to the SPC TUFMAN2 “Family” that nourishes itself of the necessary fields out of TUFMAN and integrates the necessary elements outs of the present FFA capabilities (while protecting some of the sensitive bits) 

Of course, such an action needs to be supported by all members and be part of the mandate of both organisations.

Surely the question at this stage is why we are in some way duplicating efforts… as said there are issues around the ownership of data, as well as that the capabilities and interest of the mostly Purseiners countries are different to the mostly longliners ones.

For me, is up to each country to pick and choose what works for them, all the systems at this stage “talk” to each other and can do so further, the result is what matter most, not the method 

There is only an limited amount of data fields that can be extracted from fisheries operations that are aimed at all possible uses in fisheries management, science and compliance. How we deal with the ownership and extraction of that data can always be arranged. The results are vital for having as a sustainable and legal fishery.

All this is admittedly ambitious, but the reality is that getting to this point was already a long road, so what is left, in comparison is so much less… The aim would be to have almost real time access to what and how the fishery is doing and what anyone in the fishery is doing at any moment in time. The whole set of data capabilities we have in the region is a full credit to the developers and to some very forwards thinking leadership in the countries and the institutions, and my full respect to all of them for that. I wish fish were like data… capture it once and use it for ever.

Criminalising IUU Fishing

I have posted before about the work of my colleague Mercedes Rosello. She is working on the international law side of IUU fishing. This is a vital area since in many cases IUU fishing, particularly in the high seas, falls in between the cracks of flag, coastal, and port states.

Her recent contribution to the British International Studies Association’s annual conference makes good reading for those with an interest in this topic.

I paste below the content from her blog about the topic.

Abstract:
Illegal, unreported and unregulated (IUU) fishing has been associated with human security concerns. Domestically, security concerns may be addressed through the prescription and enforcement of criminal law provisions. However, prescribing and enforcing criminal law in regard to activities occurring in distant water areas, where IUU risks endure, is less straightforward. This conference presentation argued that the interests of flag and coastal States in the criminalisation of IUU fishing and related activities as a response to security concerns differ, and outlined possible avenues for legal development.

Introduction:
According to the relevant literature, IUU fishing and activities commonly associated with it have been linked to human security concerns. IUU fishing has been argued to have food and work security implications for vulnerable populations, and to enhance the vulnerability to crime of persons involved in the industry. The human security narratives encapsulated in the UN 2030 agenda for sustainable development largely capture these human security concerns. By contrast, more traditional security conceptualisations, underpinned by territorial perspectives, may be less responsive to the type of risks posed by  IUU fishing.

In this presentation, she argued that the UN Convention on the Law of the Sea, conceived on a territorial jurisdictional blueprint, disincentivises but does not ultimately preclude criminalisation as a State response to undesirable fishing activities. However, analysis of international law and policy materials suggests that divergent interests in criminalisation as a tool to address human security are identifiable in regard to flag and coastal States. Two case studies were relied on for analysis. The first one concerns Spain, a distant water fishing State where one of the country’s highest courts withheld jurisdiction in respect of alleged acts of criminality by Spanish nationals in the context of high seas IUU fishing. The second one concerns Fiji, an archipelagic State where intensive tuna fishing by unidentified foreign industrial fishing vessels around the outer borders of the State’s exclusive economic zone was reported in 2014 to have caused problems that could be characterised as possessing a human security dimension.

The presentation concluded with a reflection on the necessity for international consensus, particularly amongst coastal States involved in regional fisheries arrangements and institutions, in order to develop domestic as well as international frameworks that secure appropriate responses to the risks posed by IUU fishing.

What to Make of Recent Data Showing 10% of Fish are Discarded at Sea?

I have quoted work from the CFOOD crew before. While some in the fisheries world may not like their messages, one has to admit that they always have a point, and are good at driving it. As in the case of their post from the title.

Always be careful whom you point fingers .

Not going to copy and paste their words, read them here, but just bring a bit of perspective and the brilliant graph they rescued. Obviously, we are still terrible at handling all foods, so some work there will have equal or more impact than the one needed for diminishing discards. 

A paper published last week titled, Global marine fisheries discards: A synthesis of reconstructed data, concludes that commercial fishermen have thrown away (discarded) about 10% of catch over the past decade. Researchers, led by Dirk Zeller, used catch reconstructions – estimates of how many fish were caught – to approximate that around 10 million tons of fish are discarded at sea per year. This number is down from a high of 18 million tons in the 1990s. For context, here is a figure put together by Dana Gunders at the National Resources Defense Council in the 2012 report, Wasted: How America Is Losing Up to 40 Percent of Its Food from Farm to Fork to Landfill. Fishing discards are considered “Production Losses.”

Zeller et al. 2017suggest that the decline in discards are a result of declining fish stocks, though they acknowledge that gear and management improvements could also play a role. Indeed, worldwide fish stocks have remained relatively stable since 1990s, indicating that perhaps management and gear technology have played a larger role in reducing discards than researchers propose.

Model Catch Certificate for the US Seafood Import Monitoring Program

I have been keeping updates on the conditions that US Seafood Import Monitoring Program establishes for imports of certain seafood products for a while now. The aim of the programme is to tackle the reporting and recordkeeping requirements needed to prevent illegal, unreported and unregulated (IUU)-caught and/or misrepresented seafood from entering U.S. commerce.

NOAA Fisheries published the final rule establishing the Seafood Import Monitoring Program (SIMP) on December 9, 2016.   This is the first-phase of a risk-based traceability program—requiring the importer of record to provide and report key data—from the point of harvest to the point of entry into U.S. commerce—on an initial list of imported fish and fish products identified as particularly vulnerable to IUU fishing and/or seafood fraud.  

Now that legal challenge that some US based operators had is dismissed, January 1 2018 still is the mandatory compliance date for this rule. 

The US importer is the central actor responsible for data collection, management, input and storage under SIMP and has ultimate responsibility for compliance. The importer of record – who must be a US citizen – is required to apply for and maintain an International Fisheries Trade Permit (IFTP), which can be purchased and issued immediately for US$30.[1]

The importer will be required to keep records regarding the chain of custody of the fish or fish product from harvest to point of entry into the US and to have these data available in the event of an audit, even if the importer of record works with a customs broker in order to submit required data into the ITDS. 

