Global Fisheries MCS Evaluation Report by Francisco Blaha

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

MCS in Action

MCS in Action

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

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

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

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

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

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

I initially started on a pilot scale as a purely research based study for my Doctoral research over 5 years (2007-2011), and I published preliminary results of 41 countries on May 2011 (Pramod 2011). The results for the 41 countries was presented with a description in Pramod (2012). The range of attributes used in the questionnaire for the 2011 study was rather limited, but after completion of my PhD and once I resumed full-time consulting I contacted several key experts in Military and civilian agencies to make the attributes for scoring the 12 questions more robust. 
The study was then extended to 84 countries and using a wide range of interviews, phone calls and e-mails & assistance from fellow consultants I was able to get feedback from enforcement agencies and civilian agencies over a five year period. In the beginning, many fisheries related ministries and military agencies (Coast Guard or Navy) back in 2012 were reluctant to provide feedback citing confidentiality of MCS data. 
But after evaluating my request and case study questionnaire I received feedback from 75 countries. In many cases, I had to call the concerned person to explain the motivation behind the study before feedback was received and cited in Anonymous format. The range of feedback received ranged from a single response from fisheries ministry in the country concerned to 5 different responses from different agencies (ports, customs, fisheries, Coast Guard, etc.). 
Twelve of the 84 country reports were released online since April 2017 and another 10 reports would be made public in the coming months (
Note that all country evaluation documents are a ‘living document’ and may change with time. I remain open at any time to comments, corrections or adjustments. Just contact me.

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

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

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

Pramod (2012) Illegal and unreported fishing: Global analysis of incentives and a case study estimating illegal and unreported catches from India. PhD Thesis. University of British Columbia, Vancouver, Canada, 343 pages (

One Noro at the time by Francisco Blaha

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

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

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

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

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

Jamie and John R clearing the arriving vessels

Jamie and John R clearing the arriving vessels

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

Nesii makes it look easier

Nesii makes it look easier

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

Sandy weighs every fish

Sandy weighs every fish

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

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

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

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

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

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

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

Jamie is great to work with

Jamie is great to work with

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

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

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

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

Solomons helps Taiwan

Solomons helps Taiwan

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

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

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

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

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

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

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

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

My home in Noro

My home in Noro

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

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

Dual use of fish wells in Purse Seiners and Longliners by Francisco Blaha

A new “storm” is closing on Purse Seiners and many longliners approved by their flag states Competent Authorities (CAs) as eligible to export to the EU. It relates to using fish wells/holds to transports fuel when they depart port or after bunkering at sea.

Only for fish my friend

Only for fish my friend

If you want to understand how "eligibility" (to be authorised to export or provide to processing establishments approved to export) to the EU works, I’ll direct you un-shamelessly to this publication.

Yet as a simplification: all establishments in the capture or aquaculture production chain (hatcheries, farms, vessels, plants, cool stores, etc.) must be approved by the national Competent Authority (CA) in regard to the EU requirements for the product that they handle to be considered “eligible” for the EU.

The list of approved establishments in the progression from “raw material to product” is maintained by the CA and represents all the Food Business Operators (FBOs) in the production chain that are allowed to provide to companies that export directly to the EU.

The establishments at the end of the chain (those that export directly to the EU) are to be included on a list of establishments authorised to receive a Health Certificate for their products. This list can include freezer vessels, plants or cool stores as long as they export directly to the EU (or to another third country for further processing and then to the EU).

These establishments are given a unique identification code, usually known as the “EU number”.

The CA sends to the European Community  a “list” of authorised establishments (including freezer and factory vessels), with the guarantee that they have been inspected and deemed to comply with the specific hygiene rules that correspond to the type of product processed.

Therefore any changes or updates in this list need to be communicated to the EC immediately. The approval and listing is not a “one off” event, it is based upon continuous compliance by the establishments.

If the level of compliance becomes so low that the CA is unable to provide the required official guarantees, then the establishment can be suspended or taken out of the list.

When this happens, the establishment loses the right to export to the EU and or provide raw materials and products to “listed” establishments.

Regulation (EC) No. 853/2004, lays down specific hygiene rules on the hygiene of foodstuffs of animal origin, and Regulation. (EC) No. 854/200411, lays down specific rules for the organisation of official controls on products of animal origin intended for human consumption, and also includes the basic rules for the surveillance of food and the listing system for imports. This system includes special rules for fishing vessels, factory vessel and freezer vessels flying the flag of a third country, in order to be able to control fishery products even when caught by one flag and processed in a different country.

