Dr Seuss and "better recognising the imperative role of the state in governing fisheries"

I wrote in the past of the past about the Ghoti papers, and when I read the words in the title of this post on a paper, that on top of that has Dr Seuss, I was hooked. 

We have lots of Dr Seuss type characters in the fishing industry!

The imperative role of the state in governing fisheries and seafood is something I have insisted for a long time now. Is part of my criticisms of ecolabels and the unrecognised role of inequality, the impacts of poverty and other social injustices that contribute massivelly to poor management and overfishing.

This paper from Megan Bailey and 4 other researchers, is the kind of research I would like to be involved if I had the financial backing of a salary!. She (to my total delight!) wrote phrases like this: “Despite all of the limitations, the sustainable seafood movement seems to exist in a fantastical world of self-congratulatory corporate speak”... which is the exact feeling I have when I hear a lot of the presentation in the seafood conferences I get invited to speak or in the seafood shows I don't go anymore.

They also tackle some of the limitations of traceability and the sad role of the US SIMP and the EU CCS… I would love to see some more on CDS there as potential way to overcome the limitations she mentions and the traceability out of the Seussian world … maybe is something we can work in a future paper ;-) (hint)

I just will quote the abstract and some of my favourite parts, but of course read the original. (If you not subscribed, there are ways to get papers for free even if in a grey legal area)

Abstract
Approaches to counter the overfishing and aquaculture production crisis include those imposed by public governing bodies, as well as those implemented by businesses and non-governmental organizations (NGOs). 

In the case of the latter, private actors govern fisheries consumption and production through corporate social responsibility (CSR). In this contribution, we focus on three key tools that businesses are increasingly turning towards in an effort to meet the one particular CSR goal of sustainable seafood sourcing. In this context, the key tools of certifications, fisheries improvement projects (FIPs) and traceability are reviewed, and their potential as well as limits in contributing to continual improvement in pursuit of global seafood sustainability are analyzed. 

We argue that seafood CSR has created its own whimsical and fantastical world, a Seussian world, in which company image has become more important than sustainability performance. We posit four important barriers that must be overcome to bring seafood CSR back to reality. 

Specifically, we suggest moving away from the business case for CSR, reducing accessibility barriers for small-scale and developing world fisheries, reconciling different labels and sustainability concepts, and better recognizing the imperative role of the state in governing fisheries and seafood.

UNLESSS OMEONE LIKE YOU CARES A WHOLE AWFULLOT, NOTHING IS GOING TO GET BETTER. IT’S NOT

In this contribution, we examine three key tools used to meet sustainable sourcing goals, including seafood certifications, fisheries improvement projects (FIPs) and seafood traceability. The impacts of these tools are reviewed, emphasizing and questioning their potential effectiveness and their limits in contributing to global sustainable seafood production. Despite all of the limitations, the sustainable seafood movement seems to exist in a fantastical world of self-congratulatory corporate speak. But major barriers to real sustainability exist, including lack of a business case for CSR, lack of equitable CSR access to small-scale and developing world fisheries, competing labels and concepts of sustainability, and a lack of engagement with public policy. In some way, seafood sustainability exists as an example of what Jasanoff and Kim (2009) have termed socio-technical imaginaries: collectively imagined forms of social reality reflected in the fulfilment of technological projects. Jasanoff and Kim were speaking specifically of nation-specific imaginaries, while here we are dealing for the most part with private and not public imaginaries. Regardless, the outcome of employing the tools reviewed here, and experiencing the shortcomings we outline without addressing them, is a Seussian world of seafood sustainability

IT’S NOT ABOUT WHAT IT IS, IT’S ABOUT WHAT IT CAN BECOME

Certification
Intuitively, the most important question to be asked about sustainable seafood certifications is: are the products they certify actually sustainable? With regard to fisheries and stock status, Gutiérrez et al. (2012) found that when looking at Principle 1 of the MSC standard (stock status and harvest levels), nearly 75% of certified fisheries were above biomass levels that would produce maximum sustainable yield (BMSY) and over 80% had an exploitation rate that would maintain the stock at, or rebuild it to, BMSY. Yet these results differ to those from a study published only three months earlier that looked at the same stocks, which found that only 44% of MSC stocks had a biomass level above BMSY and only 52% had an exploitation rate that would maintain BMSY or rebuild the stock (Froese & Proelss, 2012). This latter study also examined Friend of the Sea certified fisheries, with the result being worse, only about a third of certified stocks were “sustainable.”

These two different studies are in one way evidence of two parallel realities unfolding in the realm of seafood sustainability: the Seussian world that MSC is living in, versus the grounded reality that scholars and practitioners are living in. (I find this Delightful!)

Just short of 15% of total fisheries and about 5% of total aquaculture production is certified by MSC or ASC (Bush, Belton et al., 2013; Marine Stewardship Council, 2016). The criticisms reviewed above, coupled with the small volume of certified seafood currently available, and the low certifiability of future fisheries and farms globally (i.e., how much production will ever be certifiable? See Bush, Belton et al. (2013)), certifications may always remain on the periphery and not be a scalable solution for seafood sustainability. In the end, certifications will continue to be important because they help define how seafood is caught or produced but do not guarantee the most sustainable seafood (Jonell, Phillips, Rönnbäck, & Troell, 2013).

Despite this reality, an incredible amount of money, and business and scholarly attention (this paper included!) continue to be directed to certifications, leaving other important potential solutions to remain off the radar of those in the Seussian world.

Fishery improvement projects
Fisheries improvement projects are one way to increase the pull towards a certification defined threshold, and in this way, may be an important component towards continual improvement in seafood (M. F. Tlusty, 2012). However, FIPs can also erode progress when, through their CSR mandates, businesses use them to meet a sustainable purchasing goal. Fisheries in FIPs are not managed to the same rigorous level as those that meet a voluntary sustainability standard. Thus, companies that source seafood within a “certification or FIP” to meet volume needs have lowered their sustainability bar.

Furthermore, the success and effectiveness of FIPs have been mixed and uneven with reports showing a large number of FIPs in the early phases of improvement (i.e. workplan design), without moving on to the implementation phase (Sampson et al., 2015). The effectiveness of FIPs is limited to the extent that it is a top-down approach to improvement (based on market demand), is still subject to weak transparency and verification, and often lacks “fair” cost-sharing structures as middle and upstream actors often bear most of the costs. The business case for these upstream actors has yet to be demonstrated. Despite these limitations, FIPs hold potential for using market forces to drive improvements through a collaborative approach, particularly in small-scale and developing world fisheries.

Traceability
Certain governments are tackling the current opaqueness in supply chains through data requirements for imported seafood products while some NGOs are running campaigns that aim to increase consumer demand for traceable seafood products (Bailey, Bush, Miller, & Kochen, 2016). Improving traceability in seafood supply chains is not without challenges as it requires intense sectoral and intra-sectoral collaboration across countries, cultures, and businesses.

Moreover, there are currently no agreed upon guidelines or standards delineating what constitutes a minimum set of data elements to be reported and or acceptable verification systems that make up a credible traceability system. Consequently, companies tend to develop their own systems resulting in a myriad of traceability systems and databases that may not be compatible with each other. Additionally, the United States relies on company to company traceability, operationalized through their new Seafood Import Monitoring Program (SIMP), while the European Union relies on country to country traceability, operationalized through the EU IUU programme. This lack of coordination has limited implementation, interoperability and impact of seafood traceability (Hardt, Flett, & Howell, 2017). My note: None of both programs tackle traceability in a meaningful way, read here)

To address some of these issues, WWF and the Global Food Traceability Center initiated a Global Dialogue on Seafood Traceability (GDST) that seeks to develop a global framework for seafood traceability useable by businesses around the world. Beyond technological roadblocks, traceability is also challenging due to the unequal distribution of costs and benefits associated with its implementation. The perception is that benefits tend tobe higher for downstream companies in terms of increased legitimacy and reputation and costs carried by upstream actors (Bailey et al., 2017). Broadly speaking, traceability holds great potential for eliminating IUU fishing, combatting seafood fraud, and ensuring sustainability claims are verified but it is questionable whether consumers should be—and can be—the ones driving the demand for traceable and legal seafood products (Bailey & Egels-Zandén, 2016).

My note: Catch Documentation Schemes have a role to play here: See here and here, of just better read this book

YOU HAVE BRAINS IN YOUR HEAD. YOU HAVE FEET IN YOUR SHOES. YOU CAN STEER YOURSELF ANY DIRECTION YOU CHOOSE

Private governance, of which CSR is a part, is generally believed to have emerged in response to the difficulties that states have had in effectively regulating public marine resources such as fisheries.