NOAA has just published some model forms (something I didn't expect them to do!) on top of the Q&A guidance document I quoted before. The model forms are: 

The Catch Certificate, (also in Spanish, Portuguese, French, Mandarin Chinese, Tagalog, Indonesian, Vietnamese) and the Aggregated Catch Certificate, (also in Spanish, Portuguese, French, Mandarin Chinese, Tagalog, Indonesian, Vietnamese)

The usual advice applies, the earlier your sort yourself out for this the better, yet be ready for a lot of problems to appear, if something we learned from the EU one is that there will be 10000 scenarios that are not covered and we (in the exporting countries) will have to improvise...  

[1] IFTP information and application is available at: https://fisheriespermits.noaa.gov/npspub/pub_cmn_login/index_live.jsp

FFA has published a briefing and analysis of the regulation, very nicely written by Elizabeth Havice. It can be downloaded from here 

Alcohol claims another life, this time a fisheries observer.

I have written before about how difficult is the closure for the family when an observer (or a crew member) is lost at sea and the dangerous nature of fishing jobs. This week, unfortunately, we mourn the death of another fisheries observer.

The observer (a PNG citizen) was reported missing around 2 am on Wednesday last week, from the Feng Xiang 818, a Chinese-flagged Purseiner, while in the Nauruan EEZ. The vessel then followed all the proper procedures and went to Nauru where it was boarded by the police. 

It was reported initially here, without many details, which made many people (including me) jump into suspicions of foul play, based on the prior suspicious disappearances of other observers.

I wondered if the vessels had cameras on board, and renewed my calls for this technology to be compulsory. 

The Feng Xiang 818 had cameras on board and the event was all recorded. Unfortunately, alcohol was involved.  I have heard this from one of the most trusted sources I know.

Being drunk is dangerous, and much so when on board a fishing vessel.

And perhaps this opens (or confirms) a completely different discussion, which is the hypocrisy in regards alcohol in our society in general and in our industry in particular.

Somehow the drug that causes most deaths, family and personal damage in the world, in not only legal but socially glorified. 

I always have supported "dry" (no alcohol)  boats, "be as stupid as you like when you are on land, but at sea, no way" I was told... and it always made sense to me.  

Having been beaten up as a child by drunk adults has made me very wary of alcohol... but what is even worst... has made many of my colleagues distrustful of me, when I say: "No thanks, I don't  drink". Almost like saying to me "what is wrong with you? It always seem to me that we have more respect for an ex-alcoholic than for a non-drinker.

In any case, we all know about alcohol, and this post wasn't about it, even if it has claimed another victim.

As a former deck officer, I don't feel sorry for the officer in charge of the Feng Xiang 81. No one wants to lose a crew member overboard, yet what happens on your boat is your responsibility. If one of your crew is drunk, then 1) you need to take care of him and 2) you need to find out how come he is drunk after so many days at sea, someone has provided with the alcohol. The onboard code of conduct is a HUGE component of their training and during placement the observer coordinator insist heavily to the captain and radio operator on not providing alcohol to the observer, so someone has pushed the envelope there, and that is the fault of the vessel master. End of story.

But most of all, I feel sorry for the observer's family, since it was an avoidable death. 

Fisheries management impacts on target species status

Never shy of putting their views across, Ray Hillborn and a group of his colleges published recently a paper “Fisheries management impacts on target species status” on the PNAS Journal, that as usual has polarised some of the also well-known scientists at other ends of the fisheries discussion. Yet for me, the key finding (in bold italics below) is what we informally knew were the keys, but now is been scientifically proven are the keys, and I like that.

Summarized survey answers by dimension and country.

I will (as usual) quote some of the elements in the paper I find significant, yet I encourage you to read the original and see what the others are saying (the easiest place to do that is at his tweeter handle)

Interestingly the paper has a section I have not seen in many others:

Significance
There is broad public interest in the health of our oceans and marine life at local, national, and international levels. In recent years there has been increasing concern about whether our fisheries can sustainably provide seafood without overfishing fish stocks.

Several papers have described the global status of fish populations (i.e., their abundance and exploitation rates) and have hypothesized influences of fisheries management, but this report is unique in being a comprehensive analysis of how specific management attributes (which are numerous and operate simultaneously) affect population status across oceans, countries, and taxonomic groups.

Our report integrates management policies and population ecology to assess sustainable harvesting outcomes of target species in marine fisheries; results have important global food security implications.

Abstract
Fisheries management systems around the world are highly diverse in their design, operation, and effectiveness at meeting objectives. A variety of management institutions, strategies, and tactics are used across disparate regions, fishing fleets, and taxonomic groups.

At a global level, it is unclear which particular management attributes have greatest influence on the status of fished populations, and also unclear which external factors affect the overall success of fisheries management systems. We used expert surveys to characterise the management systems by species of 28 major fishing nations and examined influences of economic, geographic, and fishery-related factors.

A Fisheries Management Index, which integrated research, management, enforcement, and socioeconomic attributes, showed wide variation among countries and was strongly affected by per capita gross domestic product (positively) and capacity-enhancing subsidies (negatively).

Among 13 management attributes considered, three were particularly influential in whether stock size and fishing mortality are currently in or trending toward desirable states: extensiveness of stock assessments, strength of fishing pressure limits, and comprehensiveness of enforcement programs. (surprise surprise!)

These results support arguments that the key to successful fisheries management is the implementation and enforcement of science-based catch or effort limits, and that monetary investment into fisheries can help achieve management objectives if used to limit fishing pressure rather than enhance fishing capacity.

Countries with currently less-effective management systems have the greatest potential for improving long-term stock status outcomes and should be the focus of efforts to improve fisheries management globally.

A simple truth

"Everything has its advantages and disadvantages"

Was my dad's advice when I told him that I was getting married...

And that is perhaps the biggest truth in fisheries...  and a quote I use constantly in my work!  

Kiribati gains authorisation to access the EU market. What does it means and how it works?