Now, since I remember, most Purse Seiners and Longliners from the Distant Water Fishing Nations use the fish wells as temporary fuel tanks, since that extend their range and as well they bring fuel to other vessels under the same owner or syndicate. So basically they do this pure economic reasons.

In general terms, once you emptied the fuel of the well, it gets a really good clean up, since the fish buyers would look for any issue to get down the price of fish when they get. And the minimal “sniff” of fuel would be the perfect excuse to get down the price big time.

And while most vessels never really “publicise” the practice of keeping fuel in the fish wells prior departure, they also didn't really hide it. Anyone having access to the engineers logbook would have know it.

Yet it was a good advice to close the well and pile the salt bags on top of the hatch. You don't have to be a food safety expert to know/feel that storing fuel where you store fish, may not be the best idea… would you accept that your vegies are transported in the empty fuel tanks of a truck?

In any case, the EU inspectors found out about this practice on some recent inspections. With the regs on their side, they noted that the dual use of wells (to store fuel and later, after cleaning, to freeze fishery products and store them), is not in accordance with the EU rules, in particular with:

point I.A.l. of Chapter I, Section VIII of Annex III to Regulation (EC) No 853/2004 (structural and equipment requirements for vessels);
 1. Vessels must be designed and constructed so as not to cause contamination of the products with bilge-water, sewage, smoke, fuel, oil, grease or other objectionable substances.

And II.1 (Hygiene Requirements)
When in use, the parts of vessels or containers set aside for the storage of fishery products must be kept clean and maintained in good repair and condition. In particular, they must not be contaminated by fuel or bilge water.

As well as, Point 2 of Chapter IV of Annex II to Regulation (EC) No 852/2004:
Receptacles in vehicles and/or containers are not to be used for transporting anything other than foodstuffs where this may result in contamination

The reality is that the only reason why vessels would use the fish wells as fuel tanks is based on the economics of a trip. So I was told, that if the vessels can’t get to the fishing grounds with the fuel they have, then they either need to bunker at sea or redesign their vessels with bigger fuel tanks as to get where they have to go. If they need to use fish wells as fuel tanks, then those wells would need to be just that, and no fish should go back there.

Hence, if an inspector of a Competent Authority of a country authorised to exports to the EU verify this practice, then  the fish in that well should be rejected. Furthermore if the practice continues, that vessel should be taken out of the EU approved list, hence all its production is not eligible to the EU (either directly of via any processing company that exports to the EU)

Companies, of course, are not happy, and while all sorts of actions are being proposed (i.e. cleaning plans, throw away plastic liners for the wells, increased testings, etc) these are, in the eyes of the sanitary authorities, remedial situations to a scenario that should not be happening… a fish well is a fish well, and a fuel tank is a fuel tank. End of story.

Interestingly, this issue will affect mostly flag states that massively subsidy fuel for their fleets, so I guess there is some sense of equanimity at the end.

A model for IT-based risk assessment for Vessel's Inspection by Francisco Blaha

The good people of IUU Watch presented a couple of weeks ago a post by Grant Humphries of Black Bawks Data Science that developed and algorithm aimed at vessels risk profiling. While aimed to support the EU IUU Reg. I like to see beyond that (how many non EU vessels do unload in the EU?), furthermore if it is to profile the risk of a vessel based on the data in the Catch Cert, they way things are at the present, that vessel could have unloaded months and even years ago.

Said so, I do like the design logic behind the algorithm, and I can see many uses for it at ports, particularly under the PSMA principles. Furthermore, I could see it as a way to add relevance to the Vessel Compliance Index like the one run by FFA.

I paste below the text from the IUU Watch post, as written by Grant. 

I present a sample application that shows how a relatively simple decision support tool could be built into the EU IT system referred to above, to assist in the selection of fishing vessels/seafood consignments for controls aimed at detecting illegal fishing. The example below combines the predictive power of Random Forests – a powerful machine learning algorithm – with the open source, web application builder “R Shiny”. This decision support tool allows users to select a test fishing vessel with set parameters, and predict its probability of engaging in illegal fishing. Users can also create their own series of parameters and make a prediction on the probability of a ship engaging in illegal fishing

The test application can be found at:

The code and technical details for the application/simulation are available on Github:

Development of the application

The steps involved in developing the risk management application were as follows:

Step 1: Creation of a simulated dataset of ships and characteristics with pre-set relationships between illegal fishing and our simulated predictor variables (see below table) 
Step 2: Training of the Random Forests (machine learning) algorithm
Step 3: Building of a web-based application in R Shiny that allows users to input data
Step 4: Use of the information in the trained Random Forests algorithm to predict the probability of the ship engaging in illegal fishing

