How does containerisation "works" in the WCPO for purse seine and longline by Francisco Blaha

Further to my blog yesterday on containerisation as separate from transhipment, a few people asked me to explain how containerisation occurs from the logistics and operational side, and if is the same for all fleets? As I’m doing some work on that topic, here is an explanation.

container from PS.jpg

Containerisation in our region is around 2-3% of the total catch due to a set of infrastructure limitations we have, and the fact that traditional transhipments via carriers would not disappear any time soon as I explained before… particularly because most people don’t consider that the job of carriers bringing stuff is as important as the one of taking fish back to processing ports. Carriers have also a fundamental role in providing goods and parts to fishing vessels (i.e. food, mechanical parts, oil, salt, foaming and cleaning agents, ropes, cabling, net components, fishing gear, etc.).

Containerisation requires a good level of port facilities, infrastructure, and reliable electricity supply yet equally important operations and logistics management. Yet it also needs the fishing vessels to come to port, which is costly as it requires port use fees, agents, etc. 

Purse seiners (PS) fishing in the WCPO are obliged to only tranship in port as licensing condition since 90% of the skipjack occur in the EEZ of the FFA members that are part of the Parties of the Nauru Agreement (PNA). Therefore, the alternative of containerisation is potentially more accessible. 

The situation for the Pole & Line (P&L) fleet is similar since they only operate from one port in the region.

Yet the situation is totally different for the longline fleet, since most of the fishing effort (~60-70%) occurs in the high seas (HS). In the southern longline fishery, about 30 to 40% of the effort has been in the high seas in recent years. This means that coastal countries have much less leverage in the longline fishery as to oblige vessels to come to port, and an increasingly substantial volume of the fishery is transhipped in the HS.

Countries licensing longlines to fish in their EEZ, worry that by implementing unloading in port obligations, the vessels just would move to the HS, and this will impact licensing revenue. 

While under WCPFC CMM 2009-06 at sea transhipments are not allowed in the WCPFC, yet there is an “impracticability exception” which has been abused. This is because impracticability is not defined nor explained, so many boat owners take advantage. 

Consequently, in recent years, the number of reported at-sea transhipments within the WCPFC Convention Area increased by 166%; from 554 transfers in 2014 to 1472 in 2019 (WCPFC 2020a[1]). Furthermore, as of 13 November 2020, 62% of vessels on the Record of Fishing Vessels (WCPFC 2020b[2]) were authorised to tranship in the high seas (WCPFC 2020b). The same study shows that the fishing vessels allowed to tranship at sea are mainly flagged to Taiwan, China, Vanuatu and Republic of Korea, and that the carriers receiving that fish are flagged to Taiwan, Panama, Korea, Liberia, China and Vanuatu.

For the longline (LL) fleet coming to port implies higher expenses than transhipments at sea, hence containerisation of landings is mostly limited to vessels associated to coastal states by permits, vessels chartered to local companies or domestic vessels. 

Freezer longliners can also be sub-divided between those that have ultra-low temperature freezing (ULT) capability at -60°CC and those that have -35 to -40°C freezing capacity, with the former commanding a price premium, hence the option of unloading fish aimed at ULT sashimi market is and tractive for vessel owners, albeit the expenses. In fact, many vessels licensed to coastal states land and containerise their ULT tunas and tranship the rest of the catch of lower value (i.e. swordfish, marlins, mola mola, mahi mahi, wahoo, and permitted sharks)

As the realities of the fleets are so different, I analyze each fleet independently, albeit some of the ports used being the same.

Purse Seine

As discussed, the WCPO PS fishery relies mostly on transhipments. Containerisation takes place on a much lower scale and is generally associated to specific ports and logistics arrangements. In some cases, vessels do tranship skipjack and smaller yellowfin and bigeye, but also unload for containerisation the bigger YF and Big Eye to be added to the longline value chain. 

In PS fisheries containerisation traditionally occurred without grading into species or direct weighing of fish, which are only estimated – through good approximations are generally obtained when containers reached capacity. Yet, theoretically offers the opportunity to sort catches by species and/or size, thus enhancing the opportunity for diversified marketing.

On board logistics

Once on board, tuna pass below deck to be loaded into wells. Bigger vessels employ chute systems while other conveyor belt systems to direct catch into desired wells, that also quickly deliver catch to wells. Tuna in PS are generally chilled whole in refrigerated seawater (RSW) without bleeding, or removing the gills, or gutting, and then brine immersion freezing. This technique involves storing fish in brine (made by adding salt to sea water) and reducing the temperature of the brine until the fish (but not the brine) are frozen.

Freezing such large amount of fish requires very large powerful freezing equipment and high volume wells which occupy much of the lower part of the vessel and are equipped with batteries of pumps for brine and RSW circulation. In the larger vessels, there are also ”dry or side lockers” that work a "additional freezer" where already brine frozen fish is stored “dry” (as without brine). Newer vessels also have specially adapted “dry locker" that act as blast freezers for higher value species, like those in LLs that can freeze and maintain to -35C

Landing logistics

Once a PS comes to wharf side and is tied up it can take a while until unloading is authorised depending on the level of inspection and regulatory steps required. 

Once landing is authorised, the following steps take place:

From well to deck
The “lifting” of the tuna out of the wells can be done in two distinctive ways:

Dry fish
In traditional unloading, the brine is pumped out of a well and the hand expansion valves are turned off an hour or so before the start of unloading. If a well is not packed too tightly, and the salinity of the brine used for brining and re-brining and the temperature in the wells are properly adjusted, the unloaders should be able to “hook” the fish loose from the mass of frozen fish and loaded into the cargo nets to the deck. 

Increasingly tuna is classified by species before loading into the net, and then sent up in separate nets, and/or further are separated on deck and put in different nets prior to unloading. 

In newer vessels, frozen fish from the wells is removed during the finishing trip and stored in the dry/side lockers that are never brined. Tuna is stored separated by species; the unloading process works on the same principle as the nets.

This is by far the most common way of unloading for transhipment and landing. 

Wet fish
Often fish are unloaded by the “floating off" method when they are to be transhipped. Under this procedure, the brine is left in the well during unloading. As soon as individual fish separate from the mass of fish they float to the top of the well since the brine has a greater specific gravity than the fish.

Long-handled hooks are used to separate the fish. The floating fish are taken out of the wells and moved via conveyor belts or chutes straight to shore and put in cargo nets, which are hoisted from the hold to the deck.

Wet fish method is often used when the unload goes straight into bins for processing or storage, but is not used for transhipping or containerisation since the ability to handle fish loaded in the holds of carriers or stuff them into a container as 'wet fish” is lower, as fish to then be removed from containers is frozen together taking more to operate, and resulting in higher rejects from broken fish.

From deck to wharf/pier
Once fish is on cargo nets on the deck of the Purse Seiner, they are hoisted by one of the cranes of the vessels or by shore-based one, straight to the wharf or to a platform at the wharf, either using one of the vessels' own winches or a shore-based crane.

A recent innovation that has accelerated the efficiency of unloading times, is the use of loading platforms to sort and load fish.

Loading (stuffing) of Containers
This is a mostly manual operation albeit with the different levels of mechanisation available in terms of loaders. They involve stevedoring staff in the wharf, platforms, and inside the containers, requiring regular breaks and staff rotation. 

Stuffing a container manually with 20 tonnes of fish can take around 2 to 4 hours, depending on: 

  • The weather (unloading is always suspended when it rains as it “wets’ the fish and also the whole operation becomes more slippery and therefor unsafe for operators) 

  • Quantity and experience of stevedoring staff 

  • The use of different types of chutes or conveyors to move fish into the container. 

This compares with the ability of more sophisticated loaders able to stuff a full container in one hour.

The working hours correspond to those of the unloading vessel, usually, 7 am to 10 pm with various breaks for food. Yet in some cases, if the unloading is done with a contracted unloading crew, the process can be done over 24 hrs, yet this is very unusual.  Photo 3 show the “stuffing” of PS tuna

Controls by fisheries authority normally take place during this stage (either officers or unloading monitors depending on the port state set up) evaluate volumes, estimated species composition, species of interest, etc.

Representatives of both, the unloading vessels and the responsible for the containers, are also part of these controls since accurate weights per species are key for crew payments and insurance premiums for the shipping of the containers. 

Efficient shore storage logistics are fundamental, since unloading from the vessel is a time-constrained operation and requires enough precooled containers and at least a loaded container lifting/moving machine and depending on the distance to the plugging points, container moving trucks, etc.

Once containers are fully loaded, they are moved to the electricity connection points “plug in” points able to provide 360-500 Volt, 50 or 60 Hz for the refrigeration units to freeze down the tuna to at least-18C. 

The cooling down can take many hours depending on the general temperature of the loaded fish and the "stuffing density’, as cooled air sped, and circulation are dependent on it. Containers need to reach the set temperature range specified by the shipping company before the container ship will allow them to be loaded.

Shore storage and container loading logistics
Reliability of industrial power supply (360-500 Volt) is fundamental for storage, and this has been historically a problem in the region. ADB (2019)[4] reports that the Pacific region faces a unique set of electricity challenges. Its limited supply of domestic fossil fuel resources has led to a historical dependence on imported fuels for power generation, and a corresponding vulnerability to fluctuating energy prices. At the same time, outdated power infrastructure, geographical dispersion, small economies of scale, and limited generation capacity lead to high electricity tariffs (or costly subsidies), transmission and distribution losses. 

Summed to this reality Van Duin et all (2019)[5] reports that refrigerated containers are responsible for 40% of the total energy consumption of container terminals, when connected to the electricity grid on shore. Every time when many containers are plugged in after arrival, peaks in energy consumption occur. 

While power consumption is high after plugging in, once the cargo has been cooled to low-temperature mode (below -10°C) the refrigeration unit is run in on/off mode, hence the average power consumption falls. Yet, power consumption per container is affected by environmental variables such as ambient temperature, wind speed and the level of direct sun exposure of the container.

CHB[6] (2021) reports that a 40' refrigerated container set at -21C and operating at a ambient temperature of 37.8°C, has average power consumption values of approximately 5.3 to 4.5 kW according to the type of refrigeration unit used.

Container ships operating to most pacific ports are self-loading (they have their own container loading cranes on board) and operate on tight schedules allowing 12-24 hrs operations per port. Therefore, the port container logistics need to be tight and involve the agents and all line agencies (Port Authority, Customs, pilots, biosecurity, immigration, etc). 

Containers need to be arriving in sufficient numbers to be loaded in an uninterrupted way while minimising temperature loss. The cargo vessel Chief Officer will check the minimum temperature once containers are plugged in onboard, and containers out of the temperature range are rejected. 

Shipping agents and exporters need to have all documentation ready and approved, i.e. Load list for all containers and verified weights per container, shipping instructions (with individual container identification), Bill of lading, export permits, and depending the jurisdiction and destiny, specific clearance for illicit drugs, biosecurity, bioterrorism and other may be required.

Longline

In the WCPO, there are two longline fisheries – the Southern and Tropical longline fisheries. Vessels operating within the Tropical longline fishery are typically large-scale distant water vessels fishing between 20ºN-20ºS, which target bigeye and yellowfin for sashimi markets, with smaller volumes of incidentally caught albacore. Vessels operating in the Southern longline fishery are typically smaller (<100GT) and target albacore for canning markets in subtropical waters below 10ºS and have small volumes of incidental bigeye and yellowfin bycatch.

With advancements in freezer technology, particularly for the smaller vessels, the distinction between the tropical and southern longline fleets has become less obvious, with some vessels now having the ability to switch targets depending on seasonality, fishing location, stock abundance, etc., moving between both fisheries.

There is an important intersection between some freezer longliners (large and small-scale) and both the sashimi and canning-grade chains. A longline vessel's albacore may be sold for canning, while BE and YF is sold for sashimi/value-added products. Importantly, and more recent development, high-quality albacore is increasingly consumed as sashimi in Japan. Japan traders mostly only take albacore from Japanese vessels and sometimes Taiwanese ones.

The albacore needs to be handled properly onboard (and differently to canning grade albacore), so a conscious decision is made by vessels to catch and handle albacore for the sashimi market.

FFA 2017 estimated that collectively, China, Taiwan, Korea, and Japan's longline vessels have accounted for 75-83% of the total number of longliners active in the WCPO. In terms of catch volume, these fleets have accounted for 39-48% of total longline catch under flag-based allocation, with additional catches attributed to chartering states.

Japan is the major global market for sashimi quality tuna, accounting for around 80% of global sashimi consumption originating from tropical tuna catches, FFA 29017 estimates that 65% is delivered by reefer carrier, 15% by ULT containers, and 15% by longliner vessels offloading directly (e.g. the Korean fleet).

For longline albacore, an estimated 50-60% of the catch is consumed on the US market (FFA, 2017) the rest is processed mostly in Bangkok.

On board logistics

Once on board, catches are, depending on the species, processed to a different extent on board; yellowfin, bigeye, and bluefin are bleed, chilled, gilled and gutted (eviscerated), fast-frozen, and then stored at -35C or -60C depending on the vessel characteristics. Lower value species are normally gutted and either gilled or head and fins removed to then sent to freezer storage.

Most Asian longliners in the WCPO have a very similar deck configuration, one hatch with a door entry on the stern side of the deck, one “central” hatch, and two equally sized hatches towards the bow end of the deck.

For the last decade, most fish caught in freezer longliners get a closed loop of monofilament line added to their carcass (normally to the caudal end and called “tail loop" during processing, to help with their transfer, movements on board, and unloading.

Landing logistics

Once a LL comes to the wharf side and is tied up it can take a while until unloading is authorised depending on the level of inspection and regulatory steps required.

Once landing is authorised, the following steps take place:

From hatches to deck
Crew wearing freezer gear enter the hatches and remove fish one by one.

For those fish in hatches at main deck level, the fish is dragged out. For fish below deck, a closed circle of thicker rope is fed through the “tail loop" to gather the fish together. The ends of this thick looped rope were slipped over the hook at the end of the vessel's winch/boom cable. Initially, the fish are removed from the LL vessel's hatch, with its cable and hook, and then placed on the deck.

From deck to wharf/pier
From deck to wharf depending on the height difference in between the vessel's deck and wharf side as well as tide range.

In the case of the vessel being at level or above the wharf height, chutes or sometimes conveyor belts from the wharf are used to disembark the fish.

When the wharf is above the vessel height, either the fish is placed on cargo nets on the deck of the longliners, or a closed circle of thicker rope is fed through the “tail loop" to gather the fish together.

Then either the ends of this thick looped rope or the four corners of the cargo net are slipped over the hook at the end of a shore-based crane cable to be hoisted to thick canvas or to a platform made out of plastic pallets at the wharf.

In the best-case scenarios, the refrigerated containers are placed as close as possible to unloaded fish, but in others the fish may be loaded in trays or cages and then transported by forklift to the “mouth” of the containers.

The working hours correspond to those of the unloading vessel, usually, 7 am to 10 pm with various breaks for food. Yet in some cases, if the unloading is done with a contracted unloading crew, the process can be done over 24 hrs, yet this is very unusual.

Containers can either be directly opened or through a covered “tunnel’ normally a container with both ends open. This tunnel protects from potential rain or direct sun.

In both cases, there is an electronic scale there where fish are weighted one by one, or in groups of the same species prior to being loaded into the precooled container.

Controls by fisheries authority normally take place during this stage (either officers or unloading monitors depending on the port state set up) evaluate volumes, estimated species composition, species of interest, etc.

Representatives of both; the unloading vessels and the responsible for the containers are also part of these controls since accurate weights per species are key for crew payments and insurance premiums for the shipping of the containers.

Loading (stuffing) of Containers
Fish is accounted "tallied " and then manually stuffed into the containers, until weight capacity is reached, and the container closed.