Since the 16 of June 2017 via Commission Implementing Decision (EU) 2017/1089, Kiribati became the 4th country in the Pacific to be included in the list of third countries and territories from which imports of certain fishery products for human consumption are permitted. Yet, this does not mean that from now on fish caught by any Kiribati-flagged vessels can “instantly” access directly or indirectly the EU. It does not work just like that!

are you EU elegible?

My post today is on how that process works and a bit of the inside story on how Kiribati got to be authorised from the sanitary side, yet the country still with a yellow card from the IUU side.

The EU’s Regulation (EC) 854/2004 provides that products of animal origin can only be imported into the EU from a third country (meaning non-EU countries) that appears on a list drawn up in accordance with this Regulation.  When drawing up such lists, an account is taken of EC controls in 3rd countries and guarantees provided by the Competent Authority (CA) of 3rd countries in regard to compliance or equivalence with the relevant EU (health) regulations.

If a country’s control systems are considered “equivalent”, then it is authorised for fishery products and added Annex II of Commission Decision 2006/766/EC. Then the CA of that country evaluates compliance against the EU regulations by their factories and vessels (they call then Food Business Operators - FBOs). If they are up to the standards and expected levels of compliances, it then lists them (by giving them an approval number) and sends them to the EU, to be added to the list approved establishments of that country.

At this stage, the 1st list of 5 vessels and one factory has been sent to the EU for the revision, and once this is done and the FBO would appear in the list, and from then on they can access the EU market.

This all process is quite complex, and it takes countries like Kiribati a long time and effort to get to this point.

The EU obliges compliance to its own requirements, and thus requires the 3rd country to prove that it operates a control structure applicable to its seafood exports that are equivalent to those existing in an EU member country, meaning than Kiribati has to prove that has systems and controls equivalent to those of Germany for example.

Yet many Small Island Developing States in the Pacific (SIDS) like Kiribati, remain in the category of Least Developed Countries (LDC) recognised by the UN. The 3 elements that define this status (poverty, human resource weakness and economic vulnerability) are at the same time key elements in the establishment and operation of a CA. 

Until now, only three of Pacific Islands country members have been able to meet this requirement – PNG, Solomons and Fiji – all relatively large countries with substantial tuna processing industries. Even these countries face considerable challenges, both Fiji and PNG have been forced to suspend exports to the EU for a time in the last few years, and all of them continues to rely to a different extent on donor funding to maintain its CA.

For SIDS in the Pacific, the lack of EU sanitary authorization is a price disincentive for buyers of their fish caught in their waters, but not for same fish caught by vessels from EU authorised countries (like Taiwan, China or Korea) catching next to them, even if the inspectors of those flag states, may have never been on board!  

In principle, the processing countries can only provide “EU Health Certificates” for seafood products which are derived wholly or partly from raw materials products that:

• Have originated from a third country eligible to export the animal product to the EU;
• Have been derived from foreign premises eligible to export to the EU, (including vessels); and
• Be eligible to be exported to the European Community;

This “eligibility” requirement, should be always applied, yet this is unfortunately no the case in all canning countries, in Thailand for example, this issue already got them into troubles with the EU. 

A further challenge for Pacific countries is that in many cases, they do not have processing sites in their territory (nor the physical area and cost effective geographical situation to develop them), or if they do, the operational focus targets more regional markets and not the EU. For these countries, the CA needs to be developed and operated in a “vessel only” oriented manner. This would potentially imply a CA with officers either travelling to the foreign landing ports and/or establishing MoUs with the CAs of the unloading countries.

And to make things more complicated we have to add the fact is that in many SIDS, there are a growing number of foreign-owned but locally flagged vessels (as to get cheaper access) that operate in their own economic zones and regional waters. And while these vessels unload locally or in other 3rd countries for processing or shipment to processing facilities with the potential to export to EU markets, there is normally no one on board that has real link to the flagging state, or even speak and read the countries language or English, hence they are not particularly keen to have HACCP plans on board, records, train crew, and have inspectors coming to check their records.

Until now, much of the SIDS effort to gain or sustain EU Market access has been supported in one way or another by FFA and SPC, particularly in the areas of training, legislation updates, reciprocal inspections, institutional strengthening, laboratories and control systems development (in many cases funded with EU support).

These inputs have been instrumental in getting Kiribati to this stage. The process was initiated s back in 2012 under the EU funded/FFA managed DevFish II Programme. For that, w adapted the National Control Plan (NCP) that Francisco “invented” for Ecuador in 2007 and then we used to help Fiji back into the EU.

We went through a process of "reverse engineering" of all the relevant EU regulations and put the requirements in a document in the way the inspectors would like to see them and the country could comply with them.

The NCP set up the rules in which the country “EU system” is to based, as to provide the “official assurances” the EU requires and become the basis on which to judge equivalence, and that way gain/maintain market access. All methods, procedures and regulatory instruments to be used for conformity assessment, regulatory verification and official guarantees, are presented in the NCP, which in turn is presented to the EU as per their requirements.

The idea is that exporting to the EU is a voluntary act on the part of a few processors; so the recognised CA can impose the NCP only for these factories and vessels. In this way, the CA can provide “official assurances” only for those establishments and supply vessels that want to be engaged in trade with Europe.

The operators on their side recognise that maintaining approval and certification privileges, as part of the listing of companies allowed to provide raw material or to export directly to the EU, is dependent on regulatory compliance.  If an establishment is not in compliance with the requirements, then their market privileges are suspended or removed as necessary. 

We believed that this approach has the advantage of being cost effectively implemented while upholding the level of compliance required for meaningful official assurances. And it worked! Ecuador maintained its market access till today, so did Fiji and Solomons, and now Kiribati got the OK, only based on the written documentation :-)

Since 2014 FFA has taken the lead by employing Jope Tamai and contracting Cushla Hogart a very experienced consultant from NZ and both enhanced the NCP approach and with the local support of Terere, Tebeio from the Kiribati Seafood Verification Authority (KSVA) and now Saurara a former CA officer from Fiji that is based supporting this process under funding from NZ MFAT have done the massive groundwork that took them up to the present.

The reality is that getting to this point was already a long road. Yet, as in many other areas, it takes an equal amount to effort maintain your self at the top spot, than what it took you to get there, so the real work load just started for Kiribati.