By setting “higher” standards than state legislation, voluntary, often NGO-led, governance vis a vis certifications (Tlusty et al., 2015) is argued to incentivize governments to “ratchet up” their regulatory performance (Cashore, Auld, Bernstein, & McDermott, 2007). But it is not “either-or” when it comes to seafood governance. Rather, weare increasingly seeing a discussion of hybrid forms of governance, where states contribute fundamentally to how private governance is assembled and operates (Gale & Haward, 2011). Perhaps this hybrid approach is what can bring us back to reality, and away from the fantastical and whimsical Seussian world of pseudo-seafood sustainability.

There is still debate around the extent to which CSR programmes, particularly certified, labelled, and traceable products, are actually representative of sustainable fisheries. As is the case with the public management of fisheries, all private approaches come with their own set of challenges and criticisms. These have been highlighted here to provide some food for thought on avenues of future research. So: where to from here? Interactions between standards and approaches (such as MSC, FT-USA, Monterey Bay Aquarium’s Seafood Watch), and between private and public actors are constantly evolving. Ideally, improved transparency in production and purchasing practices will promote a race to the top (Bailey & Egels-Zandén, 2016). It will be important to ensure the largest number of players can compete in that race, however, particularly those in the small-scale sector in the developing world.

Coming back around to the idea of socio-technical imaginaries (Jasanoff & Kim, 2009), it is likely harder to keep up the imaginary façade, as the number of participants increases; maintaining a Seussian world means continuing to keep sustainable seafood the purview of the few. Yet seafood sustainability is a “governance concert” (Barclay & Miller, 2018), and probably a symphony if it is to be at its best. Moving into the post-Seussian seafood sustainability era will therefore require all hands on deck to ensure that seafood CSR delivers in reality.

The CDS core function: Traceability along the value chain

Following with the promised slow digests of our book, here is the 6th post (here is 5th one), since It is essential to understand what a well design CDS is trying to achieve.

Here we consider the basic CDS architecture and the ways in which traceability is designed and implemented in existing multilateral CDS. This is important in that it is the basis for appraisal of where and how country traceability solutions can support and enhance the performance of a CDS.

Adapted from Gilles' original

The figure above shows the so-called “ABC graph”, which I adapted from the one sourced from Gilles' FAO TP596 Design options for the development of tuna catch documentation schemes and shows the following elements:

• segments of the supply chain: national segments above the horizontal line and CDS traceability segments below;
• possible stops in the national supply chain;
• possible stops in the CDS-governed supply chain;
• regulatory frameworks governing the segments; and
• three notional countries – A, B and C – that model product flow along an international supply chain and through trade.

The figure models a simple fishing, transhipment and landing operation at the harvesting end of the supply chain. More complex events such as multiple transshipments and landings and mixed unloadings are omitted for the sake of simplicity.

The basic operation of the document system through catch and trade certificates is shown at the stops in the supply chain where the documents are issued and validated by the competent authorities.

The supply chain runs from left to right, from fishing operation, transhipment and landing to products entering country A and being processed before being traded on to country B and subsequently to country C and so on.

The part of the graph below the horizontal line represents the international dimension of the CDS, managed directly by CDS-related mechanisms. All harvesting operations before landing, export, import, re-export, import and re-export are subject to the regulatory mechanism of the CDS; all transactions are recorded by the CDS and stored in its central registry in the form of certificate copies or electronic data.

The CDS directly covers only the following international segments: i) all events up to landing and the issue of a catch certificate establishing the legality of the catch; and ii) every trade event that occurs when the product moves between countries, each of which involves the issue of trade certificates and the creation of links with source certificates. In this way system-bound traceability and accountability is maintained.

The upper part of the figure represents the national traceability segments of the supply chain, where traceability is limited to the national territory through which product moves. These segments are not directly covered by the CDS but by national traceability laws and regulations, with a few exceptions.

No existing CDS traces product movements through national distribution chains: the only CDS records generated in the supply chain after landing and first sale relate to the entry of product into national supply chains and its subsequent exit – in other words the entry of product into and out of international trade.

The first and last transaction records in the national supply chain – entry and exit – overlap with the transactions recorded by the CDS and are hence captured in both national and CDS records.

With regard to national supply chain segments, none of the current multilateral or unilateral CDS have their own mechanisms to trace movements of products through the national segments. This is regarded as best practice because: i) the mechanism works for the CDS currently in operation; ii) the alternative option of covering national segments though a CDS-bound traceability mechanism would introduce so much complexity that the system could fail; and iii) many countries would reject the idea of mandatory recording and tracing of national transactions under multilateral CDS.

Hence countries are dealt with as “black boxes” by the CDS. The CDS creates certificates recording of what enters and what exits a country, but it is blind to transactions inside a national supply chain.

The CDS is nonetheless capable of stablishing important indicators for any country such as: i) imported species, products and volume; ii) exported species, products and volume; and iii) the balance between them.

To be relevant to the CDS these balances must take processing yields into account  because the form and volume of products change during processing. Failure to accountfor processing yields provides an opportunity for non-originating product to enter thecertified supply stream.

A well-designed CDS will automatically detect a discrepancy when trade certificates are prepared for products to be exported. What the CDS cannot do is identify the individual operator who has caused the discrepancy – unless the exporter is the only importer of products covered by a given certificate and the same products have not changed hands in the national supply chain. The latter – a national transaction – is typically not recorded at the CDS level.

If national transactions were recorded and links were enforced by a CDS, certificate fraud could be detected at the level of the individual operator. In the absence of this mechanism in current CDS and limited enthusiasm among RFMO members to consider it for the future, it is for national competent authorities to maintain the integrity of national supply chains under a CDS. Although a CDS can identify fraud-related discrepancies with respect to individual certificates, state authorities are responsible for investigating any such discrepancies and identifying and sanctioning individual perpetrators.

Another four weeks in Majuro

Back in December I wrote about what I do in Majuro as a NZ MFAT paid Offshore Fisheries Advisor to the government of the Marshall Islands, as I just finishing my 3rd four week visit, so here is update of what we have been up to in Majuro.

Beau off to perform a cmpliance boarding on a rainy Sunday afternoon... these guys are the sustainability leaders, not the ones in the meeting rooms

My favourite advance is the implementation of our Vessel Inspection Plan grounded on PSM. 

Operationally the plan is set up under the following scheme; the vessel arrival request gets loaded into the MIMRA IMS under a unique identification in order to be processed by Compliances Officer. Then, a procedural intelligence analysis (following a decision tree) is used for the determination of port use authorization, based on assessing the vessels trip information based on information available to the Compliance officers through FFA RIMF, regional VMS and FIMS.

This info check includes among others: FFA VoI, risk index and VMS track, Licenses for the areas fished, eForms information (when available) and eObs (when available). These information sources provide the required intelligence, which we compile on an Arriving Vessel Intelligence Report (AVIR).

The arrival is then approved in the port arrival system, which communicates the approval back to the agent and the boarding is scheduled and the boarding logistics set up. In the case of various arriving on the same day, the order of boarding is established in accordance with the FFA Compliance Index (1st green vessels, then yellow, then red... i like the idea of incentivising compliance by clearing the good people first).

The boarding officers bring the AVIR as to guide any investigation they want to pursue on the vessels. Only after clearance by the boarding and inspection team, the “Port Use” is authorised and the transhipping (or sometimes unloading) monitors (off duty observers) come over to monitor operations and account volumes. Only once they are on board, the operations can start.

We are not totally there yet (good things take time) as some elements are not totally in final form, for example:

Off to clear a carrier with Melvin

Forms: Are still in draft since they will be incorporated into MIMRA’s IMS Portal along the policy of having the PSM process standardised and electronically based. At this stage the e- vessels arriving portal is functional, and the development of the Arriving Vessels Intelligence Report (AVIR) is being incorporated.

Volumes monitoring: at this stage monitors (land based observers) either evaluate the volumes transhipped via educated estimations or in some cases using winch scales that the agents set up. MIMRA already started the procurement of our own set of scales to bring on board. These would be able to connect to tablets, so monitors can accurately record the weights of the fish being transhipped and their focus can be aimed to monitor catch composition in the net loads being transhipped.

Departure Clearance Inspection: at the present we don’t have the full capacity in terms of personal and resources to fully implement this important step every time a vessel laves. While in principle staff could be recruited and trained, there is presently no physical office space to host them, this situation if to change as soon as our new MIMRA building is ready (planned for August 2018) so we can close the circle of the vessels activities here in Majuro.

Part of importance of the vessels clearance is that we know then if there is any fish left on the vessel when they go out, or in the case of carrier how much fish is there, from which donor vessels and where is it going.

The confirmation of volumes is vital because the receiving country of the carrier, lets use Thailand as example, in it role as a signatory of PSMA is responsible for assessing the legality of the fish in the carrier, but they have rally little chances to access the compliance information of vessels that fish ¼ of the world away, furthermore… how they know that the carrier did not stop half way there and got unreported fish from someone else, mixed with the reported fish and try to launder it that way.