Once containers are fully loaded, they are moved to the electrical connection points (360-500 Volt, 50 or 60 Hz) for the refrigeration units to freeze down the tuna to -35C. The cooling down can take many hours depending on the general temperature of the loaded fish and the" stuffing density" as cooled air sped, and circulation is dependent on it. Containers need to reach the set temperature range specified by the shipping company before the container ship will allow them to be loaded.

Shore storage and container loading logistics
The reliability of electricity is more important for ULT containers since the temperate requirements are higher and failures con be very costly.

Once containers are plugged in, the logistics and management are no different than those explained under PS


References

[1] WCPFC. 2020a. “Annual Report on WCPFC transhipment reporting. WCPFC-TCC16-2020-RP03, Technical and Compliance Committee. Pohnpei, Federated States of Micronesia.

[2] WCPFC. 2020b. WCPFC Record of Fishing Vessels. Accessed 13 November 2020, https://www.wcpfc. int/record-fishing-vessel-database

[4] ADB, 2019. Pacific Energy Update. https://www.adb.org/sites/default/files/institutional-document/545686/pacific-energy-update-2019.pdf

[5] Van Duin et al. 2019. Factors causing peak energy consumption of reefers at container terminals. J. shipp. trd. 4,  https://doi.org/10.1186/s41072-019-0040-y

[6] CHB. 2021. Container Handbook. German Marine Insures organization. https://www.containerhandbuch.de/chb_e/index.html

The FAO Transhipment Guidelines Expert Consultation and the Containarisation issue by Francisco Blaha

Based on the outcomes of Thirty-fourth Session of the Committee on Fisheries (COFI), which met virtually in february, FAO Members agreed on the need for international guidelines on transshipment in fisheries. Members welcomed FAO’s in-depth study on transshipment, published in December 2020, and expressed concern on the risks that inadequately regulated, controlled and monitored transshipment poses in relation to IUU fishing. (I had a go to this document here).

Picture containera.jpg

Yet there are different types of transshipment operations, not all of which have negative impacts on the sustainability of fisheries, and noted that consideration should be made for regional specificities of transshipment operations. So FAO worked on the first draft of the voluntary guidelines and convened an Expert Consultation to review this draft. The expert consultation will take place in Rome next week 11 to 15 October.

 I don't know much about who has been invited to the consultation other than my ex-boss and friend Sam Lanwi (ex-deputy director of MIMRA in the Marshals and now deputy Ambassador to UN bodies based in Geneva).

Majuro is the tuna transhipment capital of the world (written a lot of my work there) and the many aspects of transhipment have been the cornerstone of the last 10 years of my work particularly when it comes to PSM, monitoring and logistics… since my fisherman days to now I must have been involved in over 500 transhipments… maybe 20 at sea and the rest in ports of the region with over 280 in Majuro itself).

Without having seen the draft (is only for the experts and they have been asked not to share them) I totally agree we need to standardise the data and the monitoring structure of transhipments, in particular those at sea (I’ll be happy to see them gone or at least only done with independent observers and electronic reporting and Monitoring

Yet I worry a lot based on what they wrote in the Transhipment: a closer look study that will try to incorporate containerisation in the wharf as part of the definition of transhipment… and that really worries me.., as I not what we do and believe in the region… and here is where we do most of the transhipments in the world and so far I know there is only one representative at the table.

The nuts of the issue is that the Transhipment study recommends,”that the definition of transhipment should extend to indirect transfers through, vehicles, points, containers, installations, facilities, or premises used for the carriage, storage or facilitating the transfer or transit of such catch” and as I believe the same people that wrote this study wrote the draft guidelines… that would be pushed. That will subvert all the PSM work we have done around here and let down PSM itself.

The great thing about PSM is that give the port state the opportunity of not authorising the unloading of fish from a vessel that has not proven his catches are legally caught. Ergo if the fish was illegally caught in the trip just before, the unloading is the time to act! Not month later when fish in a container arrives at some commercial port somewhere else in the world thousands of km from where the IUU event happen and the vessels that committed when back fishing again many times. 

PSM are never as effective as in the 1st port and should never be subservient to the customs status of that fish.

 Transhipment should only take place in cases where there are clear and agreed definitions of what constitutes “transhipment”. The present definition in the WCPFC suffice and are also reflected by the EU IUU regulation. Furthermore, is consistent with FAO Voluntary Guidelines for Catch Documentation Schemes (VGCDS). This transfer should only happen directly in between two vessels.

In this context, the term “landing” should reflect the definition of the VGCDS means the initial movement of fish from a vessel to dockside in a port or free-trade zone, even if subsequently transferred to another vessel. The offload or transfer in port of fish from a vessel to a container is a landing” and it seems that the intention is that fisheries definition landing should constrained by the prescribed process of entry into a country or to have been cleared as an import by customs.

I really believe that this process will substantially undermine the effectiveness expected of PSM best practices.

In fact that Transhipment study recognises that while an increase in direct transfers of fish from catching vessels to containers has been observed in different regions of the world.

These transfers are variously termed “transhipment in transit” or "transhipment to container" that take place mostly in customs bonded ports, without fisheries inspections or any reporting on the landing or transhipment of volumes and species transferred. 

 It points that with this activity, a lack of clear definition in terms of landing and doubt over the application of port State measures, all lead to monitoring uncertainties, this in turn increases the risks associated with unloading catches directly to containers, potentially giving rise to high adverse fisheries impacts. 

This practice deliberately blurs the line between landing and transhipment, in fact not defining it as either the one or the other. Authorities in the following port will not have clarity whether the catch has been previously landed or not, and no effective port State measures may be applied at any point. In these cases, catch enters the supply chain without any fisheries inspector ever having seen the fish and without any monitoring and control

This significantly increases the risk of IUU caught fish entering the seafood supply chain, when the fish is directly “transferred'’ to containers without any monitoring and control.

In practice, transfers into containers can be used to circumvent port State measures, especially when the fisheries products are assumed to have been previously landed upon arrival at the containers' destination port. It appears that with the growing number of parties to the PSMA and with strengthened port State measures all around the globe this practice could be chosen by certain industry actors as one way to transfer fisheries products into the market without monitoring or control.

Increasing containerisation should not be a reason to start calling landings transhipments.

I also believe that the increase of containerisation is also not as a much portrayed in the WCPO 

What is the situation of containerisation in the WCPO?

The Western and Central Pacific Fisheries Convention (WCPFC) defines transhipment as “the unloading of all or any of the fish on board a fishing vessel to another fishing vessel either at sea or in port.”

Up to 2019, around 80% of purse seine product and 22% of longline product harvested in the Western and Central Pacific Fisheries Convention Area (WCPF-CA) has been transhipped on or near the fishing grounds. Yet the figure for LL is increasingly questioned since, contrary to the Commission's intentions and rules, the number of high seas transhipments in the WCPO is increasing.

Reports to the Commission indicate that such transhipments have increased from 544 operations in 2014 to 1,472 in 2019. It appears that high seas transhipments are becoming the norm, rather than the exception. This situation is not conducive to the long-term conservation and sustainable use of tuna resources in the region – a stated aim of the WCPFC.

Interestingly “landing” is not defined in the convention (nor in the key FAO Key reference documents other than the CDS guidelines)[1], yet its understood as “fish that is unloaded to land “(wharf) under the principle that “unloading to port” been the de facto understanding of landing in the agreed data standards to be submitted to the WCPFC.

A recent development has been the increased direct containerisation of purse seine (PS), longline (LL) and Pole and line (P&L) catches that are unloaded onshore (and thus not considered as transhipping as defined by the WCPF Convention.

While in other jurisdictions this is referred as “transhipment to containers”, in all the Pacific Islands Fisheries Forum Agency (FFA) membership[2] is considered a landing/unloading to port under the FFA Post State Measures Framework, independently of the customs rules applying to the port where the operation takes place. 

The standardised view is that any fish leaving a fishing vessel while in the port area, either to be transhipped and/or landed can only do so under the authorisation and monitoring of the fishery authority of the port state. The next place of storage of the unloaded fish, being cool store, a processing establishment or a container to be shipped, is irrelevant in terms of PSM best practices to be applied.

 The volumes of tuna landed and processed in FFA countries presently represents approximately 14% of total fleet catches within FFA waters[3]. The unloading of fishing vessels to wharf to be then loaded into refrigerated (freight/shipping) from longline, P&L and purse seine operations but is not per se in captured in the regional statistics. While I’m working on the final numbers for FFA  that is likely less than 2 to 3 % in comparison to the catch currently transhipped to reefer carriers

Landing, sorting and containerisation is enticing for processors in the countries of destination (mostly in terms of production planning and logistics), yet also provides some benefits for the ports where it happens, as it provides employment opportunities. 

Furthermore, as longs as it is done in the framework of PSM, it facilitates monitoring by the port state authorities in terms of legality (not unload unless proven legal) including a better monitoring of volumes by species during unloading, but also during logistics since they have a maximum allowed capacity (20-25 tons), depending on the freight company.

The industry standard is 40ft refrigerated containers, based on the needs (PS or Longline) they can operate form the regulatory required of -18C down to -65C in specially insulated containers.

As discussed above, reality is that only a limited fraction by total volume of the tuna caught in the region is landed in Pacific Island Countries (PICs) and an even smaller containerised. Limited competitive onshore processing capacity and limited port facilities are the key reasons for this reality. 

Proximity to the raw material, the major comparative advantage over processors based outside of the region has not proven to be a sufficient advantage to generate an expansion of domestic processing.

Country specific and regional impediments include (but are not limited to) logistical issues, small domestic markets, lack of appropriate port infrastructure, market access issues, the lack of economies of scale, land availability and higher utility and other production costs[4]

There is always people involved and volumes measured during containarisation

There is always people involved and volumes measured during containarisation

Carriers vs Containers

As discussed, with few processing facilities handling purse seine fish in the region, transhipping is the predominant way to getting the fish from the WCPO fishing grounds to the processing centres in Asia (Thailand, Vietnam, Philippines) and Ecuador.  

The big three trading companies (FCF, Trimarine and Itochu) charter carriers and place them in the in a few ports (Majuro, Pohnpei, Rabaul, Funafuti, Honiara, Kiritimati and Tarawa) depending on shifting fishing grounds and licensing conditions. Some companies (mostly from Taiwan and Korea), operate their own carriers in conjunction with their vessels.

Of the 232 carriers on the WCPFC Record of Fishing Vessels register above >1,000 GT in March 2019, an estimated 140 are active in transhipping fish from the WCPO. Of these, over half were flagged to Panama. Of the remaining fleets, Korea had the next highest number of active vessels with 27 (owned by only 7 companies), followed by the Philippines (14 vessels) and China (9 vessels).

Interestingly, the COVID-19 pandemic has strengthened “transhipment in port” as safe bet and will potentially incentivise investment in extending the life of the present fleet of carriers and the constructions of new ones. 

Mr Lee (2021, per comm) a tuna operator I know with more than 30 years in the industry said: “If we didn’t had carriers they wouldn’t be any canned tuna in the market by now. And if there something we know in fishing, is not to have all your eggs in one basket, and with fishing vessels not allowed to land in most pacific island ports for over a year, containerisation was impossible, and we will in trouble"

This is in coincidence with MRAG (2019)[5] that reports that most fishing companies, traders and carrier operators interviewed for their study reported that containers had relatively little influence on the market to date, apart from squeezing margins from the old carrier business. Most thought that carriers would continue to be the dominant method of transporting fish to market for the “foreseeable future” 

The most common reasons given for this view were that:

  • loading of containers was too 'fiddly' and time consuming – in the purse seine sector, unloading to conventional carrier typically took 3-4 days, while unloading to container typically took 6-7 days. Given limited wharf space in many Pacific Islands, some interviewees also noted that fishing vessels unloading to containers would often be 'kicked off' wharf to allow higher priority container or bunker ships to unload. Ultimately companies saw this as a loss of fishing days and therefore money 

  • container facilities and logistical support are very limited in most Pacific Islands at present.

  • the slower nature of loading containers also presented risks to the cold chain and some companies reported having problems with reliability of containers, leading to rejection of fish at market

  • scheduling is a problem in Pacific islands – because volumes are very small, there is uncertainty about when fish can be delivered to market (by contrast, dedicated conventional carriers are a direct “door to door'' service). The lack of 'backfilling' opportunities would also undermine the economics of container carriers 

  • Our port Containerisations depend on efficient and cost-effective port operations, yet port capacity and infrastructure in the Pacific region has historically been limited, most ports in the region are well below international standards in terms of infrastructure and operations

  • Electricity infrastructure is very limited and expensive in the region a 40' refrigerated container set at -21C and operating at a ambient temperature of 37.8°C, has average power consumption values of approximately 5.3 to 4.5 kW according to the type of refrigeration unit used

  • Two of the companies involved in providing high seas longline carrier services said containers had had very little impact on the high seas transhipment business to date, noting that containers were ‘only competition if vessels came to port’

A further aspect seldom addressed, is that carriers have also a fundamental role in providing good and parts to fishing vessels (i.e. food, mechanical parts, oil, salt, foaming and cleaning agents, ropes, cabling, net components, fishing gear, etc.). 

Using salt as an example; FFA (2021)[6] reports the use of an estimated annual use 140000 tonnes of bagged salt used by the Purse Seine fleet in the FFA Membership (with the qualification that these are conservative numbers). 

Salt is delivered to PS by carriers while at sea, prior or during transhipments. As reference point the number of containers needed to transport this volume into the PICs using an avg weight limit of 20 ton per container is 7000 containers. This figure can be substantially more than the present annual total number of containers handled by most ports in the FFA membership.

Carriers have also a fundamental role on crew rotation and replacements on the fishing fleet. Since is substantially cheaper to have crew as passengers on carriers to then meet the vessels in the HS or in port, than to fly them to the Pacific Islands. This extends to visa issues since the gateways for flights to Pacific Islands are USA, Australia and NZ that require transit visas for most SE Asian nationalities, which are expensive and difficult to get, particularly for those without credit cards.

Comparative costs

Cheaper costs of shipping fish in reefer containers as compared to shipping fish by reefer vessel to cannery locations is of critical importance for the practice of containerisation, yet prices varies according to location, the availability of containers (which can be problematic in most ports in the pacific given the relatively small amounts of frozen inbound cargo and which can therefore require sending in empties), plus changing and fluctuating rates of third party shipping companies required to move containers from the end point of shipping company routes to canneries.

FAO (2021) [7] analysed the typical costs of shipping containers from Majuro (excluding all shore-based costs of stuffing containers, plug-in etc)[8] to canneries in Thailand and Indonesia, these are estimated to be in the order of USD 200-275/tonne. Over 2018-2021 the cost of shipping a 40ft container from RMI to both Bangkok and Jakarta by the Mariana's Express Line (MELL) ranged from USD 5 000 to USD 7 000, but an average/typical cost was USD 5 500 (i.e. USD 211 per tonne if containers are stuffed with 26 tonnes, or USD 275 if only 20 tonnes is in a containers). Other indications are that shipping costs (excluding all shore-based costs) may typically be USD 300-350/tonne. 

While costs charged by carriers for the transport of fish to canneries in Thailand and other main destinations vary for macro-economic, geographic and seasonal reasons, the cost ranges from 240 to 350 USD per ton, with no shore-based costs.

conati $.png

A recent article from The Economist (18 Sept 2021)[9], reports the average cost of shipping a standard large container (a 40-foot-equivalent unit, or feu) has surpassed $10,000, some four times higher than a year ago (see chart on the right).

The spot price for sending such a box from Shanghai to New York, which in 2019 would have been around $2,500, is now nearer $15,000. Securing a late booking on the busiest route, from China to the west coast of America, could cost $20,000. 

Globally 8m teus (20-foot-equivalent units) are in port or waiting to be unloaded, up by 10% year-on-year.  But disruption after disruption means that the containers are losing their reputation for low prices and reliability. Few experts think things will get better anytime soon. The dislocations could even hasten a reordering of global trade.