In the real world, the dataset on which we would train the algorithm would be stored in a central, password and firewall protected database, which could be accessed through the web-based application.  A proposed model could look like this

Step 1: The data

The scenario in the test application has:

  • Five fictional countries: Sidonia, Avalon, Noordilund, Slagovnia, and Tortuga.
  • Five fictional owners: SparkleFish, FishRGud, KungFuFish, ScummyFishCo and FishARRRies
  • Five classes of ship (classed by length): 1 (60 – 100m), 2 (101 – 130m), 3 (131 – 170m), 4 (171 – 220m) and 5 (221 – 300m).
  • Five possible destinations of goods: LaLaLand, BetaZed, The Shire, Alpha Centauri, and Kings Landing
  • Five fish species: Raricus fishicaCommonae eatedieBillidae nyiecusDonaldus trumpfishii and Fishica maximus

I next simulated 3000 fictional ship IDs, with the assumption that the five countries have submitted all known data for their ships. These 3000 ships form the basis by which we “teach” our model (training) to “learn” the patterns / relationships.

With the 3000 ships, I created a data table with the following columns:

Screen Shot 2017-05-08 at 8.53.46 AM.png

I simulated this dataset under 10 assumptions:

  • Assumption 1) The largest (class 5) and smallest (class 1) vessels are slightly more likely to engage in illegal fishing. (Note: this helps to create a bimodal distribution of the ship sizes engaging in illegal activities to demonstrate the non-parametric nature of the algorithm, i.e. doesn’t depend on statistical distributions).
  • Assumption 2) “Responsible” countries with strong Illegal fishing laws are less likely to engage in illegal fishing. In our dataset, Sidonia and Noordilund are countries with strong regulations, Avalon is in the middle and Slagovnia and Tortuga have either little or no regulation.
  • Assumption 3) Companies with sustainable practices will almost never engage in illegal fisheries. In our example, SparkleFish, and KungFuFish are the most sustainable, FishRGud are moderate, while ScummyFishCo and FishARRRies are the least sustainable.
  • Assumption 4) Older fishing vessels are more likely to engage in illegal fisheries as they are more likely to be used by organizations wanting to cut costs and not prioritize safety features to save money (these are organizations likely to be more corrupt).
  • Assumption 5) Raricus fishica is likely to be illegally caught the most… but Billidae nyiecus looks like another species therefore we score it higher as there could be illegal fishing associated with it.
  • Assumption 6) CITES listed II species are more likely to be associated with illegal fishing
  • Assumption 7) If an owner has been flagged for illegal fishing in the past, this increases the likelihood a vessel is fishing illegally
  • Assumption 8) If a country has been flagged for illegal fishing in the past, illegal fishing is more likely
  • Assumption 9) If a ship has switched its trade route, it is more likely to be fishing illegally
  • Assumption 10) If ship has not switched on its AIS, it is more likely to be fishing illegally

Step 2: The analysis

Note: in this case, I was not interested in testing the hyperparameters (e.g. all the settings that help tune the algorithm) of Random Forest, so I left these under the default settings. 

Random Forests works by way of decision trees (i.e. a souped-up series of conditional “if” / “then” statements) to make predictions on a target variable. It creates those conditional statements by “learning” the relationships between the target variable (here, illegal fishing) and the predictor variables (the variables we want to use to predict the target – see table above).  Using the data simulated in Step 1, we used the “Illegal” column as our target variable – in other words, we were interested in predicting if a ship was engaged in illegal activity based on the other columns (owner, country, etc…).

We used a cross-validation technique to ensure the model was predicting our data well.  In this case, the Random Forests model we used had an accuracy of 74% – that means that it correctly guessed if a ship was engaged in illegal fishing (or not), 74% of the time. This value could be vastly improved through tuning of the model (e.g. tuning of hyperparameters, use of ensemble models, deep learning methodology, or other techniques).  I purposefully programmed “noise” in our dataset to ensure that we didn’t achieve a perfect model. The goal of this is to demonstrate how the proposed system could work as opposed to perfecting the model.

Step 3: User input and prediction

On the front end, the user is given the option to select from one of five ships, which fills in the pertinent data like “owner”, “country”, “ship length”, etc…  For example, the “Christian Bale” is a ship owned by ScummyFishCo, and is registered in Slogovnia. It is 192m long, making her a class 4 ship. The ship was built in 1975, and normally sends product to LaLaLand.  If that ship comes into port and the user tells the front end that this ship was catching Raricus fishica, that the shipment is being sent to King’s Landing, and that the AIS was active since last at port, we find that the probability of this ship engaging in illegal fishing was 0.93 – in this case, we would likely board the ship for inspection.