If the Thai DoF was to access our arriving and departing vessels clearances reports for legality and volumes, once the fish is “weight in” at the factories there, they verify if what we check leaving here, is what they are getting there

On the other side of the coin, we in the Pacific only have estimates of fish that has been caught via logsheets, observer estimates and soon the scales. Hence having access to the verified “weight in” values would be a unique way to confirm the accuracy of logsheet reporting and our transshipment estimations, which in turn could allow for better-targeted inspections on vessels that are potentially misreporting and/or underreporting their catch.

So why we don't swap that data, and we have one of those win-win situations?

Hold my beer…. and watch the space ;-) 

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At a personal level it has been quite an interesting 4 weeks.

Firstly i'm staying at house of my my friend Dr. Sergio Bolasina (in the picture to the right) and his family... we know each other since 1983 when we started university and been friends ever since, a friendship nourished by a very cynic sense of humour and the love of music. He started a position as the head of mariculture here at Marshall Islands College last January. Besides the pleasure of living with his family (which soothed the pain of missing my own one) I still pinch my self when I see him around... of all the places in the world we could have ever think about living when we lived in Mar del Plata, Argentina... Majuro definitivelly wasn't in the list!. 

Secondly, I got revive my old Search and Rescue swimmer skills when saving a drowning man a couple of weeks ago... ‪I was walking home along the road by the lagoon near Lojkar, and I see people screaming and pointing into the ocean. Everything happened really fast after that... it was obvious that a man was drowning over 100 mt away, then the trained instinct kicks in and i had a long swim out while measuring the current, once I got to the man it was easy to see that he was drunk and barely breathing, so I stabilised him. He says something about another one yet I don’t see anyone else... the current is pulling us, so I tackle a angle that would get us back to shore in a accessible area. Luckily we land there, he spits some water but is ok and quite shaken. People come to us... some cry, others hug me. All seems to happened so fast. Someone handle me back my bag, a bit confused I walked home, had a shower and started to think about how much could have gone wrong... it was all very intense, but I'm thankful to my training over 30 years ago and my love of swimming. We both got to live another day.

Thirdly, we had a well know documentarist following our work for 3 days, and this is all a bit nerve wrecking (even if authorised by the management) as one does not want to be portrayed in light of someone else angle or agenda. My job is based on the trust people have in me if that is ruined, I;m ruined. As I said in an interview last year: I'm just a fisheries specialist that provides technical and practical advice to countries and organizations. I don't take sides in the fisheries arguments, we all need to do better... end of story. But I'm a humanist, and I believe that only people can me make the difference, yet as long as everyone thinks that only their views are the only truth, we all fu*kt.

And finally going fishing with the family of Beau, one of MIMRA's fisheries inspector near Arno Atoll... We work with IUU fisheries during 6 days a week and then go catching fish on the 7th... can be monothematic... but we love it. 

The key part of fisheries that sometimes people forget

The fisherman...

anonymous crew on a purseiner

Not the vessel owners, the big companies, the international organisations, the NGOs, the ecolabels, the regulatory bodies, the traders, the agents, the consultants like my self, the companies, the marketing guys, the trade fairs, the executives and everyone in the value chain... We all have a job, just because the fisherman.

Beyond the cases of forced labour and abuses, most are just hard working people putting their loved ones ahead of their comfort and well being... and doing it with a smile on their faces.

They are not the ones involved in miss-reporting or setting over species of interest, or the rest... they are doing their job and they are the biggest part of this industry.

I do miss the simplicity and camaraderie of that life somedays... yet I grow up in a different fishing era, where crew nationalities and flag-states were related. Cost cutting and competition has changed that. This shift has been bad for fishers from richer countries but good for the poorer ones, so I'm always in two minds about it.

In any case, you all have my outmost respect and thankfulness. 

anonymous crew on a purseiner

The “name and shame” of countries as a strategy for dissuading IUU fishing

While the EU “yellow and red card” of some countries in relation to their persuasiveness to IUU fishing has received substantial media attention, the US has done something similar since 2009 by identifying countries in their the biennial reports by the NOAA to Congress filed under the provisions of the MSRA, and a regulation under development to track and certify the legal source of imports of certain fish species “at risk” from IUU fishing. (I covered the 2017 one here)

While their ways and modus operandi are entirely different, one could argue that their final objective is the same. So how they compare over countries and regions? One is to assume that countries that are persuasive to IUU fishing would be similar under both systems, yet no one has made that comparison until it was tackled by my friend Gilles Hosch in a study he published in 2016 and that I blogged about here.

It took me a while to get to the details, which I resume and quote here, but I recommend you read from the original, since what he writes is always good and solid stuff.

The EU began identifying the first countries at the end of 2012, through a procedure which is now widely referred to as the “yellow and red card” approach. As part of this procedure, the EU Commission has initiated “dialogues” with as many as 50 countries. The list of countries the Commission formally engages with is not public. These dialogues take place pursuant to Article 51 of the EU IUU Regulation, and are initiated as “mutual assistance requests.” Under this process, a country may receive a visit by a delegation composed of EU Commission and/or European Fisheries Control Agency staff, who may then issue a report regarding their findings to the EU Commission.

Based on these reports, the Commission decides on whether it is satisfied with the third country’s performance regarding IUU fishing. If it is not, the EU Commission may request that the third country implement changes that the EU Commission deems necessary in order to avoid formal identification under the regulation. If this dialogue is successful, the third country may avoid entirely a formal identification under the regulation. While this dialogue process appears to be very consultative, it is not particularly transparent: none of these bilateral exchanges or reports are made public, so gauging their effectiveness is impossible.

If mutual assistance requests formulated by the EU Commission and bilateral dialogue do not produce results that the EU Commission deems satisfactory, then it will formally “pre-identify” the country, by issuing a formal Commission decision listing the third country’s shortcomings (i.e. issue a “yellow card”).

The Commission’s pre-identification decisions are public and establish fairly long lists of shortcomings, which collectively serve to identify the country’s failure in addressing IUU fishing and provide the justification for the identification. While the design of the identification system suggests it can be linked to non-compliance with the CCS requirement, in the first Commission decision of 15 November 2012, none of the shortcomings listed in respect of the eight countries related to non-compliance with the EU CCS.

The US approach limits the definition of IUU fishing to operations in international fisheries in which it is directly involved, either as a member of an RFMO or as a party exploiting a high seas resource not yet managed by an RFMO. The US definition, with its focus on US interests, stands in stark contrast to the broad FAO definition adopted by the EU, on the basis of which the EU can identify a third country for failing to adequately manage fisheries resources within its own Exclusive Economic Zone (EEZ).

The rules for identification and certification are provided for in the MSRA (Section 609), and are further detailed through the final rule published in the Federal Register in 2011 (Vol. 76, No. 8). A country is “identified” if, in the view of the US administration, it has vessels under its flag engaged in IUU fishing. The “certification” which follows can be positive, in which case the identification is lifted, or negative, and trade restrictive measures (TREMs) may be imposed (Mexico was the first one to get such joy in 2017). This procedure is similar to the yellow, green, and red card approach of the EU, with the difference that the identification under the MSRA (equivalent to an EU yellow card) is a formal step in a regulated process.

Under the MSRA, the process starts with identification, and a two-year consultation and cooperation process follow “for the purpose of encouraging such nations to take appropriate corrective action with respect to the IUU fishing activities described in the biennial report” (Federal Register 2011). Identification can only relate to IUU activities that occurred over the preceding three years. In EU law and practice, no such limitation applies and consultations in the form of less formal or more formal cooperative dialogue are conducted at all stages.

Potential TREMs under the Moratorium Protection Act may be issued in relation to specific fish or fisheries products from given countries that have been negatively certified. This implies—potentially—that the scope of US TREMs would be limited to specific products, rather than a blanket embargo on all fish products.

Since 2009, 28 countries have been identified under the MSRA as having had vessels engaged in IUU fishing. Some of these countries, including EU member states, appear on the list several times, indicating that there is no immediate limit on how many times a country may be identified, delisted, and re-identified. The reasons for the identification are published in the biennial reports to Congress and are posted online. With very few exceptions, reasons provided for the identification pertain to established and documented infringements of fishing vessels to specific RFMO conservation and management measures.

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In any case, the contrast in the geographical focus of the identifications could not be starker. For the EU it seems that the hub of IUU fishing was the Pacific Island countries (we have only two left*) and only recently started to move towards Asia, while for the US is mostly South America. How come each system has identified such different regions is perplexing.

The EU "card system" has catalysed positive changes in many countries, and in an unexpected twist in my opinion, it has been more successful than the Catch Certification system itself. I have written at length about this. 