In the first seven months of 2021, cargo volumes between Asia and North America were up by 27% compared with pre-pandemic levels, according to BIMCO, a shipowners’ association. Port throughput in America was 14% higher in the second quarter of 2021 than in 2019. There has been little growth elsewhere: throughput in northern Europe is 1% lower. Yet rates on all routes have rocketed (see below), because ships have set sail to serve lucrative transpacific trade, starving others of capacity.

conta 2.png

So yea… I’m no one among the experts, yet I really hope that containerisation is NEVER included into the transhipment definition, as is going to be a mess, furthermore it only favours the dodgy countries that allow it to happen without any controls from its fisheries authorities.

We have a hard time already, to have smug operators come to challenge us (as they already did) showing us a FAO document that goe against what we are trying to do

References
[1] Landing” means the initial movement of fish from a vessel to dockside in a port or free-trade zone, even if subsequently transferred to another vessel. The offload or transfer in port of fish from a vessel to a container is a landing. http://www.fao.org/3/i8076en/I8076EN.pdf

[2] Australia, Cook Islands, Fiji, Kiribati, Marshall Islands, Federated States of Micronesia, Nauru, New Zealand, Niue, Palau, Papua New Guinea,  Samoa, Solomon Islands, Tokelau, Tonga, Tuvalu, Vanuatu

[3] FFA, 2020. Economic and Development Indicators and Statistics: Tuna Fisheries of the Western and Central Pacific Ocean

[4] FFA, 2017. Economic and Development Indicators and Statistics Tuna Fisheries of the Western and Central Pacific Ocean

[5] MRAG, 2019. MRAG - WCPO Transshipment Business Ecosystem Study

[6] FFA, 2021. An assessment of fishing vessels plastic waste generation in the WCPO region, and potential measures to improve waste management in the fleet.

[7] FAO, 2021. The purse seine tuna fishery value chain in the Republic of the Marshall Islands: Phase 1 project design report. (in press)

[8] But including insurance premiums that shipping companies pay to their insurers which are built into shipping costs, and which in turn are based on long-term assessment of any claims made against the shipping companies for damaged fish.

[9] A perfect storm for container shipping.  https://amp.economist.com/finance-and-economics/a-perfect-storm-for-container-shipping/21804500

What about the consumer choice? by Francisco Blaha

Enjoy your choices becuase most people in fishing do not have many

Enjoy your choices becuase most people in fishing do not have many

This paper had been in the pipeline for me to read for a while, which is unfair since I worked with one of the authors (Mariana Toussaint) during my involvement in the development of the Social Responsibility Guidelines for FAO, where she works.

Her paper with the other two researchers Intends to shed light on this nexus through qualitative research relying on in-depth interviews with decision-makers along the food value chain. Results suggest that consumers are sensitive to social abuse practices, but they face difficulties to access information in order to inform their decisions. Therefore, a higher investment in transparency instead of certifications is recommendable, as sometimes companies could be considered greenwashing.

And I like to highlight the following… “a higher investment in transparency instead of certifications is recommendable”… since align directly with my personal opinion on the topic, furthermore is my take that the effort for transparency should be based on strengthening the regulatory bodies in charge of social responsibility from the flag state all the way to the importing market.

As ai said before …The irony for me is mind-blowing. If a NGO or private certifications wants to help on these very real issues, why not just support the official institutions in the countries whose job and whole existence is to deal with those issues?

As usual, read the original. I quote here the abstract and part of the discussion

 Abstract

The environmental, economic, and social impact of food value chains have attracted the attention of a wide range of stakeholders. However, only a few studies have focused on sustainability in the food industry in terms of social responsibility from a developing country perspective. Indeed, existing analysis has not adequately addressed the role of social responsibility on consumers’ preferences and purchasing decision. This paper intends to shed light on this nexus through qualitative research relying on in-depth interviews with decision-makers along the food value chain. Results suggest that consumers are sensitive to social abuse practices, but they face difficulties to access information in order to inform their decisions. Therefore, a higher investment in transparency instead of certifications is recommendable, as sometimes companies could be considered greenwashing. In this regard a number of opinion leaders, including retailers and wholesalers, unions, media, and governments, can play a key role to enhance awareness through information flows.

 Part of the discussion

 The collaboration between trade unions, some NGOs and media is important to address these problems as it happened with environmental problems worldwide. Likewise, the collaboration between governments, the industry and trade unions is important to counterbalance powers in order to take actions from both conceptual and practical perspectives. The importance of increasing traceability systems to monitor operations and activities related to who has been involved in the elaboration of a product is key, especially as FVCs are getting longer and more complex. Furthermore, the identification of food brands is hardly recognized, as well as food products made under bad working conditions. Thus, the relationship between food brands and food products is less acknowledged from the consumers’ perspective. Consumers hardly identify a food product with its brand. Moreover, consumers may change their habits to mitigate bad practices, and they can turn to local markets as well as places where they know are responsible in their operations. Although consumers have the purchasing power, the prescribers of good social practices are those actors involved in a product's chain, but particularly retailers, wholesalers and governments. Both in collaboration with trade unions, NGOs international organizations, institutions and with their business partners.

 

 

 

 

Fishers in distant water fishing have been disproportionally impacted by COVID-19 by Francisco Blaha

When I started fishing, it was a bit of an old school apprenticeship process… you had to do a basic training at the fishing school, then spend time on a fishing boat to pike up days under the “wing” of an experienced master fisher/skipper. “Padrino” was the one that gave me that opportunity (something I’m eternally grateful to him)… he was not a man of many words, yet full of wisdom. He always had a saying or a metaphor to make his point.

yeap… I’m the reasons your can of tuna is cheap

yeap… I’m the reasons your can of tuna is cheap

One of it earliest and one that keeps seen over the last 40 years is that: “fishing is like a chicken coop, the chickens on the top shit over the ones below, and so on… fisherman are at the bottom so we always get all the shit, and underneath us is just the ocean… we are the ones that pay the real price of fish”

So life wasn't hard enough for fishers (I wrote extensively on the labour rights and mental health) this recent paper (Seafarers in fishing: A year into the COVID-19 pandemic) proves, what we knew, yet is good to see it fully explained.

 Seafarers/Fishers in distant water fishing have been disproportionally impacted by COVID-19.

Furthermore, it highlights 2 points I fully agree with and have been pushing wherever I can; Enhanced labor protections are needed for workers in distant water fishing, and a human rights approach to countering serious restrictions is worth considering.

This also fits on my opposition by principle against private certifications in the fisheries labour area.

As usual: read the original!  I just quote the abstract and the discussion/conclusions and put in italics the parts I fully believe in.

Abstract

This paper builds on our earlier publication that examined COVID-19, instability and migrant fish workers in Asia during the initial six months of the pandemic. Drawing on interviews with port-based support organizations and various other international organizations, we outline how pre-existing structural marginalizations of seafarers in distant water fishing has made them particularly vulnerable to the negative impacts of pandemic management policies for seafarers. We focus our analysis on obstacles to crew change and reduced access to crucial shore services.

The basis of these longer term marginalizations includes the exclusion of fishing from the Maritime Labor Convention, the marginal status of fishing among global organizations concerned with seafarers, the dispersed ownership of fishing vessels compared to concentrated corporate ownership in shipping, lack of unionization, and frequent inaccessibility of consular assistance in fishing ports.

We also highlight differences among important fishing ports, showing that repatriation of crew and access to shore services is the outcome of negotiation among a constellation of port-based actors.

Discussion and conclusions

COVID-19 has created major problems for all seafarers, including significant obstacles for crew change and repatriation, along with access to essential shore services. We show in this paper how seafarers in global fishing have been especially affected by these issues, due to pre-existing structural marginalizations. The problems experienced by seafarers in fishing due to the pandemic thus help reveal the long term and institutionalized ways that workers in fishing have been marginalized compared even to seafarers in other sectors. The modes of marginalization are multiple and complex, but taken together they demonstrate how work in fishing continues to be treated as exceptional in ways that justify the exclusion of workers from many basic labor and human rights afforded to other seafarers and to terrestrial workers.

COVID-19 is also revealing the limits of C188 as a way of addressing these problems. While C188 can be a good start for committing flag states to implementing regulations to provide for some basic standards on working conditions, it does not include provisions present in the MLC (Maritime Labour Convention, 2006) that are crucial to the well-being of seafarers. This suggests consideration of how protections in the MLC could be extended, or how fishing workers can be brought under the MLC. To some extent this can be done on a case-by-case, or port-by-port basis, as some countries and ports already include seafarers in fishing under policies for seafarers more broadly. But this can only happen in places where current policies are liberally interpreted. Another option would be to extend national labor law to fishing vessels where this is feasible.

The research further illustrates how important it is to address problems at multiple scales, including internationally. The ITF, ILO, and IMO are key organizations who have been supportive of seafarers in fishing at a global scale, but they are limited in their capacity to act by the lack of legal instruments that they can use as leverage, as well as their physical absence from many fishing ports. We have also shown that the marginalizations identified in this paper also need to be addressed on a port-by-port basis, where legal and institutional resources vary, and where informal practice may not always be consistent with formal policy. For example, it does not help to specify a role for flag state government officials (for example, C188, article 43) [28], if flag state representatives are not accessible.

Port-based support organizations, including both religious organizations and NGOs who support migrant workers, are important for both understanding the problems faced by seafarers in fishing, and negotiating assistance for workers. Efforts seeking to improve working and living conditions for seafarers in fishing would do well to listen to and support these organizations. They often operate on very limited financial resources, as well as in a precarious legal status with respect to port or worker access.

Many of the cases we heard arguably violate basic international human rights principles, as codified in the Universal Declaration of Human Rights [68] and other conventions intended to protect vulnerable groups, including the International Convention on the Protection of the Rights of All Migrant Workers and Members of their Families (1990) [69], and the non-binding Global Compact for Migration (2018) [70]. A key issue is that migrant workers in global fishing are effectively ‘foreigners’ in port states, who need to cross borders to go on shore, where their access to rights and services may thus be limited. The MLC includes provisions designed to address this situation, but seafarers in fishing are excluded and C188 is not very helpful. This suggests that a human rights approach to some of the issues outlined in this paper could provide an alternative approach to negotiating fishing seafarer rights with relevant states, especially those policies, legal instruments, conventions and protocols concerning state obligations to migrant workers and non-status people within their national territories. This is the approach taken by the UK-based Human Rights at Sea. The systematic violations of the rights of migrant workers in fisheries revealed by the COVID-19 pandemic are such that even the UN Commission of Human Rights could become involved.

In this paper we have focused on how the existing marginalization of seafarers in global fishing has contributed to their vulnerability to COVID-19 policies restricting crew change and shore access. The analysis has implications for the future as well, both while the pandemic continues, and after the pandemic comes to an end. Vaccine access is quickly becoming another key problem. Because fishing vessels often spend many months at sea, access to vaccination when they do visit ports is becoming a pressing problem. Some countries (e.g., Seychelles--interviews, [71]) have responded proactively by providing vaccination to seafarers in fishing. Others (e.g., South Africa [61]) were refusing to vaccinate seafarers as of the writing of this paper, at least in fishing.

Even after the pandemic has ended, the marginalizations that have been made visible during the pandemic will continue to degrade the welfare and working conditions of crew in distant water fishing. Any effort to improve poor and unacceptable working conditions in fishing will need to address them in some fashion, in particular, the exclusion from the MLC and the current inability of C188 to compensate. We argue that seafarers in fishing should be equal with seafarers in other sectors, and hope that future policies will work toward addressing the current inequalities and injustices.

The first time I met a fisheries Consultant by Francisco Blaha

I recently got approached by a Twitter acquaintance, Dr. Dyhia Belhabib (a quite remarkable person that you should get to know) to collaborate with a web publication Poplar & Ivy she has been spearheading. Quite interestingly for me, it didn’t had to do with IUU fishing or my usual work topics… but with my work itself, with being a fisheries consultant working in the development arena, but from an angle of colonisation in science and development.

Ken, Saurara and me working in Kiribati in 2019.

Ken, Saurara and me working in Kiribati in 2019.

This is an area I have been thinking to tackle for a while since I’m VERY aware that I do a fully “colonial’ job, and I struggle with that… I go to countries to “help” them to do a better job and “be” like the developed countries, which in most cases have been colonialist themselves… so it was a good opportunity to reflect on my job, my impressions from the 1st time I met a fisheries consultant and how I got to become one.

I’m also very aware that I’m not the usual consultant in the region; I’m not a native english speaker, I was a fisherman, I studied in non remarkable universities and I’m dyslexic.

I’m also aware that to write about a place that has been home, yet I’m not a local is very colonial! So I reached out the invite to my Fijian friends and colleagues Saurara and Ken (also consultants) to write about their journey into consulting for this article, but also about what they thought when they meet me! Since, I like it or not, I’m a foreign fisheries consultant! I’m humbled and thankful that they accepted and for their thoughtful words!

Needles to say I’m incredible thankful and humbled by the publishers’ trust, and to the rest of the authors of the other articles. I learned a lot from everyone

I really recommend you read all the articles in the magazine Poplar & Ivy, you may feel uncomfortable at times and/or you may relate to what your are reading, yet I asure you, you’ll have a bigger perspective at the end of it, and that can only be a good thing.

_

My story

“It's too personal, the donors are not interested in the stories of the people you working with nor your or their personal views, this is technical report, I know we wanted you to talk to them as stakeholders and get their views, but not as what they think is better, and definitively not their stories, names and places. Also your English grammar is terrible”…  this was the feedback I got for my first report as a fisheries consultant in the Pacific.

I remember the first time I met the fisheries consultant that gave me that feedback. I was working as a fisherman in the Western Pacific, I was in the wharf working out a massive line spill of the reel from a longliner, and this really white skinned man, with a strong British accent and lots of sunscreen came and asked me what agency I was working with? 

While I’m partly Eastern European in my ancestry, I have dark hair and skin. I sit in that mixed-race niche of a “white-passing” brown man or a “brown-passing” white man, so his first assumption was that I must be working for a development agency; otherwise, why would I be working with local fishers for a local skipper?.

He talked to me a bit and realized I had university training in fisheries (yet another surprise to him), so he invited me for dinner that night at a restaurant (that I could have never afforded) and interrogated me for 3 hours while I was eating. In the end, he gave me his card. 

A couple of years later, I was living in New Zealand and working for a fishing company there. I wrote to him then asking for the “report” he mentioned when we met.  He was happy to get back in touch with me, and he sent me the report. Shockingly, the report was more or less a transcription of what I said to him but without naming me once. As if that was not enough, and to my surprise, I felt his entitlement and lack of shame, when he also asked me if I would be interested in working for him as a “consultant.” He mentioned he could only pay me a reduced rate since I didn’t have “development experience.”

Albeit at that stage, I had two Masters of Science degrees and over 15 years experience as a fisherman in 4 different gears across two different oceans. Obviously, my English wasn’t at academic standards, so he would have had to edit my work before submitting it to the agencies he worked with. Still, he was offering me per day what I was earning in a  week… so of course, I said yes and became a consultant, did my first job, and got that feedback.

Having grown up in a native land on the border of Argentina and Paraguay under a colonial mind frame, the fact that a guy who has obviously never fished in his life and who could not have survived a full day in the sun, yet he was a Pacific Islands Fisheries Specialist didn’t trigger me. Well, at least not at first. He was white European, spoke excellent English, and was in a region at the other end of the world from the place he grew up in, so of course, he must be a master at his trade. On top of that, he was giving me a job! Of course, he was my “superior.” I was an “immigrant,” while he was an “expat”.