Finally be aware that all this has no relationship to Kiribati still on "yellow card" for IUU related matters... that is a whole different EU topic.

Request for participation in FAO survey on marking & tracking dFADs

When I was a fisherman (and even today) I complained complain that rules and management policies were not designed to be user-friendly and in some cases impossible to follow. A classic line is: "Obviously the people behind this, have no idea of what does really happens on board". So if this rings a bell, here is your chance to help make better management tools by completing a short survey, so you don't have to complain later!

FADs in the making

My colleague Dr Eric Gilman, on behalf of my former employer FAO, is conducting yjos survey to obtain comments to improve a section of FAO’s Draft Guidelines on the Marking of Fishing Gear on marking artificial drifting Fish Aggregating Devices (dFADs) used by purse seine tuna fisheries, to identify ownership and track position. The survey also collects views on measures adopted by the tuna RFMOs on FAD marking and tracking.

The survey results will be published as a FAO Fisheries Circular, which will be presented to the participants of the FAO Gear Marking Technical Consultation in Feb. 2018 in order to improve the guidelines on marking and tracking FADs.  

WCPFC, IATTC and IOTC secretariats have distributed circulars to their commissioners requesting their support (e.g., see https://www.wcpfc.int/node/28750). 

More information on the project, including the survey form (available in English, Spanish, French, and traditional and simplified Chinese), is available online at http://tinyurl.com/FAD-mark. 

Eric's work would be as good as the quality of the data he collects, so if you have dealt with drifting FADs at any stage of your career, provide a few minutes of your time for a better-managed fishery. 

Eric is with the Pelagic Ecosystems Research Group of the College of Natural Sciences at Hawaii Pacific University 

The SPC Fisheries Newsletter

For many years now my friend and colleague Aymeric Desurmont (SPC's Fisheries Information Specialist) has been in charge of the SPC Fisheries Newsletter. In this world full of fisheries misinformation, this newsletter is a must read for the region, and I personally think that it should be celebrated and acknowledged way more than it is at the present.

fishing for food and fun in Noro

The newsletter is always interesting reading as it offers varied topics pertaining from the region in a very scientific manner, but also has a "person" approach to some of the topics. We so easily forget that fisheries are as much about people, as it is about fish. 

Thank you SPC and thank you Aymeric for your excellent work over the years. My total respect for that!

The Number 152 (January–April 2017) is here, and the editorial below

Participants of the SPC Heads of Fisheries Meeting, in March (see article here), highlighted the need to raise the profile of coastal fisheries, given their importance for food security in the Pacific Islands region, and concluded that coastal fisheries should find a higher place in the list of priorities of their governments and donor agencies. I’m not sure if it is already a side effect of this call, but the list of articles we received for this issue certainly highlights the importance and diversity of coastal fisheries-related work being done in our region.

The fishery sector includes some of the most dangerous jobs in the world, globally causing over 20,000 deaths per year. But, in the public’s mind, this danger is more associated with industrial fishing in extreme weather conditions than with artisanal fishing in relatively benign tropical waters. Nevertheless, anyone who has ventured outside the reef on a small outboard-powered boat is well aware that disaster is never far away. Engine failure combined with offshore winds can make for a very long and possibly fatal drift.

In Tuvalu, three drifting fishermen were saved by the activation of personal locator beacons, devices they had received from their government as part of a safety “grab bag” (see articles here and here). Each grab bag cost USD 1,200 – a very minor investment when compared to the cost of air search and rescue, or the loss of a life. The Tuvaluan government decided that the safety of artisanal fishers was a high priority. Three fishermen and their families will be forever thankful for this wise decision

PacfishID, a new app to identify common coastal fish in the Pacific

The Pacific Community (SPC) has just released PacFishID, a new mobile application for learning how to recognise Pacific marine fish species. Just like Tails, a catch-data collection application launched by SPC last year, this app uses technology to improve resource management.

The first dataset available on PacFishID is based on SPC’s recently published Identification guide to the common coastal food fishes of the Pacific Islands region. This guide was initially produced to facilitate the work of fisheries officers during market and landing surveys. But the number of copies downloaded since its publication shows that it has reached a far wider audience.

The fun-to-use app works offline once the data and pictures have been downloaded and contains detailed information on marine species classified by family.

Each fact sheet shows a species’ identification keys, maximum size and the Pacific countries or territories where its presence or absence is either scientifically confirmed or probable.

Users can test their fish-name knowledge with the quiz function’s progressive multiple-choice test that gets harder as the number of right answers increases.

The app is available at:

Apple Store https://itunes.apple.com/us/app/pacfishid/id1238553695?mt=8

Google Play https://play.google.com/store/apps/details?id=spc.pacfishid&hl=en

and Windows Store https://www.microsoft.com/en-us/store/p/pacfishid/9nvg3dkqj0th

It is currently available in English only, but a French version is in the making.

The app will be upgraded with more datasets including offshore and aquarium fish, invertebrates, marine mammals, sea turtles and seabirds.

Transhipment, Boarding and Inspection Training Workshop in FSM

For the last two weeks, I have been working here in Federated States of Micronesia invited by my colleagues from FFA and from NORMA (the local fisheries authority) as resource person and trainer in during Transhipment, Boarding and Inspection Training Workshop that took place in Pohnpei.

The 7 columns of acronyms that you see on the back wall are just the start of the complexities of MCS work in a multi-state fishery like the one we have here in the Pacific :-)

Interestingly the workshop took place while everyone was at the UN Ocean Conference in NY starting with a "tuna traceability declaration". But for that to take effect a lot of work still need to be done setting up the basics for it.

Unloadings need to be first assessed as legal, and then need to be accounted, yet that is easier said than done.

Officers are typically trained through the FFA process, including MCS and dockside boarding and inspection training. Yet by their nature, these trainings are aimed at the procedural and enforcement level, with limited involvement in the pre-arrival screening of vessels, logsheet assessment or the evaluation of volumes unloaded, and equally important; volumes exported as to detect fish laundering.

My contribution aims to provide a fisherman's perspective not only on the formal elements of harvest legality and enforcement but to the approaches associated with logsheet evaluation and data verification from other documents such as captain's logbook, engineers logbook, plotters, etc. as well as catch landings and transhipment monitoring.