Furthermore, and I always make this point, while the EU impose the rules - beyond how good they are - they also fund the assistance to help comply with them. No one else does that.

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*Kiribati and Tuvalu

The two fundamentally different CDS models

Following with the promised slow digests of our book, here is the 5th post (here is the 4th one), since It is essential to understand the two models of CDS we have: multilateral and unilateral.

Current CDS are multilateral schemes founded on international treaty law establishing RFMOs and their rule-making powers, with the exception of the EU CDS, which is a unilateral scheme based on the EU IUU Regulation. (See at end of page, why we don't think the US SIMP is a CDS)*

The fundamental difference between the EU IUU Regulation and current RFMO-based schemes is that it limits the range of action open to the EU in regulating the operation of its CDS. Limits to the EU’s regulatory reach apply specifically to fishing vessels, waters, territories and trading partners that are outside the jurisdiction of the EU.

Because no country or block of nations can impose internationally binding rules, the EU decided in 2008 to regulate the types of fisheries products that could or could not enter its territory. It ruled that fisheries products sourced from IUU fishing would be denied entry into the common EU market as of the beginning of 2010.11 The EU market – and not any particular fishery or fish stock – is the basis of the EU CDS.

In all other cases the fishery and stocks under the purview of an RFMO are the basis of the CDS, and the CDS is legally established through an RFMO CMM that is binding on its members and has the force of international law. The CMMs cover the harvesting and trade dimensions of the CDS and are applicable to the entire fishery, all the trade regardless of supply chain length and permutations, and – by logical extension – all stakeholders that deal with the products in the fishery or in international trade.

Current RFMO-based CDS cover the entire stock unit throughout its global range, and must therefore also be understood as a fisheries-management measure that supports the conservation and management of the species as a whole. Any stock harvested under an RFMO-based CDS is subject to the protection conferred by the CDS.

Another major difference between the EU scheme and RFMO-based schemes is that under the former fish from any fishery are to be certified if it is eventually to be exported to the EU market. Under RFMO schemes, on the other hand, all harvested fish is subjected to certification regardless of its final destination.

The EU scheme thus protects its market from the importation of illegal products, whereas RFMO schemes protect entire stocks from IUU fishing. The EU scheme would only effectively protect stocks from IUU fishing if the entire harvest from an individual fishery was traded to the EU – i.e. if “inclusivity” was maximised.

Although the EU is one of the most important global import markets for fishery products, there is no fishery from which all catches are traded to the EU. Indeed, there are few fisheries from which most harvests are exported to the EU, of which none in tuna fisheries.

The three major world markets for tuna are the EU, Japan and the USA; a number of emerging markets are gradually gaining in importance. The importance of a market varies according to the product that is being traded: the Japanese market, for example, is significant for sashimi-grade tuna, whereas the US and EU markets are more important for canned or canning-grade tuna.

In view of the Code of Conduct for Responsible Fisheries, which guides FAO work in fisheries, it is essential that fisheries management measures be applied to the stock unit as a whole to achieve the desired effect.

If particular tuna stocks are to be protected through CDS, and if the impact of the CDS is to be maximized, these systems should apply to the stock unit as a whole, all harvests should be subject to certification and all trade should be covered. It follows that, ideally, tuna CDS should apply to individual species and their stocks, and be multilateral in nature.

We accordingly explore the multilateral CDS option as the most appropriate mechanism for designing tuna CDS, and it highlights experiences and lessons learned from the EU IUU Regulation where appropriate.

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* The SIMP does not foresee the development and implementation of a certification system in the classic CDS sense, and validations of scheme-specific paperwork will not normally be provided by competent authorities along the supply chain upstream of final exportation to the US market. The onus to collect supply-chain information establishing the supposed legality of imported products would largely rest on importers under the SIMP

Why Traceability is critical for a CDS

Following with the promised slow digests of our book, here is the 4th post (the 3rd is here), since It is essential to understand why traceability is such a critical element of CDS.

paper may fade, but i doubt it will disappear 

The objective of a CDS is to keep illegally sourced fish out of legally certified supply chains and prevent them from reaching the market. To achieve this, legally certified fish must be identified and quantified at the beginning of the supply chain, and the “laundering” of illegally caught fish into any stage of legal supply chains must be prevented. A CDS must hence be capable of detecting laundering as it is being attempted.

The only tool that enables this is a well-designed traceability mechanism, which must span an entire supply chain from harvests to landings and to trade. Fish legally entering a supply chain at the harvesting end must be quantified and qualified (form of the product: round, H&G, fillets, etc) and the quantity of fish – which will be separated into thousands of individual catch certificates – must then be traced step-by-step throughout the supply chain by means of the issue and re-issue of export or re-export certificates – i.e. trade certificates – that link the traded products to their previous certificate.

The hard links between subsequent certificates makes it possible to monitor mass balance integrity as fish products move through the supply chain. The serial linking of certificates is the central concept in a CDS traceability mechanism.

The cardinal rule is that the sum of products recorded on child certificates – mother certificates show the source of a consignment and child certificates show the products derived from it – must never exceed the volume of product on the mother certificate (Taking into account processing yields and losses).

A CDS must be capable of monitoring and enforcing this as fish move through the supply chain. In the absence of a traceability mechanism that provides for hard links between mother and child certificates, the origin and legality of product batches along the supply chain becomes an unknown.

The laundering of fish is then undetectable and the CDS cannot achieve its objective; worse, opportunities for fraud are created because IUU fish can easily gain certification and market access through laundering.

If the traceability function in a CDS is well designed, however, and the CDS is implemented correctly by the parties along the supply chain, all laundering attempts can be detected, the perpetrators can be identified and sanctions applied, and the financial benefits of fraud can be forfeited. In this scenario the CDS is certain to achieve its objective.

A CDS is not a forensic tool such as a genetic test applied to a sample to establish whether a consignment actually contains the claimed species of fish. A CDS is a traceability instrument applied to an entire fishery, and in order to be effective it must be able to trace products through the supply chain and automatically detect laundering attempts as they occur.

A well designed CDS will forestall laundering because automated accounting routines can trigger an alarm, or can deny the issue of a certificate when mass-balance integrity rules are breached

On the incentives (and disincentives) around IUU Fishing

While trying to find something for my present job here in the Marshall Islands, I found this paper by Sumalia, Alder and Keith, that I really liked back in 2005, and still valid today. We talk a lot about curbing IUU with all sorts of technological tools and schemes, yet the very basic source of any cheating of any systems is grounded on the incentives for doing that and the chances to get away (and I'm saying this as ex fisherman and a regulatory advisor).

is not personal... is just bussines

We still making systems, regulations and ecolabels requirements that are based on some sort of moral code which we all know is very shifty and based on your needs and position in life... furthermore, and in my experience, those that have upper-hand of not having much of an incentive to cheat because their countries of origin are well off (in many cases based on the colonialism of their ancestors, but thats another story), are equally susceptible to "cheating the system" as those who are economically vulnerable or desperate. 

While the paper goes over various areas I love this bit:

The basic idea is that a vessel contemplating engaging in IUU fishing will undertake a subjective cost-benefit analysis. The following direct drivers and motivators play a role in fishers’ decision-making on whether to IUU or not to IUU:

1. benefits that can be realized by engaging in the illegal activity;
2. the probability that the illegal activity is detected or the detection likelihood driver. This depends mainly on the level of enforcement or the set of regulations in place;
3. the penalty the fisher faces if caught;
4. the cost to the fisher in engaging in avoidance activities. This depends on the set of regulations in place and the size of the budget allocated by the fisher to this activity;
5. the degree of the fishers’ moral and social standing in society and how it is likely to be affected by engaging in IUU fishing (if we modify this to address both moral standing and sense of fairness. It will be seen that, in the case of high seas fishing and RFMO regimes, the concept of fairness can act as a positive driver of IUU fishing). 

Benefits from IUU fishing as a driver
For many fishers, the potential to benefit from IUU fishing motivates them to engage in the illegal activity. To some extent the higher the economic return in a ‘legal’ fishery the lower is the tendency to engage in IUU fishing. In other words, if a fisher is doing well financially, i.e., making a sizeable profit from fishing ‘legally’ then the probability of cheating is low, alternatively if the fisher is losing money, and there is the potential to derive benefits from ‘illegal’ fishing then the probability of cheating increases. There is also the factor of greed, i.e., the fisher may be making a profit but still engages in IUU fishing because of the desire to increase profits.

The following factors are important in determining the potential benefit to the fisher if they cheat:

• catches—the more catch that can be realized by engaging in IUU fishing the higher the probability that a fisher will engage in IUU fishing, ceteris paribus;
• catch per unit effort or the time it takes to catch the fish is also a consideration since the more time spent searching for fish to and from the fishing grounds, the more the cost and the probability of getting caught increases;
• price—this is related to catch and if prices are too low then in most cases there will not be a financial incentive to cheat. This logic breaks down when food security is a driving factor. However, for the purposes of this study food security is not the focus;
• cost of fishing, which includes consideration of the cost if labor, capital, fuel, license and royalty payments, etc.