He didn’t need to know the names of the kids of the people I worked with, didn’t have time for us to share with him the stories of our ancestors, go to church, learn to cook local food… that was MY job. I was kind of like them, and he was not. Of course, it was ok that he paid me less money than he was getting paid, because he had to correct my English so that people like him, people at his level, could understand what I wrote without getting frustrated by my terrible grammar and dyslexia. 

It was only after a few years living in New Zealand and learning from the way Maori dealt with colonization and their rights that I slowly realised that I actually also spoke English, surely not as good as he did, but I also spoke three other European languages he did not, besides the native language of my childhood (Guarani). I could make myself understand in the languages of the places we worked in, and he didn’t. I also had a university degree, was already in those places targeted by the consulting work, and more importantly, I really knew a lot about fishing because I happened to be a fisherman. I realized that I could work at the same level as him, or actually better if I engaged in consulting myself without him as an intermediary. If needed, I could subcontract the editing of my reports. 

So, I started doing that, yet I never kept bad feelings towards him. In fact, I am always going to be very thankful to him. Without the opportunity he offered me and the connections to this consulting world, I may have never realized what I was capable of.

I also made a point of working with my Pacific islands’ colleagues in crossing that “colonial mindset gap” that took me years to cross myself.

I am still learning the challenges of decolonizing your own perceptions on work. It also made me realize that my European upbringing thinks in “me” terms, while my non-European one thinks in “we” terms. That launching yourself into the insecurities of self-employment as a consultant is not always compatible with the expectations trusted upon your role into the “we” mindset of families in the Pacific.

Over the years, these paradigms have been the topic of long talks with two fantastic young colleagues from Fiji: Saurara Gonelevu and Kenneth Katafono that are working as consultants in their region. Their words are more important than mine in this article, since they are the present and future, while I fade into a past where those that “know best” have to be from somewhere else, and that has to stop. That is why I asked them to write about their journey and what their impressions were when they met me as a foreign consultant.

Saurara Gonelevu Story

Like for many of my fellow PICs colleagues, working as consultants or debuting on the international scene of work could be quite intimidating. As a young Pacific Islander and more so, a female working in a male-dominated field, breaking into the arena of international consultancy, and working alongside experts from developed countries is an impossible dream and something that seems so far-fetched.

In 2016, I was encouraged by a few of my good colleagues and mentors to apply for a vacancy in the region through a New Zealand MFAT funded program. I seriously doubted my chances of getting the job, because I knew of only one of my Fijian colleagues who was working in the region in my field at that time.

One of those who encouraged me to pursue this opportunity was my good colleague and friend, Francisco. I met Francisco when he came in as an international trainer while I was an attaché with the Fiji Seafood Safety Authority. I always thought that he was different because, for one, he did not look like a “kaivalagi”, a term we use to refer to “white men” coming outside of Fiji. Second, he was a fisherman who could talk so casually about international issues and subjects without having to wear a suit. 

Being a Fijian Islander, we grew up in an environment where silence was deemed the highest form of respect so that was the first hurdle that we faced when trying to overcome the challenges of colonization. Even for my generation, it was sort of “normal” to believe that regional, let alone international, jobs were only for the chosen few who were at the top of everything, be it education, experience in regional work, or what is assumed to be sort of the “right age group” to be a consultant -- let alone your ethnic group, consultancies being often awarded to white men. I say this with great respect for our colleagues who are all that and still so inclusive of those that may come from countries that may be underrepresented in these regional and international arenas of work.

It takes one who has been in our shoes to understand our unspoken struggles, show the way, and give the best advice, which could help change mentalities to embrace the changes that are here now. Francisco is one such person I know to have had continuously made efforts in his work bridging the gaps that otherwise seem impossible to close up; i.e. the younger and older generation of consultants in the region and beyond, colleagues in the similar line of work in the region regardless of your skin color or status and more importantly interact with the same respect with fisheries decision makers and those who cut up fish as their everyday job.

In 2017, I was awarded the contract by the New Zealand MFAT to work in the Republic of Kiribati, and that was my biggest breakthrough. Four years later, thanks to the connections I have forged along the way and more people believing in local and regional talent, I am now working with international consultancy companies and other organizations like the United Nations Food and Agriculture Organization (FAO).

The challenges I share here, are issues that people like us have to overcome to then get recognition similar to those of our colleagues. Though I must say, I have come across some of the most amazing colleagues in other international organizations like Francisco who do not make you feel the issues discussed, and I salute them for that. They have been the true agents of change and have our deep respect for that.

Once we see ourselves as equals, we realize then that other Fijians and PICS colleagues, like Kenneth Katafono and Francisco, are constantly breaking the glass ceilings and whose journeys are a constant reminder that nothing really is impossible if you put your mind and heart into it. As I now am more conscious of the same, I take responsibility as well in working with others to forge onwards and overcome more hurdles that can further pave the way for the many hopeful PIC Islanders and my colleagues beyond the region who think these are only possible in dreams!

Kenneth Katafono Story

I started my consulting career in my final year of undergraduate degree studies, but it wasn’t until I started working in fisheries in 2012 that I saw and worked with many consultants - mostly older “kaivalagi” (European) men who had been working in Pacific fisheries for decades. As a novice to fisheries and being Fijian, it was intimidating to work with these consultants, many of whom had a storied past. 

Progressing through my fisheries career, I often wondered – “Where are the consultants from the Pacific islands?”. Among my colleagues, it was well known that getting into fisheries consulting was difficult, and if someone was lucky enough to do so, it was often on much lower terms. In a conversation with a highly qualified, experienced, and well-respected fisheries expert from the Pacific who previously held senior leadership roles in Pacific fisheries agencies and was grappling with the realities of consulting, he asked me, “Why aren’t we (Pacific Islanders) getting the consulting jobs in the Pacific?”.

I first met Francisco at a meeting in Rarotonga, the Cook Islands, in 2012 when I worked for a regional fisheries agency. He didn’t look like any consultants I had seen before—he wore shorts and an island shirt, expressed himself well and wasn’t shy to share his opinion, had a good rapport with my islander colleagues, and even took lunchtime swims in the ocean. Certainly not the mould of consultant that I was used to. Unlike other consultants, Francisco seemed quite comfortable socializing with us.

As I grew in my fisheries experience and status, it became easier to associate with consultants, and I could easily fit into their company. A lesson I learnt growing up in Fiji was that of humility, respect, and knowing where you came from. I never forgot that in my professional career, and while I could easily fit in with the consultants and senior fisheries folks, I was more comfortable with my islander colleagues, regardless of their status.Almost a decade working in fisheries and four years since leaving formal employment to go into consulting and entrepreneurship, I can count on one hand the number of fisheries consultants from the Pacific. I’ll always be grateful for the counsel Francisco has given me over the years and for being a positive role model as a consultant and human being. Standards matter, and Francisco is one of the few people who I have seen consistently keeping to his standards, personal and professional.

Interestingly, I get more international fisheries consulting opportunities working for agencies like the FAO and in other continents than I do in the Pacific. When I started my fisheries consulting career, I recall Francisco telling me at the time that I was the youngest fisheries consultant in the Pacific. It wasn’t lost on me to be a good role model to my fellow Pacific Islanders to show them that they, too, can have rewarding careers as consultants.

Glass ceilings are meant to be broken and, like Francisco, I believe that those of us who have been fortunate to pave the way have a duty to encourage and usher in the next generation of fisheries consultants in the Pacific. 

Again with High Seas transhipment on the WCPO  by Francisco Blaha

I know, I’m very repetitive on this topic… but it does really pisses me off.

I have been working with the team in charge of the IUU quantification report  2020 update (soon to be released) and as 5 years ago. Still the area we have most problems.

Notice how most of these transshipments take place on the borders of EEZs, rather than in the most isolated areas of the high seas, where it really will be impractical.

Notice how most of these transshipments take place on the borders of EEZs, rather than in the most isolated areas of the high seas, where it really will be impractical.

Yes, we have now a Transhipment Intercessional Working Group at the WCPFC, yet its pace seems to be defined on geological timelines more than biological ones.

The Technical and Compliance Committee of the WCPFC starts today and the Annual Report on Transhipment Reporting is one of the dozens of papers and reports presented.

I have written ad nauseam on the problem here *this link will take you to plenty of explanations

 The “rule” that " there shall be no transhipment on the high seas" is compromised by the loophole that allows unscrupulous DWFNs to assert that it is "impracticable" for certain vessels to comply. We've argued for years about how to define "impracticable", and we are still nowhere close to it.

 All reported high seas transhipments were conducted by fishing vessels registered to just 4 countries and one fishing entity that NZ has different levels of engagement, vessels of China, Chinese Taipei (Taiwan), Korea, and Vanuatu accounted for almost 90% of those transhipments, with Japan for the rest. As 22 of the 24 registered longline vessels flagged by Vanuatu are owned by individuals or companies in China and Chinese Taipei, it may be possible to attribute an even greater portion of high seas transhipments to those two operators

In what is perhaps the only area I’ve seen where the “one China policy” actually works CN and TW work in perfect unison in this one.

The “good” news is that it seems to be a slight decrease in the numbers of transhipments reported…. But considering that there are no observers out there…. I’m highly dubious of the accuracy of that number. It would very convenient to show a reduction after we (PEW and others have been hammering on this for years) shown that transshipments have increased over 160% from 544 operations in 2014 to 1472 in 2019. 

HS transhipments have become the norm not the exception for those DWFN, and that is the opposite that the WCPFC CMM indicates.

You can read the report if interested, but I point out only two things that my friend and colleague Tim Adams raised

"33% of the total catch of bigeye tuna taken by WCPFC longliners is transhipped on the high seas."

Looking back at the graphic posted above, it is interesting and totally hypocritical from the DWFN how most of these transhipments takes place close to the borders of EEZs, rather than in the most isolated areas of the high seas, where it really will be impractical.

This bullshit and totally hypocritical issue on HS transhipment is a low hanging fruit we should all put attention to and fully shame internationally the countries driving it!

 

Can drifting eFADs be a good source of fishery-independent data for stock assessments? by Francisco Blaha

I always been very open about the incredible amount of professional respect I have for my science collages at the Oceanic Fisheries Programme of SPC, they are regional centre for tuna fisheries research, fishery monitoring, stock assessment and data management.

Perhaps one of the few good things of me being COVID bound, is that I can assist under some of my many hats to the various WCPFC meetings I usually can’t… like the Scientific Committee. I’ve written many times about it, and I like to read the papers there presented (open access)… and the ones I always go for are the eFADs ones since is a topic I totally fascinated by, since it changed the fishery in my lifetime. What I mean with this? Simply that the way we were finding fish (and therefore setting up our trip routine and logistics) when I came to the region 30 years ago, and today are totally different worlds, different skills set, different understanding of the fishery. Full stop

The spatial distribution of dFAD purse seine sets, from all vessels in the WCPO, used for the CPUE analysis, from 2016–2018.&nbsp;

The spatial distribution of dFAD purse seine sets, from all vessels in the WCPO, used for the CPUE analysis, from 2016–2018. 

My interest in many of the science papers presented at the SC, have a deeper issue in me… back in the days I put a hell of a lot of my time and frustrations (being dyslexic) into becoming a scientist (MSc Fisheries Science – identification of 3rd reproductive stock of hake) while working as a fisherman... to then be so frustrated with the wimps of Argentina's fisheries institute that I went back to be a fisherman and came to the Pacific, and even if did then 2nd MSc once in NZ (designing a selective bait for longline), I also tendered with industry (and won) research services to NZ Fisheries, I keep reading tons of fisheries papers, I apply a scientific approach to my work in MCS, I review papers on my blog, and so on ... I actually have not worked as a fully focused  "scientist"  since I left Argentina.

Not that I truly frustrated about it, I have been incredibly fortunate with my work and life…I’m after all a self employed scientist in fisheries, but I would like to experience being part of a group of top scientists, in the search of good and useful questions and answers…

And this is one of those reports that I love reading (and would like even more to have been part of it!) 

While eFADs are a divisive issue and many see it as a threat, they are a reality and I always like to look at opportunities from things I cannot change and have many times in the past I thought that if we could harness the data stream of the estimate 40 to 60000 eFADs in our region, we could potentially have some sort of “live” stock assessment capability, and wrote about it in the past.

So my collages from SPC, spearheaded by Lauriane Escalle, who has been working on this for a while presented final results from the WCPFC SC Project 88 ‘Acoustic FAD analyses’ at the latest SC, that explored that idea!

So read the original (recommended), I just will quote the executive summary and the recommendation to the WCPFC

The project sought to identify whether the following objectives might ultimately be addressed using acoustic data from satellite buoys deployed on dFADs: 

  1. Whether acoustic buoys on drifting dFADs can provide a novel and efficient source of fishery-independent data for stock assessments (e.g., indices of abundance or additional information for purse seine CPUE standardisation); 

  2. Whether limiting sets to only those dFADs that have a large estimated biomass beneath them could reduce the proportion of small bigeye and yellowfin caught. 

 To evaluate the utility of the acoustic biomass estimates, initial analyses examined the patterns of biomass accumulation following deployment, and related biomass estimates just prior to setting to the resulting catch levels achieved. Following deployment, a clear increase was detected in the estimated biomass up to around 30–40 days post deployment, with a maximum around 60 days. Pattern of biomass accumulation before a fishing set showed an increase through time from 10 to 1 day before a set, with most buoys in the 3 days prior to a set having an estimated biomass between 25 and 60 t (up to 140 t). Examining the level of catch relative to the estimated biomass around the time of setting, larger catches generally corresponded to larger estimated biomasses over a period of 5-days before a fishing set. For very large catch events, the echosounder often underestimated the biomass or alternatively, the whole tuna school was not detected under the cone of the echosounder.

Towards an independent biomass index for stock assessment 

For this project objective, the focus was on skipjack tuna given the regional concerns over the reduction in the spatial extent and volume of the current pole and line abundance index for this stock. Two alternative methods were developed to classify echosounder transmissions as a relative index of tuna abundance or as presence/absence of skipjack tuna. The first method is a clustering analysis that classified echosounder transmissions in four different clusters based on biomass at depth, total biomass and biomass accumulation rate. One cluster (0) corresponded to no biomass detected. Two clusters (2 and 3), detecting biomass with differing depth profiles, corresponded to almost all transmissions a few days before a fishing set and therefore likely indicated the presence of tuna.

Finally, the last one (cluster 1), might be a mix of bycatch and tuna. Spatial distribution of each cluster was investigated and clusters 2 and 3 displayed a higher proportion in the main purse seine fishing area, while cluster 0, corresponding to transmissions with no biomass associated to the dFAD, had a low proportion. Higher proportions of cluster 0 were however found outside the main purse seine fishing areas, as expected. General additive models (GAMs) were used to investigate factors influencing total tuna catch. The limited number of skunk sets precluded the investigation of tuna presence/absence. Explanatory variables in the best model of tuna catch explained 25.9% of deviance. An increase in tuna catch was detected with increasing echosounder biomass, up to approximately 150 t, but for larger sets the biomass was underestimated by the echosounder. Other significant variables linked to higher tuna catch were time drifting, higher absolute values of biomass accumulation rates, full moon and higher biomass detected by the echosounder, latitude and longitude (higher tuna catch north of the equator and to the east of the WCPO). 

The second method is a Random Forest analysis that classified echosounder transmissions into presence/absence of skipjack tuna, based on a learning dataset of matched observer set/acoustic transmissions and Vessel Monitoring Systems/acoustic transmissions; and buoys with no associated biomass. Skipjack presence generally showed longer drift times (median of 79) compared to skipjack absence (median of 21). Skipjack presence was also associated with higher absolute biomass accumulation rate values. Finally, it was also found that skipjack presence was found in areas with higher vessel density compared to absences. Interestingly, the match in results between the random forest classification and the clustering analysis was very good, with more than 97% of transmissions in clusters 1, 2 and 3 classified as skipjack presence; and 92.7% of transmission from cluster 0 classified as absence. 