Furthermore, I always like to give bring attention to the ‘why” are these activities are necessary and not just “how”.

Off to a boarding (and looking the part) :-)

We also had the opportunity to work with FFA's new Boarding Officers Job Aid Kit (BOJAK) App, that set all the paper based boarding forms into electronic forms, and provides on demand technical and compliance data in regards the boarding vessel. Then allows for the
transmission of data via 3 types (Wi-Fi, Cellular or Satellite) connection automatically into the FFA IMS (the set of Fisheries Apps we have in the Pacific is going to be the matter for another blog)

I really do enjoy this type of work, and get a kick of getting to the boats, sharing my insiders' experience and get the feedback of the good people I’m working with.

I wish to thank my FFA colleagues Peter Graham, Dennis Koroi, Kenneth Katafono and Pole Atanraoi-Reim for the opportunities and trust extended during the workshop.And to Suzzane Gallen, Justino Helgen and Preleen Martin for NORMA for organising a superb event.

The great FSM team

"One size does not fit all" - Frank Zappa on MSC P3 for Tuna?

I have been quite open about my issues with eco-labelling, as well to the fact that I respect in principle the work that MSC does. I went through their standards many years ago prior to the 1st certification of the Hoki Fishery in NZ. The 3 principles structure is solid, mainly because it tackles a fishery in its entirety (I have absolutely no time for any of the other approaches)

do we get a price plus just for being legal?

I still uncomfortable with them for reasons I described before here.

Recently I had the opportunity to go over all tuna MSC certified fisheries in the Pacific with a focus on Principle 3 “Effective management” and in particular the last two performance indicators and scoring issues,  “Compliance and enforcement” and “Monitoring and management performance evaluation”.

And honestly, except the Trimarine Solomon Islands one (5 purseiners and 2 pole&liner vessels fishing in national waters only), I don't get how they were able to score a “pass” on some of these issues.

I have no major issues (nor the knowledge) to question much on Principles 1 (Sustainable fish stocks), and 2 (Minimising environmental impacts). Most of the performance indicators and scoring issues are about work done by SPC for the WCPFC. While dependent on the quality of the data provided the methodologies behind are relatively independent of the different flag states involved in the fishery, since the key decisions do take place at WCPFC.

However, there are voices that question that the fishery "should only be certified as a whole, for its total operations, and not on “artificially construed components of the fishery”, referring to the mixed free-school and FAD fisheries in the WCPO, as I reported before here.

Back to the part I understand best, some key compliance performance indicators of principle 3, rely totally on the flag state performance and individual vessels compliance history, yet it is the client that has to provide this information. Which in some cases it would be better to hide yet in others he may not have access.

MSC expects that “Where possible the certifiers will seek independent and credible information, and would typically meet with the relevant compliance and enforcement agencies” but then, what they expect the poor performing flag state authorities to say? Other than: "we are great".

In most of the certifications, the unit of assessment – UoA (the set of vessels involved), are flagged to various flag states including DWFN (mostly associated with traders networks). Many of these DWFN have a poor record of performance. Yet in none of those certifications, they seem to be an independent verification of compliance or time spent reviewing records in the fisheries agencies in those lesser performing flag states.

Furthermore, why would the fisheries authorities of these poor performing countries allow a private consultant to dig into their MCS and enforcement data (assuming they have it available).

As an example, one of the scoring issues is “Systematic non-compliance”. I have some level of access to regional compliance databases and vessels compliance indexes, so I searched the names of some of the vessels I know are part of certified fisheries. The results were shocking in some cases. Of course, I cannot divulge this information without breaking my confidentiality agreement, even if I think that all compliance data should public.

In general, the compliance history of these vessels tends to reflect the attitude of conformity of the skippers and owners, particularly when it comes to systematic compliance issues in assessment scores. Furthermore, it shows what is the real compliance capacity of the flag states.

I struggle to understand how come Principle 3 can be evaluated without that info being available for each flag state under the UoA. On the other side, can we expect the client to have access to this data if they are not the Flag State Authority or the vessels owner? Or assuming he is keen to pass that information to his detriment?.

Perhaps is simply the case that the MSC Principle 3 was not designed for multi-state fisheries like tuna, but more for fisheries where flag / coastal / port / processing state are combined (and there are many of those)

Personally, and based on my observations from the fishing ports, I feel that the “motivation” of the vessels involved is more to “whitewash” their names and score a bit more of money that for sustainability issues.

In fact, the certified vessels are doing nothing more of what they should be doing: following the rules. Perhaps if they were to catch less of what they are allocated or giving up vessel days, then I see a sustainability drive, otherwise we are rewarding legality like if it was something special.

Furthermore, from my usual job checking training boarding officer on purseiners, I have noticed free-schools sets in the evenings or prior sunrise. From my experience, the only way to do a free school set at night is with a perfect full moon and even so is very weird.

I suspect that “free schooling” (new verb!) of FAD-associated school is going on (while the observer sleeps?). The support vessels will temporally remove or push away a FAD and then the Purse Seiner drift towards that location at very low engine revs while keeping a sonar eye on the biomass, then the school will naturally move and associate with the Vessel. Once at a safe distance, voila, you have a ‘free school.”

The other issue that bugs me is something I explained before, is what as a friend defined as MSC stands for “Mushy Skipjack in a Can” due to the soft texture of the fish. And this is something I heard now from various processors (in fact I will be codirecting a thesis on this).

Looks like with the influx of "FAD-free" fish, the canneries are encountering a much higher percentage of fish with really “soft texture,” hence the levels of rejections and downgrading has increased.

This “soft texture” may have something to do with a higher level of enzymatic reactions, and the higher body temperature of fish caught while actively feeding in a school during the day, as opposed to fish caught while lazily circling a FAD in the very early mornings.

In any case, this is a truly wicked twist in this saga, since if the level of rejections has increased which means that more fish is sent to the fishmeal factory. As the canners work against volume orders that they need to cover, more fish needs to be caught as to fulfil the contract, so the whole situation it is going against what any sustainability measure should aim for: catching less fish.