The expected penalty drivers

Detection likelihood driver: The higher the probability of getting caught the lower the incentive to cheat, ceteris paribus, and hence, the higher the risk that the violator will be caught. The major factors that contribute to this driver are,

1. the effectiveness and efficiency of the enforcement system;
2. social acceptance of cheating in society;
3. awareness of the regulations; and
4. the level of nongovernmental or private organizations involvement in detecting infringements.

The avoidance driver: A rational fisher engaging in IUU fishing in a situation where there is some degree of enforcement will take measures (such as engaging in transhipment of catch) to reduce the chances of being detected, this is denoted as avoidance activity.

The penalty driver: The severity of the penalty when someone is caught is also an important driver in the decision of a fisher to cheat. The more severe the penalty the lower the likelihood is of cheating, ceteris paribus. This driver is related to the detection likelihood driver in that if there is no enforcement then the severity of the penalty is meaningless.

Moral and social drivers

Many have observed that the deterrence model alone does not adequately explain why people engage or choose not to engage in illegal activities such as IUU fishing; rather moral and social factors also play a crucial role. It has been observed that a given population of fishers, for example, can be classified into (i) chronic violators, (ii) moderate violators and (iii) non-violators

Chronic and non-violators generally make up a small portion of a given population. The former have the tendency to undertake IUU activities no matter what, while non-violators will not engage in IUU fishing under any condition. Moderate violators, 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, and the probability of being caught.

Secondary influences that may affect the decision of moderate violators to IUU or not to IUU are the legitimacy of the regulation (and fishery management organization), and the norms of behaviour, including both the general behaviour of the fishers and the moral code of the individual fisher.

Furthermore, they go and develop a mathematical model for the analysis of the cost and benefit aspects of risks of IUU fishing. A key result of their study is that (for the cases they analysed) the expected benefits from IUU fishing far exceed the expected cost of being apprehended. For an assumed 1 in 5 chance of being apprehended, our calculations show that reported fines for the vessels apprehended will have to be increased by 24 times for the expected cost to be at least as much as the expected benefits.

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Reality for me is that combating IUU fishing has to do more with human behaviour than with just technology trying to find out the cheating . We are in fishing because of the money, doesn't matter in which side you are (there is not many people working for free in the fisheries world!) 

Hence, if as a fisher, I see an incentive from perfect reporting, full compliance and so on reflected in terms of cheaper access fees, lesser cost of inspection, better media presence, etc, etc… or no tariffs for countries with best performance. Chances are I will do the right thing because is more cost-effective than doing the wrong thing… but we still are not at that level of discussion yet, and we need to get there with realistic terms and people.

Traceability standards, technology and CDS

I promised that I would slowly digest and post parts of our CDS publication to bring some of the key elements to the table, here is the 3rd post.

IoF: The Internet of Fish

Although our book describes how CDS and national traceability systems should interact, technical aspects such as the programming languages of telecommunications platforms and the international e-business standards that may be used are not explored in depth.

But of course, it is important that CDS and national traceability systems that liaise with them should be aligned with international e-business standards such as the one developed by the United Nations Centre for Trade Facilitation and Electronic Business (UN/CEFACT). This global body for the exchange of electronic business information has developed specific agri-food sector standards that are endorsed by governments and intergovernmental organizations such as the World Trade Organization, the WorldCustoms Organisation and FAO. The UN/CEFACT standards are available at nocharge from its website.

Two of the examples in this paper are aligned with the UN/CEFACT standards – the New Zealand e-Cert (see Box 1 in the book) and the EU Trade Control and Expert System (TRACES) systems (see Box 6 in the book). A further example applicable to many elements of a CDS is the EU Fisheries Language for Universal eXchange FLUX standard – a data logging and exchange system based on the UN/CEFACT “schema” system that complements its Core Component Library. The schemas can be used for all data exchanges and processes in the Universal eXchange standard, and the Core Component Library is used to harmonize data to be exchanged and published. The advantage is compatibility with other standardization projects where fishery data can be requested from sectors such as customs, trade and food, and animal traceability (UNNExT, 2016).

The structure of CDS traceability systems must be standardised to facilitate interoperability. For this purpose the International Organisation for Standardisation (ISO) has produced ISO 12875:2011 which specifies how traded fishery products are to be identified and the information to be generated and held by the food businesses that trade the products through supply chains. The standard deals with distribution of finfish and their products for human consumption, from catch to retailers and caterers, but it does not cover data migration from one stage to another.

Similarly GS1 is a vendor-neutral not-for-profit organization that develops freely available standards for global use. It has developed standards for electronic data sharing – GS1 EANCOM and GS1 XML – and the 2015 GS1 Foundation for Fish, Seafood and Aquaculture Traceability Implementation Guideline.

There is currently no off-the-shelf software for traceability tasks in a CDS. Such products exist for private-sector operators, but no ready-to-use systems are available for state-level users. Countries that are developing their own applications on the basis of existing systems and traceability standards should consider the standards outlined by UN/CEFACT for developing their systems.

What about blockchain?
I posted recently about this, and repeat here something we wrote: "Blockchain technology may eventually eliminate the need for central registries, and is therefore likely to reduce the complexity and cost of transnational traceability systems. Current compliance functions enforced through a CDS central registry will remain in place to identify fraudulent transactions in blockchain systems and environments. The difference between a central registry and a blockchain approach to CDS data is a matter of form, not function."

image sourced from here: http://luxreview.com/article/2015/06/the-internet-of-things---the-jargon-explained

“Dollars for disaster” a good interview on Subsidies

Is not very often that I concur with Daniel Pauly's views (not that he would be ever need to worry about that!) but I have followed Dr Rashid Sumalia’s work on subsidies with interest for years. In this really interesting article by Oceana both talk about the origin an impact of subsidies in fisheries. And as you all know I hate subsidies, get rid of them and increase transparency along the value chain from licensing to consumer and we will have fisheries for a long time. In fact, I think they are worst than IUU fishing, or at least part of its cuase.

Yeah... f*ck subsidies... but I vote the one that gets me cheaper diesel

Anyway, I quote here what are in my opinion the most interest parts of the article, yet (as always) refer to the original.

Why do subsidies exist in the first place? 
Pauly: Fisheries subsidies have a different origin than agricultural subsidies. In France and in England, fisheries have been traditionally subsidized, beginning as early as three centuries ago, because these two countries wanted to maintain a number of operational fishers that could crew warships. These subsidies were part of the defense budget. 
Sumaila: Subsidies made sense when most of the world’s fish stocks were underexploited. In the 1950s and 1960s, the more subsidies a government gave, the more catch it got back. For many countries, that’s not the case anymore.

How do subsidies spur overfishing?
Rashid Sumaila: In theory, fisheries should be self-regulating. When fish stocks get too low, or fishing gets too expensive, workers and investments should move out of the fishery. But in practice, unprofitable fleets can continue fishing — and can even grow larger — when they receive government subsidies. The problem is enormous. In a 2015 study, my group at the University of British Columbia estimated that global fishing subsidies in 2009 were $35 billion, between 30 and 40 percent of the total value earned by marine fisheries worldwide. As a result of this artificial profit-boosting, and general mismanagement, the global fishing fleet is about twice the size the ocean can sustainably support. 

Note by me: I explain how subsidies induce overfishing in this graph here

Why don’t countries get rid of harmful subsidies? 
Pauly: The issue is that the first country to stop will be at a competitive disadvantage. The fish that they sell will become comparatively more expensive. And if other countries don’t follow up immediately, the first country will not be able to sell its seafood.
Some countries say they have gotten rid of subsidies, but figuring out whether this is true is tricky. We have discovered that Australia, one of the countries which claim to have gotten rid of subsidies, now gives them under different names.

Can fishing subsidies ever be beneficial?
Sumaila: Subsidies can be divided into three broad categories. The first category, capacity enhancing subsidies, is what promotes overfishing. The second, ambiguous subsidies, can either promote positive or negative outcomes, depending on how they are implemented. And the third category, the beneficial category, supports research and management. If you have a good management system, for example, you can detect illegal fishers and catch them.
Pauly: I can think of a scenario where you have fishers landing fish on the beach, throwing the fish in the sand, and later smoking them using procedures that waste fuel wood. You get a very bad product all the way from the landing and processing to the sale. Subsidies applied here could improve the product quality post-harvest. Thus, subsidies could finance concrete tables to display the fish, and well-designed smoking chimneys that make efficient use of fuel. This would make a great difference in increasing incomes.
Sumaila: The issue is that very few subsidies are of the beneficial sort. Nearly 60 percent of the global total goes to harmful subsidies like ship fuel. Instead of giving away subsidies that lead to overcapacity and overfishing, keep the money in the community. Use that money to upgrade the catch, rather than destroy the resource by intensifying overfishing.