The classification of presence/absence of skipjack tuna was then used to explore an integrated standardization approach that combines CPUE time series from the purse seine fishery with presence/absence data from acoustic dFAD buoys drifting throughout the WCPO. Two models were compared, both included the WCPO-wide purse seine catch and effort data, while only one included the presence/absence data set. Both models predicted similar patterns, with notable differences in the magnitude of relative abundance; as well as lower predicted encounter probability for the combined data set, and higher predicted abundance during the dFAD closure period. The distribution of skipjack density was also notably different between the two models, mostly due to the information about skipjack encounters from the dFAD network. The positive catch rates showed similar patterns, but with a difference in magnitude. This analysis is a preliminary exploration of the methodology, with a relatively short time-series. These results are not intended to be indicative at this stage, but rather an opportunity to evaluate alternative approaches to obtain more reliable information on trends in skipjack abundance. 

  • While further analyses are required on a larger data set, this preliminary study suggests that acoustic biomass estimates from regional drifting FADs could assist in the development of an independent biomass estimate for skipjack tuna in the WCPO. 

Exploration of bigeye and yellowfin tuna proportion in fishing sets related to estimated biomass 

Bigeye and yellowfin tuna proportions derived from the catch composition were examined in relation to the levels of total biomass estimated by the echosounder buoys in the days preceding a set. The proportion of yellowfin tuna in the catch appeared relatively constant with increasing levels of estimated biomass, while the proportion of bigeye tuna appeared to increase with higher levels of biomass estimated by the echosounder buoy. GAMs were then used to investigate factors influencing bigeye and yellowfin catch proportions. Explanatory variables in the GAMs explained 23.8 and 27.0% of deviance of the bigeye and yellowfin tuna proportions. Biomass estimated by the echosounder was not significant for bigeye tuna models, but lower yellowfin tuna proportions were found for lower biomass estimated. Other variables influencing bigeye tuna proportions were drift time, low biomass accumulation rates just before the set (2-days), time relative to sunrise, longitude and the interaction between longitude and latitude. Other variables influencing yellowfin tuna proportions were moon phase and longitude. The limited number of sets considered here should be noted, as well as the fact that the echosounder is calibrated to detect skipjack tuna. The presence of a swim bladder for yellowfin and bigeye tuna, contrary to skipjack tuna, might therefore influence the acoustic signal. Accessing data from multi-frequency echosounder buoys that are now more frequently being deployed in the WCPO may allow these analyses to be refined. 

  • While the current analysis suggests little relationship between biomass estimates and the catch proportion of bigeye tuna, statistical models showed a slight decrease in yellowfin proportion for larger estimated biomass. Other factors, including drift time and trends prior to setting (rather than at setting) showing more potential. 

It should be noted that the acoustic data available for this analysis represent a small subset, available through partnership with three fishing companies, of the full dFAD network in the WCPO. The assistance of those companies is gratefully acknowledged. Therefore, results presented in this report should be viewed as preliminary and highlighting potential methods to be further explored with a more complete data set. Our intent is that WCPFC members and fishing companies see the utility of the analyses presented, in particular towards improving the monitoring of tropical tuna stocks and encourage or commit to making their acoustic dFAD data available for these endeavors.

We invite WCPFC-SC17 to: 

  • Note the results from Project 88 on acoustic data from echosounder buoys deployed on dFADs. 

  • Note that while the acoustically estimated biomass related to the proportion of bigeye in the catch, this proved non-significant within models, but statistical models showed a slight decrease in yellowfin proportion for larger estimated biomass and other identified variables may show some promise to pre-identify sets likely to lead to greater proportions of bigeye and yellowfin in the catch. 

  • Note the potential, over the longer-term, to use echosounder data as a source of fishery-independent data for stock assessments, either as an independent relative index of abundance or to provide additional information for purse seine CPUE standardization. 

  • Recommend the need for better identification of particular dFAD buoys (e.g., via the buoy identification numbers) by commercial vessel operators or via observer reports. 

  • Endorse the continued cooperative relationship with the fishing community to obtain commercially sensitive data for analysis for the purpose of scientific and other research, particularly with regard to dFADs, and the fishing strategies involved in their use

  • Highlight the need for additional data covering the whole WCPFC convention area, including that from now available multi-frequency echosounder buoys, and encourage other industry partners to become involved in the project.

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About languages and working in fisheries by Francisco Blaha

Taking a bit of a tangent on my usual fisheries only blog here… but here in New Zealand / Aotearoa, (the place that I have called home for the last 26 years) is Maori Language Week. Te reo Māori is has been an official language of Aotearoa since 1987, and Māori Language Week is celebrated annually in September, starting on a Monday and ending on the following Sunday.

One of my best working days in the last years…  I speak as much iKiribati as they spoke english… yet it didn’t matter we had fishing as the common way to see the world

One of my best working days in the last years… I speak as much iKiribati as they spoke english… yet it didn’t matter we had fishing as the common way to see the world

As an immigrant to NZ, I wish I knew more Maori; I know enough to guess what most places mean, to exchange cordialities and follow Marae protocols… but there is where I am at.

For years here in NZ, there has been a discussion on further promoting bilingualism. Many monolingual English speakers argue that what is the point since it is only spoken in NZ, that emphasis should be given to other languages that have more worldwide relevance (Chinese, Japanese and Spanish are the usual example).

I personally think they miss the real point of a language. I grow up with 3 languages spoken at home: Guaraní - my village and Grandma family, Spanish - my mum and German - my Austrian dad. They are VERY different languages in terms of the critical components of a language (phonology, morphology, syntax, semantics, and pragmatics)… but precisely that is why I’m so grateful that I was exposed to them growing up.

What you are really learning are different ways of thinking, not just of communicating… Each of those languages taught me different ways to see and think about the world. 

I remember as a kid wondering not only why the same thing had 3 different names? But why some were straight words, others made out of compounding concepts, and why did people see the same thing from such different angles…

I just grew up knowing that different people spoke different languages, for the same reason they look different… and you just talk to them in the way they speak to you… no big deal

For me each of my languages is like a brain programming code that makes me see the world in the same but different ways; my body language, gesticulation, and even my reflexes change accordingly to the language that is operating my brain at different times. 

Changing in between them is hard as an adult, but if mastered as a child, even if one of the languages is only used in only one area (like guarani or Maori) that doesn’t matter... besides the cultural components, learning how to switch from one to the other is the gain that you can replicate later on.

I work in English, Spanish and Portuguese… albeit only having had formal language education in Spanish. Yet I can get away a bit with Italian and French to an extent. I can get some basic pleasantries and conversation in Tongan, Samoan and Tuvaluan (that helped me with Maori) and a bit of Marshallese and iKiribati…. yet this is not because I’m “gifted” of anything like that… but mostly because I was exposed to different ways of thinking and I’m shameless! Also, as a friend told me: I rather have you been poor in my language than good in English!

For example Guarani compounds concepts in order of importance to make the name of places: let say Paraguay: Para (stripy brown), gua (place/move), i (water). Uruguay: Uru (bird/s) ,gua (place/move), i (water). 

My birth area is Ibera: I (water) bera (shiny/ebbing). Now interestingly, the place I call home is Waiheke which in Maori means: Wai (water) heke (trickling/ebbing), so yeah, I found home in the same meaning (therefore place) on the other side of the world.

German also compounds works to create new meaning made of the parts.

Guarani has no impersonals… everything happens to people in places… which is something I also found in most island languages. In English, you can pretty much take the people out and speak and write as if things just eventuated. 

And sometimes, even if not words are spoken in common… I have spent days fishing with people I had no language in common… yet we had the same experience fishing… gesticulation and similar way to think and see reality did the rest

My point is: learn as many languages you can… it just open you mind to different ways to see the world and share it with others… doesn’t matter if it is only 1 person you can’t talk on that language.

I know ain’t easy but a as they say in Maori: Kia kaha, kia maia, kia manawanui (be strong, be brave, be steadfast)

 

High Seas Tuna Transshipment: What it is and why it should be reformed by Francisco Blaha

Tuna is extremely valuable to Pacific Island countries. In recent years, the annual catch of tuna in the western and central Pacific Ocean has been approximately 2.6 million metric tonnes per year, worth almost US$5 billion. This catch represents over 50% of all the tuna landings in the world.  Surprisingly, the amount of tuna captured caught in the Pacific Island region is over ten times the amount of fish from all the other types of fishing in the region combined. Although tuna is captured by a variety of fishing techniques, the vast majority is taken by industrial-scale operations using either purse seine or longline gear.

Frozen Carrier and Longliner preparing to tranship catches in the High Seas outside the control of coastal states (anonymous source)

Frozen Carrier and Longliner preparing to tranship catches in the High Seas outside the control of coastal states (anonymous source)

Tuna transshipment 

Transshipment is a legitimate practice in the tuna fishing industry. In a typical transshipment operation, a refrigerated carrier vessel collects catch from multiple fishing boats and carries it back to port. This practice enables fishing vessels to continue fishing, which reduces fuel costs for fishing vessels and gets the catch to port quicker.

There are two main types of tuna transshipment in this region.  In one type of operation the transshipment occurs in or near a port, normally under the authorization, control, and inspection of the country where the port is located. In most Pacific Island countries the staff of the fisheries department monitor the volumes and species composition of the catch being transferred.  

The other form of transshipment in the region (which is far more problematic) is transshipment at sea, particularly in the high seas – which are ocean areas beyond the exclusive economic zone of any country.  In those areas the authorization and controls over the transshipment are the responsibility of the country of registration of the concerned carrier vessel and fishing vessel. This type of transshipment is particularly common for longline vessels.

Problems with tuna transshipment 

It is generally known that the volumes and composition of the catch being transferred in high seas transshipment is not as rigorously monitored as that for in-port transshipment.

High seas transshipment at sea is widely recognized as one of the main ways that illegally caught fish finds its way to market. Poorly monitored high seas transshipments offer opportunities to hide both illegal catches and prohibited fishing activities.  The Food and Agriculture Organization of the United Nations has stated that in the absence of effective monitoring and control, transshipping poses a serious risk to fisheries by allowing the catching and landing of fish to go unregulated and unreported. Within the western and central Pacific Ocean, it has been estimated by a recent study that US$142 million per year of tuna and tuna-like products are involved in illegal, at-sea transshipment.

The Western and Central Pacific Fisheries Commission

Tuna fishing in the central and western Pacific Ocean is regulated by both the countries in the region and the Western and Central Pacific Fisheries Commission (WCPFC). The Commission has a total of 42 member countries (including all independent Pacific Island countries), participating territories, and cooperating non-members.  The WCPFC seeks to ensure, through effective management, the long-term conservation and sustainable use of highly migratory fish stocks (i.e. tunas and billfish) in the western and central Pacific Ocean.
The Commission develops conservation and management measures that are binding on vessels that fish in the region. These are enforced in various ways, including by on-board observers, electronic vessel monitoring systems, at-sea boarding and inspection, and aerial surveillance. 

The WCPFC has a role in regulating transshipment. Recognizing that transshipment on the high seas could cause problems, the international agreement that established the WCPFC states: “In order to support efforts to ensure accurate reporting of catches, the members of the Commission shall encourage their fishing vessels, to the extent practicable, to conduct transshipment in port.”   Recognizing this point, the Commission made a rule in 2009 stipulating there shall be no transshipment on the high seas except where a member country has determined that it is impractical for a vessel – but the Commission did not define “impractical”, thereby creating a loophole.  

The current situation in the central and western Pacific

Contrary to the Commission’s intentions and rules, the number of high seas transshipments in the western and Central Pacific is actually increasing. Reports to the Commission indicate that such transshipments have increased from 544 operations in 2014 to 1,472 in 2019.

It appears that high seas transshipments are becoming the norm, rather than the exception. This situation is not conducive to the long-term conservation and sustainable use of tuna resources in the region – a stated aim of the Commission. 

The way ahead

Recognizing that poorly monitored high seas transshipments are a major factor in illegal tuna fishing in the region, there is a strong case for reforming such operations. There appear to be two possibilities for this:

  • Ban transshipment on the high seas and require any transshipment to take place in a port where it can be easily monitored; or

  • Greatly improve the monitoring of high seas transshipment.

 The first possibility would certainly result in improved accountability and transparency of the tuna catches – but it would place additional costs on fishing vessels, such as extra distances to travel and port charges.  This possibility would likely be opposed by the transshipping vessels and their countries of registration. 

The second possibility for reforming high seas transshipment would be to have the observers onboard the carrier vessels produce detailed reports and have those reports sent in a timely manner directly to the Commission for analysis. This possibility is likely to be less of a burden on vessel operators – and hopefully would meet less opposition than simply banning high seas transshipment and forcing a major change in way vessels operate.  

What can the governments of Pacific Island countries do to promote the reform of high seas tuna transshipment?  Through their voice in the Western and Central Pacific Fisheries Commission, they should point out that poorly monitored high seas transshipment could threaten the benefits they receive from their tuna resources – and insist on closing this loophole that gives opportunities for illegal fishing. 

hypocrisy, cherry-picking information, and singling out a particular form of food production by Francisco Blaha

As I have said many times before, any form of food production has an environmental impact, full stop. 

The only way to not have an impact is for all of humanity to die at once, everything else implies some form of compromise. This applies not only to all forms of food production but also to urban development and so on. 

My mate Jan before boarding for a sampling trip in a NZ coastal trawler

My mate Jan before boarding for a sampling trip in a NZ coastal trawler

Personally I’m very interested in minimising my carbon footprint, so I cycle as much as can, I don't use any form of engine when I go spearfishing, I produce food in my garden, and so on.

But then my bicycle is made of mined metals, many parts come for oil derivatives, as it is the fiberglass of my canoe, my speargun, my wetsuit, and so on. The paddles and the boom of my canoe are partly made from wood that was cut from living trees, where my house stands there was native forest less than 500 years ago… and I’m not even bringing in the flying I have done for my work on controlling fisheries. We all have impact… how much we do is a matter of personal choice and public policy.

Fisheries do have environmental impacts no doubt… yet when I read or hear this usual argument against trawling for example: 

“Imagine if the native forests were bulldozed in at least part of them, and in all wetlands, dunes and alpine areas… the public reaction would be swift and visceral”.

And I look outside my window… and that is what I see!! Houses and farmland! If you fly from over NZ other than National parks and areas that are useless for agriculture… that is what we have done!. We almost eliminated all native forests to plant and grow introduced plants and animals and made cities.  And where is the swift and visceral and public reaction? 

My colleague and friend Andy McKay among other many talents is an oracle of information, and many times I found each other confronted by the same rhetoric. He recently posted some data in regards to the impacts of the issues discussed above… 

In comparison, trawling (that no doubt impacts benthos, yet in different ways, under different types of bottoms and gear configurations and depths) is really limited using the usual parameters of comparison. Andy did some figures from publicly released data from Fisheries NZ for 2019 via a OIA

I’m all for minimising our environmental footprint, but not from a point of hypocrisy, cherry-picking information, and singling out a particular form of food production because is the one you understand the least and/or dislike the most.

Yes fishing does impact nature, yet even in the arguable most fished area of the country, the Hauraki gulf (by commercials and recreationals), at the doorstep of the of NZ biggest and richest city, at a beach that is accessible by public transport less than 30 km from downtown (and 200m down the road from my home). I see at least 10 to 20 times a year dolphins frolicking, kahawai boilups, all sorts of birds diving for baitfish, stingrays cruising the sands while I swim above… In the meantime, I challenge anyone to find tuataras, kiwis, or any NZ native species in the same numbers at any farm in the country… let alone one at 30 km from downtown Auckland.

We all have to do better, and fisheries have a lot to do! But if you take the bias out, some fisheries are doing comparatively better than many other food systems that do not get the level of criticism (and hate) that fisheries get.