Finally, I’m not comfortable with the use of fisheries observer to “guarantee” the “catches and chain of custody” something that is only required in the Tuna Fisheries.

In the Pacific, observers have a lot on their hands already, scientific data, compliance and MarPol, in an already complex set up. So having them involved in a private commercial enterprise does not seems ethical nor fair. While observers are getting a payment plus for the MSC work, these may offer chances were a conflict of interest may arise. Furthermore, the observer is supposed to stay on board for landing or transhipment of MSC catch, which is quite a lot to ask for an observer when he gets to port.

Today for 3rd time in this year, while training officers on vessels clearance to assess the legality of catches and monitoring transhipment volumes, on vessels that had MSC catch. I've seen that no observer was controlling the mixing of certified and non-certified fish

I want to make clear that I’m not trying to fire cheap shots to MSC, I believe that it does work for some fisheries (even I don't share why we need ecolabels), but perhaps wasn't designed for the complexities of multi-states fisheries like tuna. And this should not surprise anyone after all Frank Zappa said it many years ago: "One size does not fit all.”

Domino effects of cumulative bias and erroneous data in fisheries big-data mapping models

A couple of months ago I wrote on the report of Global Footprint of Transshipments produced by Global Fishing Watch and then on the methodology used. I was quite positive about it, recognising that the base tool AIS, while limited in their application to fisheries, is not totally useless.

The business of transhipemnts 

Now the other side of the bell rang, and a report by Roberto Mielgo Bregazzi from FishSpektrum (i+D).  I don't know much about them, yet they look like as a solid outfit that defines themselves as:

FishSpektrum Project (FSK) is a multidisciplinary “big-data” project focused in improving knowledge on global fisheries activity and historical footprint that combines the identification of vessels and their fishing capacities as well as their targeted fishing grounds

FSK's core is based on a Unique Fishing Vessel and Fish Carrier Vessel Identifier Database (UFVFCID or Krakken) that currently accounts for some 1.697.327 fishing-unit references and should reach the 2 million mark by the end of 2018, thus already the single largest and most robust existing fishing vessel database in the world, largely doubling FAO’s Fishing Vessels Finder (FVF) data content.

The report is a critical in-depth look on the GFW one, and from what you can see in the abstract (quoted below) is not particularly complimentary of it.

Cumulative-biases in fisheries big-data mapping models have a domino effect that inevitably culminates in independent innovative and worthy technological projects failing to deliver the scientific rigour that is expected of them.

Worse still, they open up such projects to the charge that the over or under-reporting in their findings and the lack of rigour in their statistical analysis is down to politically biased vigilantism, skewed more towards media environmental activism rather than a true reflection of the situation at sea.

Moving from public-facing awareness- raising tools to credible independent Monitoring Control & Surveillance (MCS) systems that help bring rogue fishing industry to order, such is the challenge facing the independent fisheries MCS intelligence community.

Science advances by contrasting research and educated criticism on a subject. I don't have the technical knowledge to have an opinion on the accuracy of these two reports, yet I celebrate that they are out there and deepening the understanding in an area that is going to get more and more important. 

No storing fuel on fish wells anymore, if you want that Tuna to go to the EU...

A couple of weeks ago I commented on the EU's FVO (now Directorate F of DG SANTE) findings related to the common practice of using the fish wells to transport fuel in purse seiners and longliners.  At the time I could not go into too many details because the reports weren't published. They are now.

Smells more than fishy in there...

While the this is not the 1st time the FVO found this issue they have grounded their rationale in these two published reports for Ecuador and Colombia. You can download the reports from the links under each countries' name.

This will have a big impact on the logistic of the fleets and on the Competent Authorities (CA) of flag States authorised to export fish to the EU that controls them. 

From now on, if an inspector of a CA of the country (the flag state) authorised to export to the EU verify this practice, then the fish in that well would not be elegible for the EU.  Furthermore, if the practice continues, that vessel should be taken out of the EU approved list, hence all its production is not eligible to the EU (either directly of via any processing company that exports to the EU)

The interesting question now is, what is the role of the CA in a Port State if they are required to verify the conditions of unloading and they see that the vessel is loading fuel in a well. Should they inform the responsible CA (the flag state one) of the issue?

If it was a fishery non compliance they should under PSMA (Port State Measures Agreement) but there is no such an obligation for the EU market access requirements other than good practices and due diligence.

Jope can guarantee that no Fuel has ever been there... we don't need to do it, we fish near by and we don't get fuel subidies. 

what a fish well looks like... 

Has the EU an effective fisheries control system in place?

A very good report by the European Court of Auditors was recently published and it makes for interesting reading. The court's job is to audit the effectiveness of different bodies and EU-wide policies. This time their question was a simple, yet amazingly complex to answer: “Has the EU an effective fisheries control system in place?” 

Fisherman in Vigo, Spain

They approached the issue from various sides and found quite challenging answers. I’m not gonna go over the whole report (read the original), but it was on one side reassuring, and on the other side worrying to read statements like this:

In general, the Member States we visited planned and carried out fisheries inspections well. However, the fact that inspectors did not have real-time access to information about vessels reduced the effectiveness of inspections. Member States had established standardized inspection procedures, but we found cases where available report templates had not been used by inspectors. The inspection results were not always correctly reported in the national databases. We also found that sanctions applied were not always dissuasive. The points system, one of the main innovations of the current control regulation intending to ensure equal treatment of fishing operators, was applied to very different extents across Member States we visited and even within the same Member State. Finally, there is currently no European register of infringements and sanctions, which would allow a better follow-up of points applied, a more effective risk analysis and enhanced transparency among Member States. 

Reassuring, because there are parts of it I could have written for many of the small Pacific island developing states I work with “had established standardized inspection procedures, but we found cases where available report templates had not been used by inspectors. The inspection results were not always correctly reported in the national databases. We also found that sanctions applied were not always dissuasive… there is currently no register of infringements and sanctions”. Hence if this is the situation in the richest and organised countries in the world, then we deserve some slack. Furthermore, we do have “real-time access to information about vessels” and we have also a developing register of infractions.