Another potential ship a user could pick in our application is the Bruce Lee. She is owned by KungFuFish and registered in Noordilund. The ship is 83m long, making her a class 1, and was built in 2014, normally shipping to LaLaLand.  If on an excursion, the Bruce Lee returns with Commonae eatedie being shipped to LaLaLand, and had her AIS on, the probability of the ship engaging in illegal fishing would be 0.03 (3%), so we would not likely inspect the ship so thoroughly.

Step 4: Using the information

The question really lies in what thresholds do we use to make the decision on whether to inspect a ship or not. For example, if the probability is 51%, do we board?  The precautionary principle would suggest we do, but this could increase the number of inspections which may not be commercially viable.  One school of thought could be to only inspect ships with a very high likelihood of engaging in illegal fishing (e.g. 80% or more).

No matter what approach is taken, decision support tools that take advantage of sophisticated algorithms are showing great promise. Using them to combat illegal fishing will automate decision-making in a transparent way that can be scaled from local to global solutions. Furthermore, data integrity can be secured through centralized databases with specifically designed access.

There is still much work to be done to develop these tools in a way that is agreed upon by the global community, but we are at a stage now to begin the process.

Back to Noro in the Solomons Islands by Francisco Blaha

I like my job (even if some days I don't like working) and going back to Noro (the place that to me exemplifies what fishing should be in the Pacific) makes me happy.

Not a bad view to wake up for 3 weeks :-)

Not a bad view to wake up for 3 weeks :-)

I'll be there to assist the Ministry of Fisheries and Marine Resources (MFMR), through the Mekem Strong Solomon Islands Fisheries (MSSIF) a NZAID funded initiative.

This consultancy is to follow up on initial training conducted in 2016 for the Noro based Compliance team in their day to day activities to build their capacity to confidently and effectively implement their roles, particularly in relation to CDS and CCS. I will contribute to implementing the capacity development road map for the Noro based compliance team. 

Particularly help them identify problems and unresolved issues and work with each of them to problem solve and build problem-solving skills. 

I'm going to a friend's place... (that is what it feels) and is a friend I have known from many years now, and I see growing in confidence and determination. 

50-60% chance of El Niño later this year by Francisco Blaha

There is a 50-60% chance of an El Niño event forming in middle to late 2017, according to a new Update from the World Meteorological Organization. Following borderline weak La Niña/cool-neutral conditions during the second half of 2016, sea surface temperatures and most atmospheric fields returned to more ENSO-neutral levels in January 2017 that continued to the present.

from the MetOffice 

from the MetOffice 

However, sea surface temperatures in the far eastern tropical Pacific Ocean increased to 2.0° Celsius or more above average during February and March, creating very heavy rainfall and a trade wind collapse from the Galapagos Islands to the coasts of Ecuador and Peru. This localised warming – known in Peru as a “coastal El Niño” - is different from the more broadly known El Niño warming pattern, but its impacts on the affected areas were just as big.

Many of the climate models surveyed indicate that basin-wide neutral conditions will persist through to June 2017. The subsequent development of an El Niño during the second half of 2017 is more likely than the continuation of neutral conditions. The emergence of La Niña appears very unlikely, according to the Update, which is a consensus-based product, based on contributions from leading centres around the world that monitor and predict this phenomenon, and expert assessment of the results of climate models.

It should be kept in mind that predictions of ENSO made before May or June for the second half of the year typically have less certainty than outlooks made later in the year.

Normally with El Niño stocks will move towards the east further into Kiribati, Tuvalu, Tokelau and Nauru, as water temperatures changes, and therefore away from fishing grounds of Papua New Guinea, Solomon Islands and Palau.

These changes the logistics of tuna trade since it moves transhipments to the reef lagoons of Tarawa and Kirimati and away from Majuro, Pohnpei and Rabaul. It also diverts processing towards Manta in Ecuador, as the most eastern grounds are at this stage closer to Ecuador than to Thailand or the Philipines.

The effects on regional climate of each El Niño event are never exactly the same: they depend on the intensity of the event, the time of year when it develops and the interaction with other climate patterns.

Below and explanation how the 2015-16 impacted global weather.

Background notes

El Niño is often associated with warm and dry conditions in southern and eastern inland areas of Australia, as well as Indonesia, the Philippines, Malaysia and central Pacific islands. During the northern hemisphere summer season, the Indian monsoon rainfall generally tends to be less than normal. In the northern hemisphere winter, drier than normal conditions are typically observed over south-eastern Africa and northern Brazil.