What can be done?
Sumaila: One of the things we could do practically is take the top-subsidizing countries — there are a maybe a dozen — and then create cadres in these countries of biologists, economists and other thought-leaders to help their government really see how bad this is, and push through action. Sometimes it’s better to tackle global issues on a global stage, but sometimes one person in one country does something, and then that becomes something global.
Pauly: The irony about subsidies is that they contradict the spirit of capitalism. We can get support for getting rid of them. And then you might get a breakthrough at the WTO. Whether it happens through the WTO, or through multilateral arrangement, it is possible that subsidies could at least decline.

The types of states in a CDS

I promised that I would slowly digest and post parts of our CDS publication to bring some of the key elements to the table, here is the 2nd post.

Standardised supply chain: CTEs and State control

One of key issues we found when talking about CDS is a limited understanding of the “roles” of each type of state in the CDS picture in particular, but also in the MCS in general. Since country-specific mechanisms are often essential for verifying and corroborating submitted data, enhancing monitoring functions and identifying and sanctioning fraudulent transactions. (And is also a good proxy on why a "single country CDS" would hardly ever have a substantial impact on multi-state value chains)

The state types involved in fishing, landing, processing and trade of fisheries products along the supply chain are “fixed” and each type of state carries out functions that contribute to the success of the CDS:

Flag state. This is the state whose flag is flown by fishing vessels, whose activities it is obliged to authorize and to monitor under international law. In international fisheries targeting species under the management of an RFMO, flag states also have reporting obligations to the international body as to the activities and catches of their fleet(s). Oversight by the flag state covers harvesting, transhipment and landing operations, the latter typically regarded as the last transaction related to fishing. The flag state is crucial in a CDS in that it validates catch certificates for catches harvested during fishing trips deemed by the flag state to have been conducted legally.

Coastal state. This is the state in whose waters a fishing operation may be taking place, in which case the coastal state must provide the necessary oversight to ensure that foreign vessels entering its waters are authorized to operate, and report operations and catches to relevant coastal state authorities. Coastal states currently have no statutory role in existing unilateral and multilateral CDS.

Port state. This is the state in whose port(s) fish are landed. The port state has a legal obligation under the PSMA to ensure that only legal fish are landed by carrying out rigorous in-port inspections of vessels flying a flag other than that of the port state and voluntarily entering its ports to land fish. The port state is crucial in ensuring that catch to be landed from a CDS-managed fishery are covered by valid catch certificates at the time of landing.

Processing state. This is the state in which raw products are converted into semiprocessed products or end products. The processing state may be the same as the port state, but fisheries products for processing may enter the processing state by sea, air or land. Processing states are important in CDS systems in terms of ensuring that non-certified fishery products are not imported, processed or certified for export or re-export. The “laundering” of fisheries products into legally certified supply streams occurs mostly at this level.

End-market state. This is the territory in which final consumer products are placed on the market, acquired by customers and consumed, often after importation. In a CDS the action of the end-market state is limited to ensuring that non-certified products cannot gain access to its consumer markets – a crucial final element in guaranteeing the success of a CDS.

The illustration above shows a standardized supply chain with the segments covered or controlled by the various state types. It is clear that few operations or CTEs (Critical Tracking Events) along the supply chain are under the exclusive purview of a single state type and that a large number of operations fall under the purview of different state types along the supply chain. The flag state, for example, will (or at least should!) oversee transhipments and landings, but so will the port state when these do take place in a port, and sometimes the coastal state is involved in oversight of transhipments in its EEZ.

Yet is really important to understand, that a single country can act as a few or as all of the state types at once, and at different levels of involvement.

In the Tuna world, a country like PNG for example, is at once a important flag, coastal, port and processing state, and in a lesser level a market state. Countries like Nauru or Tukelau are only coastal states, Thailand is the ultimate example of a processing state, Taiwan and China (even if it brings some fish back to its ports) are examples of major flag states, finally the EU and the US, that dependes substantially on imports, are major End-Market States, even if they have their own fleet, ports and processors.

This multiplicity of roles is important, since from the seafood traded internationally; 61% originates in developing countries and 85% of it is destined for developed countries. The current internationally integrated seafood value chains show that for most products many different administrations may be involved from catch to consumer.

Nature and function of a CDS (Catch Documentation Scheme)

I promised that I would slowly digest and post parts of our CDS publication to bring some of the key elements to the table, here is the first one.

the simplest explanation of a CDS (page 12 of our book)

In the our experience there is some confusion as to the nature of a CDS, its objective and its core function. There is in fact no internationally agreed definition of CDS, and the diverse terminology used to designate a CDS such as CDS, catch certification system, catch documentation and traceability system and bluefin catch document scheme further confuses the matter because the terms suggest that the underlying systems may also differ with regard to design, objective and function. It is therefore important to posit at the start the object, remit and core function of a CDS.

CDS objective. The objectives of the three multilateral CDS are not clarified in the CMMs that establish them, though it is evident that they aim to prevent IUU fishing. The EU, however, clearly states that the objective of the CDS is to deny IUU-derived products access to its markets, thereby contributing to the goal of eliminating IUU fishing.

CDS remit. All current CDS apply to the entire supply chain of international trade, from harvesting, landing and processing to importing products into end markets. To achieve this they all have a system of data acquisition, storage, certification and documentation in place.

CDS core function. The CDS mode of operation is to identify a unit of legally harvested seafood, to certify that it is of legal origin, and then to track it through the supply chain – which may be highly complex – to the end market.

By allowing only legally certified fish to be landed, processed and traded, the supply chain is in practice fenced off from illegally harvested fish. The core objective of the CDS is hence to prevent the entry of “laundered” IUU fish into the supply chain. The challenge – and the criterion for success – is not in keeping legal fish in the supply chain, but in keeping IUU fish out (see illustrartion). Traceability is central in the implementation of this CDS function.

If IUU-derived products are denied market access by a CDS, their prices decline rapidly, the financial incentives are eroded and IUU fishing diminishes as a result. To achieve this, market access must be denied to IUU-derived products at every stage along the supply chain.

A CDS is hence not something that ends with the certification of catches by flag states. Catch certification is in fact only the start. Coastal states may wish to confirm that flag state certification of catches made in their EEZ is valid, port states must ensure that non-certified products are not landed, and market states must ensure that noncertified products are not imported, processed, sold or re-exported.

In a CDS, legality is established at the first step – harvesting. Preventing “laundering” is the objective of the system at all subsequent stages.

International Women’s Day 2018 (and their undervalued role in our industry)

I been vocal in the past the unique role and perspectives that Women bring to fisheries, and about my personal experiences working for a woman captain in a factory vessel, to the many managers (like today's PSM project). A while ago I posted about a questionnaire on the issue, by the Woman In Seafood group, the report is out and make for sobering reading.

At a global scale woman represent 50% of all seafood workers including 90% of all seafood-processing workers. Yet only 9% of woman are in managerial roles and over the past 12 months across the 20 conferences analysed out of a total of 820 speakers, only 20% were women…

And is not that you have to give them a space or job because they are woman, but rather because they are good what the do, and as I said they are there, here in the pacific alone on the top of my head I could name:  the chair of the WCPFC, the compliance manager, the tuna management advisor, the heads of two long lining companies are all incredible capable woman at the tope of their game.

As a I said before, I’m not coming into this issue from a “new age” approach but from a fairness approach and just from general attitude of pointing out what is wrong, assuming any fault of my own that contributed to it and help fixing it.

My friend and college Katrina Nakamura (another very incredible capable woman in seafood) finish her mails with a phrase by Francis Picabia: "Our heads are round so that our thoughts can turn." Hence if you have not done much about by ignorance or position, start changing that.

What can one do about it… well a lot… just by raising awareness is a best start, and bring the concept in your decision-making. I’m just a consultant, but for example I don't participate a speaker in conferences anymore if they don't have more female presenters that in the last edition.

Men and women occupy distinct roles all along the seafood value chain and regardless of location or level of industry development country, female workers are consistently over-represented in low skill, low paid, low valued positions and remain mostly absent at the other end of the value chain. The distribution of power and profit between the two sexes is uneven.

Women are a key resource shaping and contributing to the seafood industry, yet they remain noticeably absent from public discourse, research and industry development initiatives. Women in our industry are effectively rendered invisible and undervalued by decision takers and policy makers

So read the report, spread it around and do something about it… simple as that. Because at the end of the day, you would not be reading this if it wasn't for a woman when your life started.