If you buy a ecolabeled fish, is it guaranteed not IUU? Yeahh.... Nah mate by Francisco Blaha

My views on Ecolabels are quite open and I’ve written in extent about it… many issues… yet the main one is that they push the myth that a fishery is sustainable because it has certification when in reality is the opposite… it is sustainable because the action of concerned governments and RFMOs and therefore it can get an ecolabel (as long as they industry pay, of course

he is the one that defines legality of catch….he does not work for a ecolabel, nor he gets any benefits from it

he is the one that defines legality of catch….he does not work for a ecolabel, nor he gets any benefits from it

Let me use 2 examples of fisheries I know well

 Hoki in NZ. Was one of the first certified fisheries in the world, is the most analysed fishery in NZ, it has almost yearly stock assessments, etc… is not sustainable because of the ecolabel… The idea that a certified product may get a price premium is not a golden rule; furthermore, the logic of that assumption is flawed. In New Zealand, we have argued that the industry should not even expect a price premium for certification noting that: “No plausible case can be made for a premium for ‘sustainable seafood’. If anything, a well-managed fishery should also be a cheaper fishery to harvest as the fish should be more abundant and easier to catch!”

The other example is Tuna in the pacific… For example, I work a lot in the transshipment hub of Majuro, and I have been many times in situations where I see very similar purse seiners transhipping to the same carrier - both fishing vessels catch the same tuna species, using the same methods, under the same management system, from stocks evaluated by the same institutions, with the same regional controls over the activities, we apply the same port State Measures regime to both…  yet fish from vessel ‘A’ that does not pay for the ecolabel process, therefore as the narrative goes, is not sustainable? While fish from vessel ‘B’ that pays, is?

I wanted to understand well the system, so I went through the process to become an evaluator against the MSC standard and I did a pre-assessment for principle 3 (the regulatory principle)… I work on a pre-assessment of a huge tuna operator and walked away as it was fleet with various flags, I insisted that the assessments were to be based on individual flag state performance… yet even so there were vessels with the worst compliance index possible in the unit of certification (which I knew from my work with regional organizations)… but I could not use it because it wasn't offered to me by the client and I had no contact with the flag state… so I did not play that game.

Even if the origin of ecolabels is based on the assumption that fisheries administrators in particular those from developing countries) are not doing a good enough job… during my work with many fisheries administrations in the Pacific I have spent 2-3 days responding to the questions of the consultants that have come to ‘assess’ the fishery for certification… so in effect, they come for data to the people and institutions that the ‘consumer’ does not trust! That irony for me is mind-blowing. If you really want to help, why not just support the official institutions in the countries whose job and whole existence is to manage fisheries in a sustainable way?.

I have lived with the hypocrisy of that narrative for a while… but a paper that I just read takes it much further by suggesting that the certification has a role in ELIMINATING IUU fishing… and I don't buy that

I don’t get pay to criticise papers so I not gonna spend to much time on it (unless someone here wants to pay me for a detailed analysis)

Firstly I start with the fact that 8 of the 11 authors work for the ecolabel they are promoting and one of the reviewers was the boss of that ecolabel, they do declare that conflict of interest, which is great… but what does this mean on the value of unbiased information? Personally, I think the views presented by the authors of that work could be perhaps more a promotional article for the ecolabel, then a science paper.

Now I want to be very clear here… I not questioning the capacity and professionalism of any of the authors and reviewers, they are all way more qualified than me by far… I’m just a self employed dyslexic ex fisherman with a couple of degrees from unknown universities that works in the MCS realm, I’m writing this as the total nobody I am and my opinions are personal, they don't represent at all the ones of any my contractors.

You can go over the paper if you like, from the operational point of view there are three components to the IUU concept. They are not mutually exclusive, but also can occur independently. A simplified “definition” of each of the concepts follows.

Illegal fishing is conducted by vessels that fail to comply with the licensing conditions put upon their operations, types of gears, access restrictions and so on, by their own legislation, the legislation of the coastal states whose waters they fish in, and/or are parties to a regional fisheries management organisation (RFMO) but operate in violation of its rules, or operate in a country’s waters without permission.”

Unreported fishing is catch that is either not reported or is misreported to relevant national authorities or the RFMO. (As reporting accurately is a licensing condition, to a certain extent unreported fishing is also illegal fishing.)

Unregulated fishing is conducted in areas or for fish stocks where there are no applicable conservation or management measures and where such fishing activities are conducted in a manner inconsistent with state responsibilities for the conservation of living marine resources under international law. (Conservation and management measures are rules set by an RFMO that govern fishing in its jurisdiction.) This term also covers vessels without nationality or flying the flag of states that are not parties of relevant fisheries organisations, and which therefore consider themselves not bound by their rules.

 So, the first two are related to each other, and unregulated fishing is much rarer these days. There are only a few areas of the world that are not under the management of an RFMO, one of them being the South Atlantic off the coast of Argentina beyond the country’s exclusive economic zone.

So if the fishery is unregulated or performed by vessels without nationality, then chances are that the P1 and P2 would of the MSC would not have data to start… furthermore the operators in those fisheries would not even thinking to pay for a certification… so to suggest that the ecolabel has a role there is rather flimsy.

In terms of Illegal and unreported, the key issue here is that they happen during the fishing event, they happen at sea every time the vessel operates… how does a certification that is reviewed every 3 years or more can check every fishing event. Let me use the Pacific tuna case, where different state actors are involved. Some responses rely on the national legal frameworks, which may need improvement, while others rely on regional organisations such as FFA, and international frameworks, as is the case of RFMOs.

For us in the WCPO, we have robust systems based on the unique coastal-state cooperation (via the Forum Fisheries Agency and the Pacific Community) that marks our region. We use common tools, like the shared registers; the vessel monitoring system; shared surveillance operations with the support of the USA, France, Australia, and New Zealand defense assets; and so on.

These tools have been in use in our region for a couple of decades now. Therefore, we have achieved a solid level of control over the common understanding of what illegal fishing is, and, as said, unregulated fishing has not been a problem in the region for many years.

The FFA 2016 IUU fishing quantification study (currently being updated by way of IUU mitigation progress report) showed that the key area of problems for us is unreported fishing. This can happen in different individual or combined ways, including non-reporting, misreporting (saying you caught A, when in reality you caught B) and under-reporting (declaring you got 50 when in reality you caught 70).

So, this is the area we are focusing on in the WCPO, through a series of initiatives and innovations such as strengthening our port state measures, monitoring transhipments with remotely read electronic hook scales, catch documentation schemes, and electronic reporting and monitoring, just to name a few. All of this is under the jurisdiction of the national agencies (those that by principle consumers don’t trust) 

In the region, the legality of the catches is verified by the PSM systems prior authorising unloading (we check identity, licensing and maneuvering) and is the same for vessels that pay for the certification or don’t. No one from the ecolabels has any role in this… if the officers fail the fish goes straight to the consumer

As per unreported… we have monitors that crosscheck the volumes with scales against the logsheets and then as part of the catch certification process… and again is the same for vessels that pay for the certification or don’t. No one from the ecolabels has any role in this… if the officers fail the fish goes straight to the consumer

The one I give them is that they have a “chain of custody” (CoC) which could stop the laundering of fish (mixing reported fish with unreported fish) in the factories. CoC is required to maintain certification in regard to the integrity of the product bearing the logo of the ecolabel, particularly in the case of purse-seine caught tuna certification, as vessels fish in the same trip both certifiable products (FAD-free) and noncertifiable products (FAD-associated).

The issue here is that the CoC only applies to products in the wells that have fish caught without FADs in vessels that are part of the unit of certification (i.e. have paid for the certification). Is not designed to assure “non IUU fish” but to make sure the fish does not mix with fish from FAD wells or the fish from other vessels fishing the same stocks, with the same fishing gear, during the same seasons are not clients of the ecolabel. 

 Anyway… my main point is that the fight against IUU happens at sea and in port, normally by people who do not get ANY benefit from ecolabeled fish…

Let me use a parable to explain: in most countries of the world, to drive a car, you need to go through the process of getting a driver’s license run by an official institution in that country. Once you have that license, you can legally get on the road and drive a car.  How good that system depends on a varied number of reasons such as human resources, cultural values, the rule of law, transparency, etc. Obviously, there would be countries that are better than others at this. So let’s say that a country has a bad rate of accidents by licensed drivers, in comparison with other countries. So what you do? 

For me, the most logical, democratic and cost-effective solution is to set up a programme to strengthen the institution that is legally authorised to do that job in the country, standardise the licensing systems, exams and controls under auditable standards and reward conformance in some way.

What I would not do is to create a private parallel system on top of the already existing national system. Hence I, as a driver need to get through the hurdles of the official systems, and then contract a foreign private assessor and go over a whole set of new exams and tests (at my cost) to prove to people in rich countries that I know how to drive in a way they consider ‘safe’. And that is what in my opinion private certifications do: they create a parallel system instead of supporting the organisations that are supposed to do the job.

In my opinion, one of the biggest hurdles that we face in legality and sustainability is that while we want it, we allow the underfunding of official institutions and pay fisheries officers and fishers salaries that are way below mediocrity, but we expect excellence from all of them. They are the ones that have a role in IUU fishing.

FAO tell us that over 70% of the seafood consumed in developed countries comes from developing countries. Partly this is because the fisheries in developed countries have either collapsed or can’t keep up with local demand. Yet all of the ecolabels, private certifications, retailers, and most of the consumers that allegedly require them are based in developed countries. This has led me to say that I see the whole private certification scene as hypocrisy in the best-case scenario, or neo-colonialism in the worst-case scenario.

Fijian flagged vessel on a US custom detention order for forced labour, by Francisco Blaha

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I wrote in the past about Vanuatuan flagged vessels on a US custom detention order for forced labour, this time is Fijian flagged one.

This is quite unfortunate (particularly taking into consideration the COVID crisis there), and a reminder of how much work is ahead of us to make good of the great step that was the inclusion of decent labor conditions under the FFA’s Harmonised Terms and Conditions of Licensing (HMTCs)

The use of trade-restrictive measures (TREMs), as “trade sanctions“ enacted by a market-state have aimed to the IUU side of fisheries, either by closing the market to a country (as in the case of the EU with the red cards) or to an individual vessel on IUU blacklist, the USA is increasingly using them for labour issues.

While these “name and shame” trade measures do hurt, as they bring shame to a country and are normally based on a few bad operators, at the expense of the excellent ones (like Solender and Sequest whom I worked with and are already hurting from the COVID crisis) and have a very progressive and efficient fisheries administration whom I’m proud of having worked with for many years.

Yet the truth is that they are Fiji flagged, so hopefully, this type of announcement can catalyze much-needed strengthening.

While the vessel at the center of this announcement is Chinese-owned and operated, the factual reality is that what happens on those vessels competes to the flag state authority… the present capacities of Fiji or their development status, can’t be an excuse when it comes to flag state responsibility.

There are reports that the company who at this point are denying the allegations and want to respond to US BPC… yet the bad publicity via the news this is bringing even if the company is “innocent” is quite bad.

Effective August 4, 2021, U.S. Customs and Border Protection personnel at all U.S. ports of entry will detain tuna and other seafood harvested by the Hangton No 112, a Fijian flagged and owned longliner operated by a Chinese national. The order came after the agency determined there was credible evidence that the vessel’s crew was operating under forced labor conditions

While the vessels of this company are China-owned and operated, the factual reality is that what happens on those vessels competes to the flag state authority… the capacities of Fiji or their development status, are no excuse when it comes to flag state responsibility.

As I was told in the navy and the fishing boats many times… if you cannot live up to a responsibility don’t take it!

Unfortunately, vessels still are in the FFA list of good standing, even if their listing by the US put serious doubts on the adherence of these vessels to the HMTCs, this event so new, I guess that listing is to be changed at the request of the flag state.

CBP issued a Withhold Release Order against the longliner fishing vessel based on information that reasonably indicates the use of forced labor in the vessel’s fishing operations. CBP identified at least three of the International Labour Organization’s 11 indicators of forced labor during its investigation: withholding of wages, debt bondage, and retention of identity documents.

“Foreign fishing vessels like the Hangton No. 112 continue to lure vulnerable migrant workers into forced labor situations so that they can sell seafood below market value, which threatens the livelihoods of American fishermen,” said CBP Acting Commissioner Troy Miller. “CBP will continue to stand up against these vessels’ abusive labor practices by preventing the introduction of their unethically-harvested seafood into the U.S. market.”

The International Labour Organization estimates that 25 million workers suffer under conditions of forced labor worldwide. The distant water fishing industry is at high risk of forced labor as foreign companies often coerce vulnerable migrant workers to perform hazardous labor for little or no pay aboard fishing vessels that may spend months at sea without making port calls.

19 U.S.C. 1307 prohibits the importation of merchandise produced, wholly or in part, by convict labor, forced labor, and/or indentured labor, including forced or indentured child labor. CBP detains shipments of goods suspected of being imported in violation of this statute. Importers of detained shipments have the opportunity to export their shipments or demonstrate that the merchandise was not produced with forced labor.

CBP has issued Withhold Release Orders on other fishing vessels, including the Lien Yi Hsing No. 12, the Da Wang, and the Yu Long No. 2. In May 2021, CBP issued a Withhold Release Order on seafood caught by a fishing fleet owned by the Dalian Ocean Fishing Co. Ltd. All Withhold Release Orders are publicly available and listed by the country on CBP.gov.

Pathways to sustaining tuna-dependent Pacific Island economies during climate change by Francisco Blaha

Once in a while, a fundamental paper get published… and you know that is fundamental not just because of what they say but who is saying it.

This paper “Pathways to sustaining tuna-dependent Pacific Island economies during climate change” has in its authorship pretty much everyone I worked with and respect in the region (i.e. Johann D. Bell, Timothy Adams, Sangaalofa Clark, John Hampton, Quentin, Steven R. Hare, Simon Nicol, Yoshitaka Ota, Graham Pilling, Chis Reid, Neville Smith and Peter Williams

Redistribution of biomass and purse-seine catch from the combined EEZs of the tuna-dependent Pacific SIDS

Redistribution of biomass and purse-seine catch from the combined EEZs of the tuna-dependent Pacific SIDS

I have written in the past about the impacts of climate change on tuna fisheries, yet this paper is putting it in very unequivocal ways… and like anything else with climate change… is not good.

I quote here the abstract, part of text and discussion… but read the original.

Climate-driven redistribution of tuna threatens to disrupt the economies of Pacific Small Island Developing States (SIDS) and sustainable management of the world’s largest tuna fishery. Here we show that by 2050, under a high greenhouse gas emissions scenario (RCP 8.5), the total biomass of three tuna species in the waters of ten Pacific SIDS could decline by an average of 13% (range = −5% to −20%) due to a greater proportion of fish occurring in the high seas. The potential implications for Pacific Island economies in 2050 include an average decline in purse-seine catch of 20% (range = −10% to −30%), an average annual loss in regional tuna-fishing access fees of US$90 million (range = −US$40 million to –US$140 million) and reductions in government revenue of up to 13% (range = −8% to −17%) for individual Pacific SIDS. Redistribution of tuna under a lower-emissions scenario (RCP 4.5) is projected to reduce the purse-seine catch from the waters of Pacific SIDS by an average of only 3% (range = −12% to +9%), indicating that even greater reductions in greenhouse gas emissions, in line with the Paris Agreement, would provide a pathway to sustainability for tuna-dependent Pacific Island economies. An additional pathway involves Pacific SIDS negotiating within the regional fisheries management organization to maintain the present-day benefits they receive from tuna, regardless of the effects of climate change on the distribution of the fish.