Worryingly, because many of the countries I work with got issued yellow cards for reasons that are no too different to some of the ones I read here. And these countries made substantial efforts that if we were to measure them as % of GDP are way bigger that whatever the EU states need to do to be shining examples of good practices.

To the EU’s praise, I have to say that I only read this type of information out of them themselves, and that has to be applauded. Yes, they have problems and they publish them for everyone to read. Total transparency. Something like this published by China or Taiwan would be unthinkable, yet totally necessary.

The other bit that really surprised me is the section on VMS, I quote:

On analysing the information in the EU fleet register, we found that 2 % of vessels that were over 15 metres long and were licensed to fish had no VMS, contrary to the requirements of the Control Regulation. The Commission had detected this irregularity but it had not been corrected at the time of the audit.  Due to the limited requirements of the Control regulation, at 31 December 2015, 89 % of EU fishing vessels included in the EU register did not have VMS equipment on board. Of these, 95 % were vessels under 12 metres long, which are not required to have VMS under the Control Regulation. Most of the vessels between 12 and 15 metres long (79 %) were exempted from the VMS obligation by Member States. We recognise the need to avoid overburdening operators of small vessels with expensive and complex localisation systems. However, the fact that an important part of the fishing fleet is not equipped with VMS represents a significant gap in the fisheries management system.

I totally understand that smaller vessels (>10m) should be exempt, yet for 79% of vessels in between 15-12mt to be out, is surprising. 

The one that wasn't surprising for me* was the following:

In the Member States visited, the VMS systems were generally being correctly used to plan inspections and monitor the fishing activities of vessels linked to the system. However in Italy, unlike the other countries visited, the system did not produce automatic alerts when fishing vessels entered restricted fishing areas, to enable the authorities to check whether the vessel was authorised to fish. Member States sometimes set more stringent conditions than those required by the Control Regulation. For example, in order to better check vessel activity under the national Mediterranean management plan, Spain required all purse seiners and trawlers, regardless of size, to be linked to the VMS. Moreover, some regional authorities in Spain required all vessels fishing in certain protected zones to be equipped with simpler (non VMS) localisation systems.

So basically, good on the EU for being transparent about their problems, yet remember them when you point fingers to others ☺

*Fishing back in Argentina was mostly managed by Italians migrants, and they weren’t very compliance oriented. Spain on the other side keep showing leadership in changing their compliance performance.

Global Fisheries MCS Evaluation Report

I have known Pramod Ganapathiraju for a few years now, (even if never actually meet in person I think). He has been involved in various areas of the IUU scene. My initial contact with him was in regards his  “anchor point and influence” methodology to examine illegal and unreported catches.

MCS in Action

The idea was to use empirical data from a wide variety of sources to establish “anchor point” estimates of the upper and lower bounds of illegal, unreported and unregulated fishing in each tuna fishery in different countries top 3 tuna species.  Monte Carlo simulations would be then used to investigate the effects of uncertainty, with 1000 simulations across the distribution of uncertainty. The aim was to estimate IUU catches for each of the tuna products caught from both within Exclusive Economic Zones (EEZs), the high seas and Regional Fisheries Management Organizations (RFMOs) waters. The proposal, unfortunately, did not get funding, but we stayed in contact.

He recently started publishing country reports from a mammoth Policing the Open Seas report, a global evaluation of Fisheries Monitoring Control and Surveillance to date covering more than 80 countries.

His report document’s latest information to draw a picture of the gaps & strengths in MCS infrastructure, inspections and capabilities in each nation to tackle and control Illegal, Unreported and Unregulated (IUU) fishing. 

Over a period of five years, more than 180 enforcement officials, MCS experts and Government officers from 84 countries were contacted for consultation and feedback at different stages of this MCS analysis. 52 confidential interviews were also conducted with enforcement officials in developing countries. 

There is hardly any published literature to estimate MCS effectiveness in the fisheries sector and hence his global study constitutes a unique resource.

As he is doing this self-funded, I asked why he took on this? Below is what wrote back to me:

I initially started on a pilot scale as a purely research based study for my Doctoral research over 5 years (2007-2011), and I published preliminary results of 41 countries on May 2011 (Pramod 2011). The results for the 41 countries was presented with a description in Pramod (2012). The range of attributes used in the questionnaire for the 2011 study was rather limited, but after completion of my PhD and once I resumed full-time consulting I contacted several key experts in Military and civilian agencies to make the attributes for scoring the 12 questions more robust. 

The study was then extended to 84 countries and using a wide range of interviews, phone calls and e-mails & assistance from fellow consultants I was able to get feedback from enforcement agencies and civilian agencies over a five year period. In the beginning, many fisheries related ministries and military agencies (Coast Guard or Navy) back in 2012 were reluctant to provide feedback citing confidentiality of MCS data. 

But after evaluating my request and case study questionnaire I received feedback from 75 countries. In many cases, I had to call the concerned person to explain the motivation behind the study before feedback was received and cited in Anonymous format. The range of feedback received ranged from a single response from fisheries ministry in the country concerned to 5 different responses from different agencies (ports, customs, fisheries, Coast Guard, etc.). 

Twelve of the 84 country reports were released online since April 2017 and another 10 reports would be made public in the coming months (http://iuuriskintelligence.com/global-fisheries-mcs-report/)

Note that all country evaluation documents are a ‘living document’ and may change with time. I remain open at any time to comments, corrections or adjustments. Just contact me.

Beyond any opinion, one may have on the accuracy of the individual reports by insiders knowledge, the task is impressive and good on him for tackling it.

And as some said to me once “no project is perfect… they are all perfectible!” so if you think you know better, get in touch with him and help make them better!

References
Pramod (2011) Evaluations of Monitoring, Control and Surveillance in marine fisheries of 41 countries, MCS Case Studies Report, Fisheries Centre, University of British Columbia, Canada, May 2011, 222 pages.

Pramod (2012) Illegal and unreported fishing: Global analysis of incentives and a case study estimating illegal and unreported catches from India. PhD Thesis. University of British Columbia, Vancouver, Canada, 343 pages (https://open.library.ubc.ca/cIRcle/collections/ubctheses/24/items/1.0072627)

One Noro at the time

By some reason, weekends are busy days in most fishing ports in the world, the cynic in me thinks it has to do with the fact that most fisheries administrations (as most non-emergency related public servants) work Monday to Friday. Not in Noro, the fisheries office here run 7 days a week.