Wetter than normal conditions are typically observed along the Gulf Coast of the United States, the west coast of tropical South America (Colombia, Ecuador and Peru) and from southern Brazil to central Argentina. Parts of eastern Africa (Kenya, Uganda) also usually receive above-normal rainfall. El Niño is associated with milder winters in north-western Canada and Alaska due to fewer cold air surges from the Arctic – a result of a large-scale region of lower pressure centred on the Gulf of Alaska/North Pacific Ocean.

World Tuna Day - My take by Francisco Blaha

Until now 2 of May was quite a sombre day in my life for something that happened exactly 35 years ago, and I guess among many other things made me very aware of the rights of coastal states (and the fragility of life, the stupidity of wars, etc., etc.). Is totally coincidental (but very appropriate for my life) that the UN General Assembly proclaimed 2 May World Tuna Day, spotlighting the vital socioeconomic importance of tuna around the world. 

More than just a fish to me.

More than just a fish to me.

And yes, I’m one among the estimated 22000 people in the Pacific whose livelihoods depend directly and completely of Tuna. An industry that at its base produces some 256 million cases of tuna that are consumed annually, amounting to U$D 7.5 billion, yet around only 600 to 700 million come back to the resources owners, the Pacific Island Countries (PICs) where over 60% of the world tuna resources originate. 

Tuna has served as an important source of food for people across the Pacific islands for centuries.  However, there are serious challenges to their long-term sustainability, as there is more fishing effort for tuna than for any other group of fish, and the overwhelming majority of this effort is by Distant Water Fishing Nations (DWFN). 

And this is an issue of overarching importance since confronting interests are pushing tuna sustainability. There is a fundamental (and perhaps unbridgeable) difference; as clearly expressed to me, by my Nauruan friend and colleague Monte Depaune last year:

“for non PICs and DWFNs the issue of sustainability is one of long-term financial benefit. However, for Coastal States PICs it is also a food security issue, one that DWFNs have less trouble with, as they can leave… but PICs cannot”. 

Tuna is the lifeline of the Pacific but the balance of benefits is entirely skewed, in a way that has not moved far from the times of colonialism. 

Countries with money, technology and resources get richer by using the resources of poorer smaller countries at a lower level of development. They do so by pushing many agendas (including aid) and taking advantage of the lesser level of institutional maturity in countries that are struggling to manage themselves, as they are only 40 to 50 years old and had to “learn” from scratch a system of laws and a concept of nationhood entirely foreign to their former reality.

Tuna users in the big background boats... tuna owners in the canoe... this is just wrong.

Tuna users in the big background boats... tuna owners in the canoe... this is just wrong.

Tuna gave me a new and good life when I came to the Pacific, escaping far from my origins and struggles. Yet it gave me a life in a place whose people draws many similarities with the people I grow up in the backwaters of northern Argentina . Tuna gave me friends and an extended family in places that barely figure in maps, yet there is more “humanity” than in countries whose “empires” cover the earth.

I can only say “thank you” to tuna, and believe me that if there were any way in which I could avoid killing them, I would be first on the line. For now, the best I can aspire is that their deaths are maintained at the minimum necessary, under the terms of the law and entirely accounted for. 

I owe to myself... perhaps compensating for the unnecessary deaths I could not stop.

Closing the High Seas by Francisco Blaha

The High Seas (a.k.a. ABNJ) is a topic I have boarded a few times in the past, and is part of my ever expanding "interest list". A good discussion on “Closing the High Seas” was posted by the CFOOD (Collaborative for Food from Our Oceans Data) page.  CFOOD are the loose network of scientists who work together to better understand the science of fisheries sustainability, The group includes some heavy weight scientists like Ray Hilborn, Kevern Cochrane (former FAO colleague), Ana Parma and others.

lost in time, space and control

lost in time, space and control

I have shared CFOOD work before, as it is always thought provoking and in some cases quite controversial. Controversy and critical thinking are vital in fisheries, where uncertainty is a tool, not an excuse.