The problem with comparisons about fishing impacts in the media

Recently I posted about a paper on the global footprint of fisheries, based on AIS. Albeit an interesting read on the use of the technology, I was taken aback on some of the comparisons made in the website of origin. Yet I had not the time to elaborate much on them, but someone that is good at that is Ray Hilborn, so I quote some of his responses to the claims.

Study state that vessels are now fishing in 55% of the world’s oceans, which is an area four times larger than occupied by onshore agriculture. The immediate popular conclusion was that this shows immense overfishing, and Oceana was quoted saying “That means we’re putting more pressure on fish populations.”

Hilborn says “The comparison to agriculture fails to note that the 50 million square kilometers under agriculture have destroyed the natural ecosystem as the plow or new pasture eliminates the native plants. The areas fished, particularly for tunas, have changed very little.”

Furthermore,  “Fishing does not impact the primary production (plants), and in very few cases does it impact the species that graze on the primary producers.  So the 50 million square kilometers of the earths’ surface that is used for agriculture is totally transformed,  most of the oceans that are being fished (high seas tuna)  have some changes in top predators abundance. 

 “High seas fishing for tuna, which constitutes the majority of the “footprint” shown in the Science paper has been mapped for 40 years, and the widespread nature of high seas tuna fishing is well known.  The footprint of bottom trawlers has been mapped in much finer scale already in many places, and the Science paper overestimates the proportion of the seabed impacted by trawls by 10 fold.”

The AIS data is interesting, and allows for specific types of research that was not possible before.  However, the dataset does not give as accurate a picture of global fishing as does the comprehensive database on fish stock surveys and catch records.

Hilborn is a longtime collaborator with Dr. Boris Worm, one of the authors of the paper.  Together they did a groundbreaking study of global fisheries databases, and helped create a standard dataset to measure fisheries catches and stock health.  Neither Worm nor the other authors are claiming that the AIS study shows increased fishing pressure on stocks, they are simply reporting that the tracking data provides a new visualization tool for global fisheries.

Now in my opinion, while these comparisons have the advantages of (sometimes) putting things in perspective against each other, they feel a bit like a "my dick is bigger (or in this case smaller) than yours" and I'm never sure how conductive to change this is. By the fact of living we are impacting nature... nothing grows under our houses, roads, schools, etc... We all have to make constantly more compromises, and this is not going to change as long as we live.

Does unreported catch lead to overfishing?

Is not the most know fact that the key element of IUU fishing in our region is not the Illegal fishing (as vessels without a license) but is Unreported (which is either; under-reporting – declaring less from what the caught, and/or miss - reporting declaring different species from what was caught). Besides the economic impact of unreporting, there are downstream consequences since you will never take the right management decisions with the wrong data.

verifying reporting the hard way... one by one in the Solomons

One area that I always assumed that would be immediately benefit for totally accurate reporting is stock assessment and modelling, since it would immediately impact the outcomes of the assessment, yet this recent "Fish and Fisheries" paper by Merrill B Rudd & Trevor A Branch somehow challenges that concept, to refocus it on the trends more than the actual figures. While I think in principle this paper was a response to the recent drive into catch reconstructions, I like the concept of the trend focus. It makes me think… and I like thinking.

Below is the abstract, but as always read the original!

Catches are commonly misreported in many fisheries worldwide, resulting in inaccurate data that hinder our ability to assess population status and manage fisheries sustainably.

Under-reported catch is generally perceived to lead to overfishing, and hence, catch reconstructions are increasingly used to account for sectors that may be unreliably reported, including illegal harvest, recreational and subsistence fisheries, and discards.

However, improved monitoring and/or catch reconstructions only aid in the first step of a fisheries management plan: collecting data to make inferences on stock status. Misreported catch impacts estimates of population parameters, which in turn influences management decisions, but the pattern and degree of these impacts are not necessarily intuitive.

We conducted a simulation study to test the effect of different patterns of catch misreporting on estimated fishery status and recommended catches. If, for example, 50% of all fishery catches are consistently unreported, estimates of population size and sustainable yield will be 50% lower, but estimates of current exploitation rate and fishery status will be unbiased. As a result, constant under- or overreporting of catches results in recommended catches that are sustainable.

However, when there are trends in catch reporting over time, the estimates of important parameters are inaccurate, generally leading to underutilization when reporting rates improve, and overfishing when reporting rates degrade. Thus, while quantifying total catch is necessary for understanding the impact of fisheries on businesses, communities and ecosystems, detecting trends in reporting rates is more important for estimating fishery status and setting sustainable catches into the future.

The 2018 FFA / SPC Regional Port Monitoring Workshop

I’m back to work and it could not be a better start. Quite a few people has been working hard on setting up a framework for Port State Measures (PSM) along the membership of FFA and SPC, but we are trying to do in a methodical and data driven way. Normally countries rush into stuff and then try to sort it out, well this time under the good leadership of my friend and colleague Pam Maru, they want to sort it out first and then walk into it.

my home and flatmates for this week

Is no news that PSM are an effective way of addressing IUU fishing and are generally focussed on determining vessel compliance with applicable conservation and management measures and laws, through port inspection regimes, since unfortunately we cannot trust always flags state as the first responsible for the conduct of its vessels.

Furthermore, the linkage of PSM’s with other port based activities that monitor and verify fishing vessel catches is a key step for effective CDS and in that way securing market access.

Technological advancements provide FFA members the opportunity to improve the effectiveness of their MCS arrangements and address some of the capacity issues faced by Small Island Developing States (SIDS). However, assistance is needed to better define how emerging technologies can be used to advance MCS capabilities.

FFA is implementing a five year project funded by the New Zealand Government aimed at strengthening FFA member PSM’s with the objective of ‘Reduced IUU fishing in the Pacific through cooperative monitoring, control and surveillance programmes’.

The project recognises the need for intensive national work to develop and deliver instruments and tools that will enable FFA members to enhance their PSM’s. This will also provide the necessary frameworks for members to participate in information sharing and MCS activities regionally and internationally, and to better combat IUU fishing.

I’m doing this work with my colleage Damian Johnson a former NZ fisheries inspector, whom I work alredy in the past in the Pacific and Thailand. We are expected to deliver in four tasks are to be delivered within the timeframes outlined as follows:

Task 1
Review all current port based activities and programmes (legal, fisheries management, MCS or otherwise), in each FFA member country, relating to PSM and CDS. This should provide a baseline on which to further enhance both PSM and CDS.

Task 2
Develop a framework for port state measures that identifies the minimum MCS programme requirements to implement effective port state measures, in the context of Pacific tuna fisheries managed by FFA members.

Task 3
To compile all relevant market state requirements, including the identification of data and certification requirements, determine if these requirements are met within existing regional information management capacity and provide recommendations to strengthen port based activities to support these requirements.

Task 4
Develop an IUU risk/compliance assessment criteria for port state measures, taking in to account the IPOA-IUU, FFA vessel compliance index, WCPFC MCS programme requirements and other relevant considerations. This work must support port based vessel inspections and CDS functions.

So more than interesting and busy times ahead. Personally this stuff is at the core of my work over the last few years (PSM and CDS). In fact in the book we recently wrote we put a lot of attention on PSM, and I quote: “The port is the point at which fisheries products move from the seaborne to the land-based supply chain. Few other points are as important for a CDS”, and “It is largely the quality of port state monitoring and the work of its port-based fisheries officers that determine the risk of illegally sourced fish entering the land-based supply chain”

Hence a good start to the (already full)  2018 agenda!

Tracking the Global Footprint of Fisheries

To tackle a study on global footprint of fisheries is quite a task, and to release the dataset to open public access is unprecedented. I have discussed before the limitations of AIS as a compliance tool, but is definitively a good visualization and transparency tool. The recent paper published in Science and the future analysis that could be done form the data set is quite something. AIS is definitively here to stay as fisheries tool.

I quote below from the Global Fishing Watch release.

Executive Summary

Humans have been fishing the seas for over 42,000 years and fishing is one of the most widespread means by which humans harvest natural resources. However, fishing’s global footprint – that is, its spatial and temporal patterns, and extent – was poorly understood and unquantified, until now. “Tracking the Global Footprint in Fisheries,” a new paper published in Science, presents a comprehensive, high-resolution map of global fisheries for the first time. 

The study, produced by Global Fishing Watch in collaboration with research partners at University of California Santa Barbara, National Geographic Pristine Seas, SkyTruth, Dalhousie University, Stanford University, and Google depicts global fisheries with an unprecedented resolution.

Below are links to learn more about their findings.