The projected climate-driven redistribution of tuna biomass and purse-seine catches also has potential implications for sustainable management of the world’s largest tuna fishery. In a scenario where a lower proportion of tuna resources is under the jurisdiction of the PNA VDS, the sustainability of tuna catches could be at greater risk because the monitoring, control and surveillance required to combat illegal, unreported and unregulated fishing, and impose penalties for non-compliance, are more difficult in high-seas areas. This is because responsibility for compliance with fishing regulations on the high seas rests with the states that ‘flag’ fishing vessels (often resulting in self-regulation), whereas compliance within EEZs is under the purview of coastal states. With continued GHG emissions, the onus will be on WCPFC to implement tighter controls on fishing for tropical tuna species by all vessels operating in high-seas areas of the WCPO.

Discussion

This analysis demonstrates that sustainable development of tuna-dependent economies in the Pacific Island region is likely to be at substantial risk from continued high GHG emissions. Although considerable uncertainty remains, our modelling provides sufficient information to indicate that it is not a question of ‘if ’ tuna biomass will shift from the combined EEZs of the ten Pacific SIDS but ‘when, how quickly and to what extent’. It is important that this risk be recognized by the United Nations Framework Convention on Climate Change and included in the rationale for limiting global warming in line with the Paris Agreement.

The process to identify a mechanism to eliminate or substantially reduce this risk for tuna-dependent Pacific SIDS, based on the principles of cooperation and long-term sustainability through the WCPF Convention, should also begin immediately. Ultimately, the necessary international negotiations will be facilitated by reducing uncertainty in the timing and extent of tuna redistribution and the associated impacts on catch, access fees and government revenue.

Reducing the remaining uncertainty in redistribution of tuna biomass will depend on improving tuna modelling to increase the spatial resolution (for example, up to 0.5°), incorporating ocean forcings for all emissions scenarios considered.

Model Intercomparison Project Phase 6 (CMIP6), integrating additional and enhanced biogeochemical models into the simulation ensemble for the impacts of ocean warming and acidification on the food webs that support tuna, and assessing the effects of the Interdecadal Pacific Oscillation on the onset of accelerated ocean warming. Preliminary genetic research, showing that some tropical tuna species are composed of multiple, self-replenishing populations (‘stocks’)41–44, indicates that efforts to reduce uncertainty in redistribution of tuna biomass will also be strengthened by identifying the stock structure of each species. This would enable the response of each stock to climate change to be modelled separately and then aggregated to produce a more accurate understanding of tuna redistribution from EEZs to high-seas areas.

Using Lessons Learned to Strengthen Implementation of the UN FAO PSMA by Francisco Blaha

I get often asked what is the main problem faced by fisheries… like of it was only one simple thing you can point out! I’ve written in extent about some of them: subsidies, climate change, geopolitics, poor flag state performance, CDS, labour issues, pathetic budgets for fisheries administrations, and so on… but the one that worries increasingly is that as a sector we fail to engage with new people and more importantly diversity among the people working in fisheries science, policy and MCS .

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I think I have been one of the youngest consultants in fisheries in the region for over 20 years now … and that reflects very badly on us as a sector… if you were to try to design the stereotype of a fisherman, you wouldn't fall far from a big bearded man with sun and salt dry skin that is weary of paper pushers. So you’ll come not far from me… yet if my gender, age, and background represent the only good way to do things, then how come we are facing the problems we have? How hypocritical would it be of me to not try to bring in, listen to new voices, new perspectives, new ways to do things. 

So as much as I can I take on supporting students working on fisheries issues (and I do this on a pro bono basis) this year I’m involved with 3 different masters and PhD students.

One that was just published, and I got quite involved as she was working on PSM in two countries I work with RMI for the last 3 years and Thailand (via FAO and Ocean Mind) is Chloé Gouache’s one.

Her thesis “Proposed Guidelines on Pre-Arrival Risk Assessments of Foreign Vessels: Using Lessons Learned to Strengthen Implementation of the UN FAO Agreement on Port State Measures” was also supported by the following colleagues and friends: Mark Young (whom I worked with at FFA, PEW and now IMCSn), Dawn Borg-Costanzi (whom I worked with at FAO and now PEW), Natalie Tellwright (whom I work with at Ocean Mind) and Sara McDonald (whom I worked with at Monterrey Aquarium)

PSMA is not prescriptive about the ways a risk assessment on arriving vessels should take place or how to effectively perform this risk analysis. The objective of her work was to attempt to fill this information gap and compile lessons learned from countries that have implemented a port inspection regime of which risk assessment is an integral part: Thailand and The Republic of the Marshall Islands. These lessons helped generate proposed guidelines for the implementation of the pre-arrival risk assessment of foreign vessels in the context of the PSMA. The goal for these guidelines is that they will help those countries that have become Party to the Agreement or are looking into ratifying the Agreement in the future and be used as a resource by port authorities.

It would be a substantial piece of work for MCS practitioners, let alone for someone coming from the outside… but maybe that fresh view from the outside coupled to listening and respecting those on the inside is why she nails it!

Chloé, I do hope you stay working in fisheries… we need more people like you!

I recommend you read it if you are interested in PSM implementation, in the meantime, I quote below her work closing remarks:

I- Importance of Regional Context

The regional context is key for the implementation of good Port State Measures. The Marshall Islands’ membership in the FFA, which made fighting IUU fishing a priority, allows the country to benefit from resources it uses every day to perform risk analysis on foreign vessels. But for the tools created and shared by the FFA to its members, implementing PSMs would be even more challenging the country’s port authorities.

In addition, experience from Thailand and the Marshall Islands shows the importance of having a consistent process including for the request of port entry. Both countries agree that a measure of success is how better prepared vessel agents are when asking port entry over time. A consistent process changes expectations and results in efficiency over time. This links back to the need for consistency in the implementation of Port State Measures among states and the requirement of documentation to prove legality before port entry. Further, in a regional context, the issue of a potential transfer effect from implementing more stringent measures than neighboring countries is reduced. With a consistent regional framework and implementation of PSM, it would be more challenging if not impossible for vessels to land their catch in another port to escape controls.

Regional frameworks and RFMOs in particular, also play a key role in cooperation. Those that maintain registries and tracking of vessels fishing in their region accessible to their members and non-member cooperating countries facilitate the risk analysis of port States on these vessels. It seems that for some RFMOs, states are keener to report and update the available tools than they do for the FAO tools.

In addition, RFMOs and other regional groups such as the FFA forbid certain behavior.

Among these measures, they both prohibit transshipment at sea, which allows for more oversight and control. Transshipments must occur in port, which contributed to the heavy vessel traffic the Marshall Islands receive. Indeed, tuna purse seiners use Majuro for unloading and transshipping tuna catches because the RFMOs in the Western Pacific and Indian Ocean prohibit at-sea transshipping.  At-sea transshipment is a particular risk because of the lack of oversight on fishing vessels that are not returning to port. Mandating that transshipments should occur in port, allows for implementation of risk assessment process such as those described in this report, as well as inspections of these fishing vessels, and control over the transshipment operations. By prohibiting certain risky behavior in their region and promoting robust MCS measures, RFMOs lower the risk of IUU fishing behavior.

II- Decision to Deny Port Entry

The PSMA empowers the port State to deny entry to vessels for which the risk of it having engaged in IUU fishing is too high, but if the port State has the capabilities and resources, the best scenario would be to permit entry into Port and conduct a full investigation, and, if warranted, impose sanctions. This would contribute to solving the problem rather than denying entry which would push the problem to another port State, which might not have the capacity to perform a full risk analysis or take appropriate enforcement action.

In the Marshall Islands for example, port authorities are empowered to grant port entry and eventually delay port use pending the clearance of all risks. As an example, in 2020, the Marshall Islands charged a Korean fishing vessel for fishing in its waters without a valid license.

For this to be possible, there is a need for national legislation that forms the basis to prosecute such behavior when the illegal activity occurred in waters beyond national jurisdiction. The Lacey Act in the United States for example creates a basis for prosecution of international trafficking of wildlife. This includes, among other behavior, illegally taken commercial fish. The Lacey Act requires accurate labeling of all wildlife shipments entering the country and criminalizes most types of trafficking of wildlife, including fish that have been “taken, possessed, transported, or sold in violation” national or foreign law. Violators under the Lacey Act can face a range of penalty including civil fines, forfeiture of wildlife and equipment, and criminal penalties, including fines and incarceration.

But these decisions also have a cost, the cost of unloading the catch, and keeping it in bonds to conserve it pending investigation, or the cost of the investigation itself and the possible court proceedings. In practice, some decisions are based on economics and capacity. In Thailand, investigations can be so costly that even if the recommendation would be to allow vessels to enter port to investigate, the costs are potentially so high that the decision can be made to refuse port entry rather than using government funds.

It seems that there is a lack of incentive to take enforcement action. When a vessel presents a high risk of having engaged in IUU fishing activities, there is no incentive for a port State to spend resources and funds on a thorough investigation, conserve the catch in the meantime and prosecute that vessel. Therefore, the solution to deny port entry might be the one that makes the most sense financially. This must be taken into consideration in the cost of becoming party to the PSMA. There are financial consequences for a country to implement more stringent controls. An option could be granting port entry and imposing higher fines that would cover the cost of the investigation, thereby incentivizing port States to take enforcement actions.

Complying with new laws and regulations can increase production costs for port States. As a result, international suppliers must also agree to eventually increase their price. There is increased demand from seafood companies across the globe for expanding seafood traceability, including through the ratification and implementation of the PSMA, which should put further pressure on governments to become Parties to the Agreement.  This, however, also includes supporting the change and potential associated costs.

Another issue of denying port entry is the potential transfer effect of vessels going to a port that enforces fewer controls, which allows catch from IUU fishing into the market. However, increased concern from seafood buyers and seafood industry for port state controls would offset the interest to go somewhere else.

 III- Container Vessels

The Port State Measures Agreement includes an exception in its scope for container vessels. As such, the Agreement does not apply to:

“container vessels that are not carrying fish or, if carrying fish, only fish that have been previously landed, provided that there are no clear grounds for suspecting that such vessels have engaged in fishing related activities in support of IUU fishing.”

Likewise, the IOTC PSM Resolution’s scope of application is to all vessels not entitled to fly the port State’s flag that request entry to their designated ports, with the exception of:

“Container vessels that are not carrying fish or only fish that has been previously landed”.

Therefore, containers vessels are currently out of the scope of the PSMA, as long as fish they transport have been previously landed. Movements of containers have increased over time because of many factors including aging carrier fleets, or improved efficiency. As a result, containers are increasingly used to move fisheries products to market.136 This exception in the Agreement has created a potential loophole and provides for opportunities for IUU fish to land and make its way to market through container vessels, thereby circumventing some reporting obligations.

The lack of definition of the concept of “landing” in the PSMA, also leaves room for interpretation and inconsistencies between port States. A 2016 FAO document for the Implementation of Port State Measures provided a proposed definition of landing as “to begin to offload fish or to offload fish from any vessel in port or at a dock, berth, beach seawall or ramp, but does not include transshipment”.

Under this definition, some catch in container vessels might not have been properly landed and should be covered by inspection.

Often times, catch would be directly unloaded on the container vessel and no documentation would prove that it was properly landed. In addition, container vessels do not use fishing ports but cargo ports that do not enforce Port State Measures because of that loophole. Such use of containers can therefore circumvent PSMs when there is an assumption that the fish has been landed before.

A 2020 UN FAO study on transshipment also highlighted a practice called “transshipment in transit” where fish is directly transferred to containers without any monitoring or control, blurring the line between landing and transshipment and “in fact not defining it as either the one or the other”. During these operations, port authorities have no insight on whether the catch has been previously landed and no effective Port State Measures can be applied.

In addition, new issues are emerging with the use of containers. Some carrier vessels are now carrying containers themselves to reduce the landing costs. The fish is stored directly in containers on the carrier before being transported to port and transferred to a large container vessel. These are charging lower transport rates. The UN FAO transshipment study highlighted in 2020 that unless clear port procedures are developed, there is a risk that carrier vessels will “switch to operating as merchant vessels that transfer containers to another merchant vessel in a free zone, instead of as vessels engages in “fishing related activities” for the purpose of the PSMA”.

This is also an important aspect of defining international transshipment guidelines and will have to be considered in the near future in implementing the PSMA. It seems that offloading fish to containers should be considered as landing or transshipment and be within the scope of the PSMA.

 Mapping interests in the tuna fisheries of the western and Central Pacific ocean by Francisco Blaha

One thing I really like about fisheries is that it attracts a diversity of people, many against it of course, some (like me) that work on it, either as regulators, industry, service and tech providers, capacity and institutional support providers… and then the academics 

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And here you also have two main groups: have the scientists that work providing services (stock, climate modeling, primary productivity, bio-economists, social scientist, etc) normally as part of different types of institutions … so to an extent, we are all stakeholders. But then you have the academics that work for universities and study aspects of fisheries.

These guys are an interesting lot… because they have (to an extent) or should have a higher and perhaps more detached and neutral opportunity to “see” things those of us more inserted may not see. In another life, I would like to be a more traditional academic and be paid to study things like many of these guys do…

Said so there is a full range in this group too… from total idiots that obviously have no clue of what they are talking about and don't understand how fishing works, or fully biased and bring a position with them, and then those few that do really engage study, collaborate and contribute with unique knowledge that explains things and/or add vison to the general understanding. 

I really like when I read one of these papers… and here is one: Mapping interests in the tuna fisheries of the western and Central Pacific ocean. By Kamal Azmi and Quentin Hanich, from the Australian National Centre for Ocean Resources and Security, University of Wollongong, Australia

I’m not surprise is a good paper because I know and collaborated in the past with both authors and have lots of respect for their work, and from what I have seen, they are genuinely nice people, and that really counts in my book. Furthermore, I kind of envy them for their jobs… to be paid to think and anise stuff, drawn conclusions and so on… I guess I do the same at a lower level with my work… but we all know the grass is always greener in the field next door!

In any case, great insight if you are tuna in the WCPFC nerd… which let’s agree may not be a huge group… but chances are that if reading this blog… you definitively are one! So the different interest-driven dynamics of the players in the WCPO fishery is something you’ll be keen to further undersytand!

As usual, read the original (great graphs), in the meantime, I just quote the abstract, a bit of the discussion, and the conclusions!

Abstract
Fisheries for highly migratory fish stocks are complex, featuring multiple species targeted by different gear types across several national jurisdictions and high seas areas. They require effective cooperation to manage sustainably, typically through a regional fisheries management organisation (RFMO). However, diverse interests in different species and gear types among participating states and fishing entities, many of which are developing, mean that cooperation can be difficult to achieve, with severe consequences for fish stocks, the economies of states with an interest in those stocks, and the livelihoods of communities that depend on them.

The Western and Central Pacific Fisheries Commission (WCPFC) manages some of the world’s largest tuna fisheries and exemplifies these challenges. We argue that a prerequisite for effective cooperation is an understanding of the interests of each participant in each species and gear type to ensure that conservation and management measures take into account the differential impacts on each one, including whether measures place a disproportionate burden on developing states. This paper uses catch value data for four key tuna species of the WCPFC convention area to illustrate the diversity of interests of participants in these fisheries, with a view to enhancing delegations’ understanding of those interests and to inform more effective cooperation.

Discussion (last part)
There are many conclusions that can be drawn from the foregoing analysis. We identify three examples of concern in the WCPFC in which new measures will have differential impacts on various interests. First, the determination of whether a disproportionate burden is likely to be placed on developing CCMs by a new measure needs to take account of any new measure’s impact on each species and gear type. For example, tropical SIDS′ strong interests in purse seine fisheries are likely to be affected by measures to restrict purse seine fishing in order to protect bigeye stocks. This has been a longstanding point of tension in the WCPFC. Second, compared to the tropical purse seine fishery, power in the tropical longline fishery is tilted more toward large, well-resourced distant water fleets, which tend to operate more commonly on the high seas.