The discussion collected opinions of diverse range of people that is really experienced including some I know personally and respect a lot, like Sydney Holt, John Hampton, Bubba Cook and Petri Suuronen

The discussion ins centered around 4 areas:

  1. Should we close the high seas to fishing?
  2. Motivations for closing the high seas
  3. Closing the high seas – potential implications and outcomes
  4. Alternatives to closing the high seas – other potential strategies and outcomes

I let you read the discussion by your self by clicking on the links above, I just quote the closing comments;

Resolving the issue of whether or not to close the high seas to fishing is mostly about politics. To quote Otto van Bismarck, “politics is the art of the possible.” “Any advancements here will involve that art and not just science,” says George Rose. “I believe that a complete closure is not possible, and in some cases where reasonable management is in place not advisable, for the many reasons stated in the comments.
Nonetheless, there are many ocean areas where a moratorium as suggested by Holt makes sense – at a minimum to draw attention to uncontrolled fisheries and lack of any science or even basic information. This approach would rely on spatially based categorization of the HS into management areas, much as suggested by Chris Costello, with some areas having controlled fishing with gear restrictions and others with no fishing (I see no future in an open category except as a throw-away).
Having fishing industry involved in this would be necessary for this to have any chance of being effective. There are examples of this approach that have been very effective at smaller coastal scales.
Accomplishing this would be difficult enough politically and involve a major international effort but setting complete closure goals that are impossible to achieve and of questionable merit only muddies the waters.
how can you close so much space?

how can you close so much space?

SPC's 11th Fisheries Data Workshop by Francisco Blaha

2017 marks the 11th annual Tuna Data Workshop, and it is held from the 24th to the 28th of April 2017, in Noumea, New Caledonia. The regional Tuna Data Workshop is conducted on an annual basis for SPC member countries to improve their scientific tuna monitoring and data management capacity and satisfy their data reporting obligations to the Western and Central Pacific Fisheries Commission (WCPFC). 

Data management in fisheries (at this level) is unfortunately an indoor activity.

Data management in fisheries (at this level) is unfortunately an indoor activity.

Data acquisition and management are essential to successful fisheries management, and a lot of effort has been provided by SPC over the years to strengthen their capabilities and to support member countries in collecting and managing fisheries data, for their own and for regional benefit.  (See here what are the roles of SPC and FFA in these aspects). 

For the last years, I been working on the use of these (SPC's and FIMS) data streams in MCS to control IUU fishing and "fish laundering", hence I very grateful to SPC and FFA to have invited me to assist to the present workshop as to strengthen my knowledge in these areas and offer a glimpse of what I'm working on for FFA.

Very much looking forwards to this week, besides work New Caledonia being a small piece of France in the Pacific they take their coffee, their bread and their fitness quite seriously... and I'm quite partial to that!


Benefits of a moratorium on transshipment on the high seas by Francisco Blaha

Transhipments is a complicated issue I boarded (pun intended) before. While there are valid logistical and economic reasons for their existence, they remind a problematic issue and all efforts to control them seem to fail short. To the recent study on likely transhipments I posted a week ago, this new paper on Marine Policy adds more salt to a already known injury, and makes a good case for a total ban on transshipment at-sea across all RFMOs.

Yellow: ORION S (reefer), Blue: AMERICAN EAGLE (purse seiner), both Colombian flagged, transhipping in the High seas between Ecuador and Galapagos Islands.  2015-04-09. Image source Global Fishing Watch

Yellow: ORION S (reefer), Blue: AMERICAN EAGLE (purse seiner), both Colombian flagged, transhipping in the High seas between Ecuador and Galapagos Islands.  2015-04-09. Image source Global Fishing Watch

The six authors of this paper come from a mixture of academia and NGOs, wich is good to see as (in my opinion) some NGOs tend to be weak on the factual analysis side, while academics (in principle) go trough a more rigorous process on their publications. The paper does not tell "unknown" truths to the people in the IUU field, but grounds those truths on a solid methodological review of the rules at RFMOs and from those, they draw some robust conclusions that go beyond fisheries.

I paste below the abstract and conclusions, but as usual, go to to the original for the full picture.

One way that illegal, unreported, and unregulated (IUU) fish catch is laundered into the seafood market is through transshipments at-sea. This practice, which often occurs on the high seas (the areas of ocean beyond national jurisdiction), allows vessels fishing illegally to evade most monitoring and enforcement measures, offload their cargo, and resume fishing without returning to port. At the same time, transshipment at-sea can facilitate trafficking and exploitation of workers who are trapped and abused on fishing vessels.

This study gives an overview of high seas transshipment as well as evaluates transshipment at-sea regulations across 17 Regional Fisheries Management Organizations (RFMOs), which are responsible for regulating fisheries on the high seas. Transshipment at-sea regulations have become increasingly strict in most RFMOs since the late 1990s. However, only five RFMOs have mandated a partial ban, and only a single RFMO, the South East Atlantic Fisheries Organization (SEAFO), has mandated a total ban on transshipment at-sea.