• Access our press release and media kit 
• Learn more about the Research Accelerator Program
• Download Global Fishing Watch data
• See Science paper
• View an interactive graphic showing fishing by flag state
• Read about the paper on our Research and Development site

This new dataset is possible because of new technology and creative use of data sources. Over 22 billion Automated Identification System (AIS) messages were processed and the researchers identified more than 70,000 seagoing vessels – including >75 percent of industrial fishing vessels larger than 36m – over a five-year period (2012 to 2016). Over the span of the study, these vessels engaged in 40 million hours of fishing activity, consumed 20 billion kilowatt hours of energy, and covered a combined track length of 460 million km, a distance equal to traveling to the moon and back 600 times.

Results revealed that fishing extends over at least 55 percent of the ocean – covering almost four times more of the Earth’s surface than agriculture. The absolute footprint of fishing is much larger than that of other forms of food production, even though capture fisheries provide only 1.2 percent of global caloric production for human food consumption. Five flag states – China, Spain, Taiwan, Japan and South Korea – accounted for over 85 percent of observed fishing effort on the high seas. 

Surprisingly, results also suggested that fishing activity is more closely tied to cultural and political events, like holidays and fishing regulations, than naturally-occurring events, like El Niño or fish migrations. In China, there is a significant decline in fishing during the annual fishing moratorium and the Chinese New Year. In the northern hemisphere, fishing activity declines over the weekend and breaks for Christmas.

Longline fishing in the open ocean for species such as tuna, shark and billfish, was the most widespread type of fishing globally, detected in 45 percent of the ocean. Longliners also had the greatest average trip length between anchorage, with the longest at 7,100 km. 

Results also demonstrated that significant regions of the ocean are not heavily fished, and these areas may offer opportunities for low-cost marine conservation, creating ‘buffer zones’ which conservationists say help marine species to regenerate. 

The data used to create this report and power the Global Fishing Watch fishing activity map is now available for download via the Global Fishing Watch Research Accelerator Program. The researchers hope that this data provides the tools for scientists, advocates, governments, journalists and citizens to better understand and therefore better protect their oceans. The data is also available through Google Earth Engine.

Is blockchain such a silver bullet?

Lots and lots of talk in the media about the potential of blockchain to solve issues from IUU fishing to forced labour and so on. I personally think that such a hype, typical from media that does not fully grasp the complexities around IUU fishing and forced labour (or even blockchain!) is not really conductive and as any hype, could be detrimental to the cause in the long term.

the tool does not replace the MCS job, it just makes the results transparent and verifiable.

I don't like the present hype because it puts too much pressure on one example of very good use of technology, but is not more than that.... IUU and forced labour issues are multifaceted and involve a lot of jurisdictions, socioeconomic and political aspects. Pining the solutions, on one data architecture tool is really unfair and risks hyper-inflating the expectations on what that technology can offer, and then people walking away because it does not deliver on the hype that was built around it. 

There plenty of explanations of what blockchain is, the way I see it is basically a digital ledger that is distributed, decentralised, verifiable and irreversible, so their records can’t be changed once in (but you still have to record it!) is a mechanism that can be used to record transactions of almost anything and where “ownership / responsibility” needs to be accounted for. 

I don't see limitations on the technology (blockchain) but rather on the political will to implement a system based on any technology available. Blockchain just offer some advances over other technologies to set up a Catch Documentation Scheme, which if implemented and set up the right way, involving the full set of MCS tools and catch accountancy requirements at flag, coastal, port, processing and end market states (read this book to know what you need how is to be done ☺) does has the chance to control IUU, but is a system that need to be adopted / imposed / sanctioned along the value chain by RFMOs, witch at the present are toothless tigers, in respect to compliance.

The willingness of any player in the seafood value chain to be part of any system that add transparency is based on the perceived economic benefits arising from its use and/or the fear of regulatory consequences of its "not use" (assuming the government agencies responsible have the mandate, willingness and capacity to enforce the rules)

Which  development tool (block chain, relational databases, etc) to use, is an interesting discussion, but the key point in my view, if "how" the tool is going to be imposed. 

Some players (like the system my friends set up in Fiji) can see the use of such a system as way to make better earnings and position themselves as the ethical operators they are, and see benefits along their customer base. But the company down the road (literally) has a very profitable and established market somewhere else that does not require any form of ethical assurances... so where is their incentive to use the system? (Which as I said is independent of the tool)

Now, if Fiji or any other country was to legislate that such as system is required by law for any trade and exports, that in principle is great... but no doubt will increase costs to the Fijian operators whom in turn would may not be able to recover it from the clients. Since your have other countries that produce the same fish and have not even thought about institutionalising such a transparency tool and they will be more competitive than Fijian producers are.

And here, is for me the key issue, we have not formalised the incentives system by which the ethical and legal operators are rewarded and the non ethical are punished by consumers* and regulators... and that is not going to be changed by any App or traceability tool (Independent of type of programming tool its used) implemented voluntarily by some operators or institutionalised only by some countries, while the competitor operators or countries (or the DWFN fishing on them) do not take part. 

Any flow takes the path of less resistance, fisheries is no different. Until there is a global commitment to value chain transparency tools like Catch Documentation Schemes (based on any technologies) we are just tinkering along the sides, by providing transparency to the value chain of responsible operators (who in reality did not needed them in the first place - otherwise they would have not volunteered to be part of the pilot project) we are showing it is possible, but we are not solving the issue.

Don't get me wrong, is great that systems like the one form my friends in Fiji works along the established value chain they have, because it shows that the system are able to produce results, and I’m sure it would work in another value chains like canned and loined tuna in the Solomons Islands, since they are also well regulated and run by very ethical operators. Yet these operators have never been the problem, is the rest of the sector that needs transparency... and that as any other transnational crime setup needs a combined and global effort, otherwise there would be always backdoors that can be used.

As my friend Gilles Hosch said: “With CDS we have developed a market-based tool to effectively tackle a range of severe forms of IUU fishing. Whether the collective will to adopt and expand these systems exists, is a different matter.”

*The whole argument that the ethical consumer will reward the good practices and transparency with a price plus, maybe real for part of the 29% of the world population the earns more than 10 USD a day, unfortunately my life experience has shown me that "ethics" is a very shifty ground... but then, I have grown up and spent a significant part of my life being part of the 71% that lived below that threshold.

Training on Science and Media

A almost constant in my life is that I have started working or getting involved in area and then later on did some studies on it. I got into blogging because the template in which I developed my website had a blog page and a picture gallery so I just started to add content, but there is more to that.

Media training in for science in action

A couple of times I have run into trouble for the contents of my blog posts, because I’m quite honest (candid?) about my limitations, issues and problems and I instinctively pass this attitude to of some of the issues we face in fishing. I fell like if I put them “on the table”, it means that I recognise them and I’m in control of what I need to do.

Other people see this as portraying your failures, and those who run a different agenda can use this info against you.… and I understand those sensitivities, yet I still think that total honesty and transparency about my failures is the best road to take, since you take the power “off” your critics and place it under what you are doing to change.

Yet being “out there” and having opinions (like the ones in this blog)  exposes you to the media… and as anything you do, it has advantages and disadvantages. Hence how to deal with media requires some training, and that is an opportunity I never had… until today, here at the University of Auckland.

A month ago I applied for one of the 12 places at the Science Media SAVVY workshop of the New Zealand Science Media Centre*, and luckily I was chosen to participate.

This is a two-day workshop designed to encourage effective media engagement, build skills and confidence, and enable scientists to navigate a range of media encounters with success.

More than basic media training, this course has been built from the ground up to meet the needs of scientists and researchers. It offer practical exercises to help researchers explain complex ideas clearly, introduce tools and strategies for connecting with new audiences, all while providing feedback and support from fellow researchers.

The workshop also offers a unique chance to make valuable media contacts and gain first -hand insight into news media practices during an invited journalists’ panel and newsroom tour. New skills are then put to the test with the chance to pitch research stories directly to interested reporters.

Their programme says that:
Researchers on the SAVVY course will:

• gain insight into what works for media

• work out compelling ways to explain tough concepts

• learn to be enthusiastic without losing credibility

• improve their on-camera presence with simulated TV interviews

• get advice on handling risk and controversy

• practice saying what they really mean to under pressure

• learn how scientists can use social media to their advantage

And so far so good! I’m leaning a lot and interacting with people that are way clever than me. Issues around how to structure the message and how to deal with media, body language, editorial keywords not only from the perspective of my opinion being sought, but also from the content I’m creating.

is a delicate balance, and one I'm sure I don't always get right. But then, if would not have takes risk over my life, I will still piling hake boxes in the hold of a rusty trawler in Argentina. I hope i can use this training to improve on this blog. Watch the space

*The  Science Media Centre is an independent, publicly - funded resource for New Zealand  scientists and journalists covering science -related issues. their aim is to promote accurate, evidence - based reporting on science and research by helping the media work more closely with the scientific community.

What I’m doing at the #fishackathon NZ 2018

A very straight forwards explanation of what a mentor does and why to be a mentor.