High seas limits must recognise the particular circumstances of SIDS that rely on catches of the same stocks within their waters. This also requires giving practical meaning to the compatibility requirements of UNFSA and the WCPFC’s founding Convention. Third, the ongoing delays in restricting longline catches of albacore in order to improve the profitability of the southern longline fishery, are likely to favour distant water fishing states with substantial resources compared to SIDS. But in the absence of restrictions for the high seas, SIDS struggle to agree on restrictions for their EEZs.

 Conclusion 
In 2017, the WCPFC achieved a breakthrough when the Commission agreed that it would begin a process to establish hard limits for the high seas purse seine fisheries, and a framework to allocate these limits (WCPFC, 2018, paragraph 29), thereby implicitly recognising the sovereign rights of coastal States over fisheries within their EEZs and their own domestic limits for purse seine. The Commission would also establish hard limits and allocation frameworks for bigeye catches by longline vessels, but apply these across high seas and EEZs (WCPFC, 2018, paragraph 39). This process began in 2018, but has now been stalled by the COVID- 19 outbreak as travel bans impact on decision making. In the meantime, the WCPFC tropical tuna CMM, which was to expire in February 2021, has been extended for a further year through the adoption of CMM 2020- 01.

This paper has sought to identify the key interests among flag states and coastal states, both developed and developing, in the key species and gear types that are subject to the CMMs of the WCPFC. It did so by building on similar previous analyses of the same fisheries with more recent data and further refining the analytical framework. Steps taken in recent years to strengthen measures to conserve and manage these species have been positive but incremental.

The entrenchment of coalitions within the WCPFC, such as the FFA and the PNA, have demonstrated that gains can be made by groups of like-minded participants. The incorporation of some of their positions in key WCPFC measures – most notably various iterations of the tropical tuna measure (WCPFC, 2018) – has demonstrated that such coalitions can stimulate cooperation among a broader, more diverse group of interested participants. This case study offers both a rich line of inquiry for the study of approaches such as cooperative games (Munro, 2008) and an opportunity for RFMO negotiators to progress the sustainable management of the stocks under their stewardship. As for the WCPFC, once negotiations resume, it will be critical that the WCPFC understands and considers the interests identified in this paper.

A clear understanding of the interests of each CCM in each species and each gear type, and whether as a flag State or a coastal State, will help to ensure that new CMMs take into account the differential impacts on each participant, including whether they will place a disproportionate burden on developing States. In doing so, RFMOs will be more likely to achieve an outcome, and that outcome is more likely to be an enduring and effective one that is also more likely to move toward SDG14.

Flag state interests in distant water fishing: catch value, all gear types, all species 2016–2018. This chart plots each WCPFC flag state against two dimensions – _the vertical axis indicates the state’s GDP per capita as a measure of the level of d…

Flag state interests in distant water fishing: catch value, all gear types, all species 2016–2018. This chart plots each WCPFC flag state against two dimensions – _the vertical axis indicates the state’s GDP per capita as a measure of the level of development, while the horizontal axis indicates the proportion of the value of catches by the state’s national fleets that is caught beyond the waters of the flag state. The latter is inferred from FFA value of catch data for each national fleet less the value of catches by vessels flying the flag of the coastal state in which the fish are caught. A third dimension – _the value of the total catch by each national fleet in both national waters and beyond national waters – _is illustrated by the size of the bubble for each coastal state. Datapoints represented red bubbles are FFA members, and blue bubbles represent non-FFA members.

 

Online week: Global Fisheries Enforcement Workshop and Social Responsibility in fisheries webinar by Francisco Blaha

in this new world, we swapped o week meetings for a couple of days of online catch-ups, yet I’m sure there is a very similar amount of work by the organizers behind it!

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I have been very lucky to be invited to speaker/panelist at the last 2 iMCSn Global Fisheries Enforcement Workshops (Auckland 2016 and Bangkok 2018) , so I jumpd at the opportunity to participate in the online version of this year’s one, crafted by my brother Mark Young that deserves all kudos possibles for organizing a very successful event on an online platform.

I was part of a panel on “The Emerging Complexities of Containers Related to Transshipment’, where I articulated my take pm this topic along the lines of what I wrote here (the slides of the short presentation are below). I really enjoyed it as I was discussing the issue with some very amazing panelists Tony Long, Duncan Copeland, Peter Flewwelling and Kristin von Kistowski

Needless to say, I still have to pinch myself sometimes when I'm in those situations to see if they are real! A mongrel like me to be among MCS royalty! and I got quite a lot of good feedback… my favorite: Great presentation Francisco... practical, easy to follow, and laced with an uncommon dose of common sense!

Then the next day I also talked about the crane scales (and the selection process), we are using in Majuro now

then the next day I swap interests and was part of a panel for the webinar “Building Resilient Supply Chains: The Case for Comprehensive Social Responsibility Programs” I wrote about here. The video, if anyone is interested, is here

I’m incredibly humbled and thankful to the organisers for their invitation and trust... I don't have an organization behind me, not a line to follow or a product to sell… I'm invited just by being me, and that is a total privilege that I don’t take lightly

My presentation is below


Free Webinar: The Case for Comprehensive Social Responsibility by Francisco Blaha

The good people of RISE/FishWise (whom I have been working with for a few years) now and Seafoodsource.com are putting a free webinar “Building Resilient Supply Chains: The Case for Comprehensive Social Responsibility Programs” on July 15.

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I’ll be sitting as part of a panel with Marina Colby - Senior International Relations Officer (US Department of Labor | Bureau of International Labor Affairs) and Tom Pickerell - Executive Director (Global Tuna Alliance)

The pitch of the webinar is below, but basically is for you to learn about RISE and see if it can help you!

Register and see you then!

Demand for responsibly sourced products and momentum for mandatory human rights due diligence is increasing. Many companies recognize their responsibility to proactively identify and remediate labor and human rights abuses, but strategies that focus on risk mitigation and social compliance fall short of international norms and standards. Instead, to accelerate progress toward the ILO Decent Work Agenda, UN Guiding Principles on Business and Human Rights, and UN Sustainable Development Goals and to make impactful investments to protect human and labor rights within their supply chains, companies must take a comprehensive approach to social responsibility. Supporting decent work and other worker protections are also essential to maintain public trust and build supply chain resilience.  

Today, seafood businesses need a one-stop-shop to learn about human rights risks, find streamlined and useful guidance tailored to their operations, and identify organizations that can support their improvement efforts.

That is why FishWise created RISE - the Roadmap for Improving Seafood Ethics. RISE is a free, online resource that provides comprehensive guidance for seafood companies, from producers and processors to retailers and brands, and organizes resources from across the sustainable seafood sector, into an 8-step roadmap that is aligned with UN Guiding Principles and other international norms.

In this webinar, you’ll learn how RISE can help companies to:

  • develop a comprehensive and proactive social responsibility program,

  • take action on responsible recruitment, worker engagement, and decent work at sea,

  • and get connected to the tools, resources, and organizations that can help them take action today.

RISE advocates a paradigm shift. Moving from avoiding corporate risk to building value for workers, communities, and companies to create supply chain resiliency and sustainability.

Free Workshop on the Implementation of Port State Measures by APEC by Francisco Blaha

I have done work for APEC in the past… they are a very unique organisation in the membership and scope, i like the fact that their Ocean Fisheries Working Group (OFWG) has beee alwasy quite active and keeping up with what is happening.

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It is NZ turn to host the meeting this year… but COVID got on the way, so NZ is hosting it on line… which as most things in life has advantages and disadvantages…. to be on the positive side the advantage is that it can now be open to everyone… member or not, as there is no cap on attendance.

The workshop will feature a wide range of speakers (including me) covering a range of topics associated with Illegal, Unreported, and Unregulated (IUU) fishing, with a specific focus on port state measures as a tool to combat IUU.

This workshop aims to build capacity to implement port state measures through sharing experiences and how challenges associated with their implementation can be overcome. This is a significant event, as it is the first step in the APEC Roadmap to Combating IUU Fishing.

Below is the workshop agenda for your reference.

The work will be held across two days (21 and 22 July) from 14:00-17:30 NZT! Even if you can only join for a small portion of the workshop, you are most welcome!

To register for this workshop, please: 

1) complete this online form; and then 

2) compete the attached ‘Consent Form for NMP’ spreadsheet and send it to caleb.blackbeard@mpi.gov.nz [please note that there are two tabs/sheets in the spreadsheet, both need to be completed]

Please complete both of these steps before COB Tuesday 13 July and I “see” you there

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AIS-based profiling of fishing vessels falls short as a “proof of concept” for identifying forced labor at sea by Francisco Blaha

Back in December I was quite critical of a paper that correlated IAS, vessels characteristics and labour abuses. Of course, my criticism was based on my understanding and experience and the fact that did din not seem to have ground-truthed their assumptions and indicators with fisherman, as they could have immediately picked up the issues I picked up.… but then I’m just an ex fisherman and a couple of masters, while the authors are all PhDs and academics… so my criticism was just on this blog.

Not bad for vessels with a big engine

Not bad for vessels with a big engine

Now interestingly a letter to the authors was sent by some heavyweights scientists and published over a month ago. The authors say is way more elegant English (and without needing too many details) things around the line of what I wrote, further adding that it fails a “proof of concept”

Not that it really matters at the end, but it made me feel well. Maybe one day I’ll give PhD a go.

In the meantime, I paste the letter below, original here.

McDonald et al. argue that labor conditions in fisheries can be discerned from the movement and characteristics of fishing vessels. We recognize the authors’ effort, yet have strong reservations regarding their 1) limited dataset, 2) assumptions, and 3) model validation. Forced labor is a serious human rights violation, and any scientific claims potentially informing policy must be considered with particular care to best promote efforts toward ending human terror and supporting survivors. We, therefore, urge that the authors consider how their efforts may misinform policy.

The authors create profiles from vessels reported to have committed labor abuses, search for similar profiles in a database of 16,000 vessels with available positioning (automatic identification system [AIS]) and associated data, and conclude that up to 4,200 vessels in “global” fishing fleets are “high risk” for labor abuse. First, of 193 labor abuse vessels identified by McDonald et al., only 58 used AIS and just 21 yield AIS profiles suitable for their analysis, implying that nearly 90% of their known cases are undetectable by AIS-based profiling as proposed.

Second, the 27 features used in their profiles are not causally linked to labor conditions onboard. The four features identified as most predictive of labor abuse “risk” (engine power, maximum distance from port, yearly voyages, average daily fishing hours), describe large distant-water vessels and are therefore likely correlated. Third, there is no testing of vessels with similar profiles that have not engaged in labor abuse. Existing evaluation methods for positive-undefined learning systems require some positive/negative-class knowledge of unlabeled cases in the training or test datasets, and their performance given unbalanced data (with many more “undefined” than “positive” cases) is questionable (24). The authors fail to accomplish the former and display problems of the latter. The use of the 21 positive cases to both train and validate the model violates the golden rule of machine learning in that the test data cannot influence the training phase. Additionally, risk as presented is not likelihood or probability of labor abuse and statistical findings are not ground-truthed; thus, the data offer no evidence that forced labor is more prevalent in vessels identified as high risk.

Given the suggestion that their model provides “new opportunities for unique market, enforcement, and policy interventions,” we believe the authors must address the potential ethical implications of their approach. Statistical profiling risks being reductive, especially given limited understanding of the modeled system, and there are real concerns over its use leading to unfair decisions or discriminatory practices (57). McDonald et al. emphasize that model limitations may underestimate high-risk cases; given their limited sample and lack of model validation on data not used for training, even this statement remains speculative. We appreciate that their model is exploratory, but it remains largely untested and these crucial limitations should have been at the fore of the analysis. In conclusion, McDonald et al. falls short as a “proof of concept,” and therefore, the capacity of remote sensing as a tool for detecting fishing vessels engaged in labor abuses remains unsubstantiated.

And to be correct, I also acknowledge the response to the above letter by the authors of the original here. Yet for me personally their answer does not really address the obvious problems with the paper

Do FADs Contravene International Marine Pollution Law? by Francisco Blaha

A couple of days ago I blogged about the complexities of estimating how many FADs are added every year to the WCPO fishery, and more generally ho FAD fishing changed the fishery from the days I was fishing.

If I was to go back I would have to learn how to find fish again… literally. I don’t think Purse Seine tuna fishery would be economically viable at the present catch rates without FADs… you just have to see the catch rates during the next 3 months (FAD closure on the WCPFC area) to see that most of the fleet would be losing money at the present tuna prices.

I’m actually made for you to find me.

I’m actually made for you to find me.

In any case, there is an aspect of FADs that can’t be argued, they contribute to Marine Pollution (MARPOL), and this a paper Just a Harmless Fishing Fad—or Does the Use of FADs Contravene International Marine Pollution Law? analysis that fact from a legal perspective., which is always interesting.

I have no sufficient knowledge on the topic to make a value judgement on the paper, yet the fact that the author, Dr Robin Churchil, is an Emeritus Professor of International Law, University of Dundee, should be a guarantee, as Plastic from FV is a topic I worked working recently, I make an effort of learning by reading.

I quote the conclusions below, but as always I recommend you read the original from the link above.

Conclusions

A large number of FADs are lost or abandoned every year, with many eventually washing up on beaches as litter, stranding in sensitive marine habitats, such as coral reefs and seagrass beds, or sinking and causing damage to seabed habitats. That raises the question of whether international marine pollution law, in particular the international dumping regime (the London Convention, London Protocol, and UNCLOS) and MARPOL, could be used to regulate and mitigate such loss and abandonment. As far as the international dumping regime is concerned, the abandonment (but not the loss) of a FAD probably constitutes “dumping.”

From that it follows that where the London Convention is the applicable law, the state of loading or the flag state, as the case may be, must prohibit the abandonment of FADs made of persistent plastics or other persistent synthetic materials and issue permits for all FADs made of other materials that a fishing vessel intends to abandon. Where the London Protocol is the applicable law, the state of loading or flag state must prohibit the abandonment of FADs made of materials other than “organic material of natural origin,” and must issue permits for the deliberate abandonment of FADs that are made of such materials.

Under UNCLOS, where a fishing vessel intends to abandon a FAD in the territorial sea, EEZ, or continental shelf of a state other than the state of loading or the flag state, it must obtain the express prior approval of that state. There is a due diligence obligation on the state of loading and the flag state to enforce the prohibitions and permit systems of the London Convention and Protocol. Where those states fail to do so, they may be made subject to the dispute settlement processes of the London Protocol and UNCLOS, and to the noncompliance procedure of the London Protocol.

In the case of MARPOL, the nonaccidental loss of a FAD constitutes a breach of Annex V. That is also the case with the abandonment of a FAD, should the conclusion that abandonment falls within the scope of the international dumping regime not be correct. Flag states are under a due diligence obligation to enforce Annex V. Action against states that fail to do so may be taken under the dispute settlement procedures of MARPOL or UNCLOS. Alternatively, such failure could be drawn to the attention of the IMO when the flag state concerned was next due for audit under the IMO’s mandatory audit scheme.

Over the past few years, tropical tuna RFMOs have adopted a number of measures designed to alleviate some of the environmental problems caused by lost or abandoned FADs. All four RFMOs prohibit the use of entangling material suspended beneath FADs in order to prevent sharks, turtles, and other non-target species from becoming entrapped, and “encourage,” but do not (yet) require, FADs to be constructed of biodegradable materials apart from the satellite buoy.

The ICCAT and WCPFC encourage the recovery of lost and abandoned FADs.80 Both RFMOs also prohibit the use of FADs in certain areas at certain times of the year81; it is not clear whether that leads to a reduction in the use (and therefore the loss and abandonment) of FADs or simply leads to greater concentrations when their use is permitted. It remains to be seen how well the mandatory measures will be observed, and whether the hortatory measures eventually become mandatory.

In the meantime, there is a real need for the international dumping regime and MARPOL to be properly implemented and effectively enforced so that the significant pollution caused by lost and abandoned FADs may be reduced and eventually eliminated.