A total ban on transshipment at-sea across all RFMOs would support the ability of oversight and enforcement agencies to detect and prevent IUU fishing and also likely reduce human trafficking and forced labor on the high seas.

The RFMOs around the world are in a unique position with respect to transshipment, and are likely to come under increasing pressure to address this activity for both ecological and sociological reasons. Given the increased overexploitation of high seas fish, sizable economic losses to illegal fishing globally, documented IUU fishing associated with transshipments on the high seas, and ever-increasing concerns about forced labor, it would be prudent to invoke the precautionary principle and instate a moratorium on transshipment at-sea across all RFMOs.

While most RFMOs have improved transshipment at-sea regulations over the last two decades, a moratorium on transshipment at-sea would provide the best ecological and social outcome for high seas fisheries. A total ban on transshipment at-sea is a primary way to ensure that human trafficking can be combated alongside preventing the laundering of IUU catch.

The socioeconomic effects of an RFMO-wide moratorium would likely be fairly immediate, as vessels would be routed into EEZs and return to port more frequently, which would likely increase the costs of fishing but also improve trafficked fishers’ opportunities of notifying authorities of human rights abuses. Ecological effects, however, would likely only become apparent over time, if the moratorium on transshipment reduced overfishing and IUU fishing.

Reduced fishing pressure on the high seas could also offset economic losses of a ban on transshipment at-sea if fishing within EEZs subsequently becomes more productive. RFMOs might adopt a precautionary approach similar to SEAFO's, which included an interim prohibition on transshipment at-sea before implementing a permanent ban.

The issue of IUU fishing and human rights abuses on the high seas deserve urgent attention, and a moratorium on transshipment on the high seas is one way to address both issues.


A database of global marine commercial, small-scale, illegal and unreported fisheries catch 1950–2014 by Francisco Blaha

I wish I had more time to read, or more validly, I was more disciplined in my job to allow reading time! Yet again a recent paper by Reg A. Watson caught my attention. In this latest work, he harmonised global fisheries landing datasets from the best public sources, interpolate missing taxonomic data, then map the records to a grid of 30-min spatial cells so as to remain consistent with all available auxiliary data and make that dataset publically available. What a legend!

Examples of database use with mapped catch rates (kg km−2 yr−1). (a) Average annual reported catch rates (including IUU) for 2010–2014; (b) Average annual catch rate of discarded marine products 2000–2004; (c) Average catch rate of sharks and rays 2010–2014; (d) Average catch rate of tunas and billfish 2010–2014.

Examples of database use with mapped catch rates (kg km−2 yr−1).
(a) Average annual reported catch rates (including IUU) for 2010–2014; (b) Average annual catch rate of discarded marine products 2000–2004; (c) Average catch rate of sharks and rays 2010–2014; (d) Average catch rate of tunas and billfish 2010–2014.

Read below my shameless quoting of his paper or go (for free) to the original.

As Global fisheries landings data from a range of public sources was harmonised and mapped to 30-min spatial cells based on the distribution of the reported taxa and the fishing fleets involved. This data was extended to include the associated fishing gear used, as well as estimates of illegal, unregulated and unreported catch (IUU) and discards at sea. Expressed as catch rates, these results also separated small-scale fisheries from other fishing operations. The dataset covers 1950 to 2014 inclusive.

Mapped catch allows study of the impacts of fisheries on habitats and fauna, on overlap with the diets of marine birds and mammals, and on the related use of fuels and release of greenhouse gases. The fine-scale spatial data can be aggregated to the exclusive economic zone claims of countries and will allow study of the value of landed marine products to their economies and food security, and to those of their trading partners.

Background & Summary
Fishing operations span the globe and occur in all but the deepest and most remote places in global oceans. Fishing remains central to the food security of many countries. It provides much needed protein and income to those with few alternatives. To wealthier nations it is associated with an extremely valuable and a highly globalised seafood trade. The world’s oceans hold continued promise to provide a range of vital services, and fishing will remain important.

Conflict for coastal land use, pollution and other increasing population-based demands are compounded by ocean acidification, warming, spread of pests, deoxygenation and toxic algae blooms. Humans need to guard marine resources, and mapping global fisheries is an important element. Fishing effort continues to increase, putting pressure on marine resources. Large ocean areas have been set aside from fishing as marine protected areas but placing these also requires knowledge of fishing pattern. Knowing the details of global fishing operations remains an important part of ensuring that the ocean’s services and productivity are not misused.