We have NFD's 6 PureseSeiners, two Pole&Line (all locally flagged and crewed) unloading exclusively for Soltuna cannery and then various Taiwanese Longliners that use NFD as an agent for unloading of targets species and the port facilities for transhipping of by-catch.

We had 4 Taiwanese longliners coming to Noro this Friday. They announce that on Wednesday, which gave us the time to cross-check via FFA VMS their tracks and compliance index, furthermore via FIMS we can verify the whereabouts since their last port of call. As many of them are using e-reporting, we get to see how much fish they have declared, plus the EEZ where they fished, as well as the licenses they hold. 

Hence we have the tools to evaluate their activities prior arrival and approve their Port Entry and Port Use. We have been doing this with Port State Measures Agreement (PSMA) in mind, either by direct signing or perhaps via a WCPFC CMM (now that Japan, who was the main antagonist, has ratified and this is BIG news). In any case, we been doing it for a while so is up to the bosses in Honiara to decide what and when.

We have a target of 100% inspection on foreign vessels,  we suspect something from the screening, we go on board to find answers. If not (as with this 4) we go to the clearing and to crosscheck the e-log with the log sheet as well as the logsheets consistency and format, besides making sure that the vessels are the one we have tracked via the markings and the serial numbers on the gear on board. 

Jamie and John R clearing the arriving vessels

When (like on friday) we had 4 Longliners in a row and all of different sizes, getting to the last one can be tricky. So my full respect to Jamie and John, but especially to Nesii, there are not many young female fisheries officers that would move so at ease like her. 

Nesii makes it look easier

Once is all good the vessels is cleared to unload, with they start doing immediately, mostly -35 to -50C YF. As you can see we (in this case Sandy) tally each fish individually, next to the buyer rep and the seller rep. The fish goes immediately into a -50C container that is aimed later to the Asian market. 

Sandy weighs every fish

While our targets for domestic vessels could be lower, we do the same procedure (vessels VMS check, e-log and in these cases many times e-observers as well), we go on board to look for issues if any, and then clear for unloading.

Have to say that NFD vessels are the best vessels I ever work with, super straight, clean, most of them only fish in archipelagic waters and they know compliance by heart. In fact, they are the only MSC certification for tuna I have personally agreed with… but that is a thorny topic for another blog!

Here in Noro for the last 3 years now, we have accounted for every kg of each species caught by the locally flagged fleet for every individual landing and we have accounted for every kg that has been exported in any shape or form to any market, plus what goes for domestic consumption.

If it was unloaded and not processed or exported, then is here. End of story

We do a "mass balance reconciliation" prior every movement of fish out of establishments here in Noro. There is no way that "fish declared in is more than fish declared out" can happen. On a weekly basis, we audit a random landing of any of the seven vessels, and we check that "fish in = fish in storage + fish out", just to make sure that we are doing the right job.

Thankfully NFD and Soltuna have the best inventory and process controls database that is have ever seen in the 52 countries I have worked so far. I have know Edmond, the database guru behind it, for years now and we have always interacted on what is expected of the system to do from the compliance side. 

Jamie is great to work with

We (government and industry) can track and trace fish from any landing of any locally flagged boat from the moment it was fished to the container number in which it left Noro, and/or where in the coolstore is the balance… and we can do that without anyone getting crazy… because as I said, we do it on a weekly basis.

Now back to the LL! What is not landed (target species) is transshipped (bycatch and smaller fish). Transshipping for longliners are complex events as they happen while anchored, in the port area but away from the wharf. And it gets even more complicated when we try to estimate by-catch. As said the vessels are anchored (hence they move) therefore electronic scales don't do the trick, so we have struggled to account for the by-catch. So far we did pieces counting and weight estimations, yet this Friday we manage to account species, pieces, and weights. 

With a couple of old scales I found, a couple of ropes, a well-designed checklist, lots of humour and the good will of everyone we are doing the full load (piece by piece) of the four vessels.

And incredibly an inspector of Taiwan Fisheries Agency is here (albeit quite clueless), and he really wants our info (surely the EU yellow card has nothing to do with it). Solomons helps Taiwan this time :-).

Solomons helps Taiwan

What this system now means for us here, is that we check the legality via a procedure compatible with PSMA and then account for every kg of fish that is unloaded in Noro and for every kg that leaves Noro in any form or shape and we mass balanced it. 

Which is in principle what a CDS should do, and that one is long conversation we been having. 

The fact we manage to have this here in Noro in the Solomons (with all the limitations of an LDC country) is a combination of two very straight local operations and the good will from the local officers. 

And I cannot stress how critical this is, particularly regarding having the officers committed, empowered and understanding why they are doing what they are doing. And believe me, is not their salaries… most western teenagers have more pocket money over the year. But these guys and girls here do believe in what they are doing and understand the bigger picture. Not that they or things are perfect… far from that; the office is small and stingy (we moving soon to a bigger one), the car does not work, internet is unreliable, every thing takes long time to arrive... but the officers are committed, and that is worth gold.

Lunch with the crew, they would have not invited us if they did not respect what we are doing

But I think that if you treat people with respect for their way to see things, create personal connections, do their job with them, share food, learn from them, make it two way relationship… things do happen. Whakataukī (proverbs) play a large role within Maori culture, and my favourite for years has been this one:  He aha te mea nui o te ao (What is the most important thing in the world?) He tangata, he tangata, he tangata (It is the people, it is the people, it is the people). The longer I do this job, the more it makes sense. 

I don't know if what we do here is replicable across the Pacific or even in other ports in the Solomons… but I do know that Fisheries would be in better space if we could move forwards, one Noro at the time.

My home in Noro

Disclaimer
My presence here over the last 4 years has been of around 6 to 9 weeks per year, doing mentoring and thechnical gidance, either with contracts with FFA/EU or NZ Aid.

But I have been coming here since 2000 under many roles and agencies, if there was to be a 2nd home for me in the Pacific, is here in this leaf house you see, is my place here in Noro, the place that for me represents what fisheries should be in the Pacific.