Examining the relationship between global fisheries and the marine environment, including its wildlife and sensitive habitats is challenging but is necessary before the impact on biodiversity and its values can be estimated. Publically available fisheries records are vague, especially in locating where fishing occurs. Nevertheless, it is vital to map fishing and use all available information to do so.

This information includes all public sources covering various spatial scales, and auxiliary data such as the distribution of the reported taxa, and information on the distribution of fishing fleets based on access rights and on their observed behaviour. Datasets have been compiled with increasing skill since 1999 and are renewed as more data become available.

The approach here is to use a harmonised global dataset from the best public sources, interpolate missing taxonomic data, then map the records to a grid of 30-min spatial cells so as to remain consistent with all available auxiliary data and to make that dataset publically available (Data Citation 1: Institute for Marine and Antarctic Studies, University of Tasmania

Data was sourced from a range of public sources (Fig. 1).

Fig 1: Flow diagram of data collation and processing

Fig 1: Flow diagram of data collation and processing

These were harmonised into a single global dataset with common coding. For each location and year, the best coverage from the available sources was selected and overlapping data removed. This dataset was filtered to retain only marine animals but excludes amphibians, reptiles, birds and mammals.

The records were mapped to candidate cells within a system of nearly 300 k global 30-min spatial cells using information on the reported fished taxon’s distribution, the behaviour and access of the reported fishing fleets and any area description provided. A portion of the reported landings represented by each record of the unmapped global dataset was mapped to each candidate cell following a gradient based on the reported taxon’s expected distribution based on depth, habitat and other requirements. Known quotas imposed on fishing fleets were applied.

The result was a mapped dataset of catch rates (tonnes per square km of ocean) for each spatial cell separated by year, fishing nation and fished taxa. This data set was further extended to breakdown the reported landings by fishing gear type based on associations with year/country/taxa. Following this, the catch rate of illegal and unreported landings was estimated for each data record. An estimate of discards (not necessarily of the reported taxa) is also made. Though much of the input landings would be derived from large-scale fishing operations it was possible to estimate rates from small-scale fishing and adjust catch rates to minimise duplicate reporting.

Non-overlapping data sources are selected as input (Fig. 2a). In general, the United Nation’s Food and Agriculture’s (FAO) dataset was the only source that provides global coverage but spatial resolution can be quite coarse. FAO’s various regional bodies provide finer spatial definition for several areas and those were used when available and possible. The breakdown of global tonnage represented by records (Fig. 2b) correlates generally to those developed by reconstructions of individual countries in another global dataset (SAUP), which uses different methodology. The number of database records varies spatially (Fig. 2c) and was impacted by the diversity and intensity of fishing and the level of management control. The number of different taxa reported also varies and is greater in coastal areas (Fig. 2d).

One of the likely conclusion of this mammoth dataset, is something we all suspect, that for more than a decade catches have plateaued and we are at maximum extraction capacity. Even if fishing effort still increasing (mostly thanks to subsidies) there is no "more" fish to take... what we have now is as good as it will get... if anything it will go down.


Inroads into Ilegal transhipments analysis by Francisco Blaha

I recently reported on an interesting report on the Global Footprint of Transshipments produced by Global Fishing Watch. As is had a flight with shitty movies, I went over the methodology of the report, and I like it. Is well thought and explained.

Is a pity that these guys don't have access to RFMO and the flag state data on observers, and logsheets, and in many cases the RFMOs don't have the manpower, budget and political will by their DWF Members to get a couple of good consultants/researchers to go over the results and track back the vessels documents, wich are at the end of the day the responsibility of the flag state. (Maybe there is a space for support from big NGOs like Pew or WWF?)

For example, one of the cases they present is of 2 vessels I got to know something about.

In page 6 they present data of an encounter between the ORION S (reefer), and the AMERICAN EAGLE (purse seiner), in 2015 at the high seas (ABNJ) between Ecuador and the Galapagos Islands. Both these vessels are Colombian flagged and belong to the same company that operates a dozen purseiners from the port of Manta in Ecuador. In principle, the purseiners transship in port to the carrier, and when the carrier is full it goes to Panama, crosses the canal and comes down to unload in Cartagena.

All the vessels of this company (including the carrier) are EU listed, hence for that fish to go to the EU a catch certificate is to be validated by the Colombian Fisheries Authority (AUNAP) so in principle they should have access to the logsheets and VMS of the vessels, plus it would surprise is they were to allow transshipments at sea.

In any case, the information should be there to verify the finding, and if is not, then that is a big failure by the Authority of an allegedly responsible flag state. Otherwise, they should audit the company that owns both vessels and look for the “mates receipt” that conform the volumes transferred. No captain would ever let fish go without a receipt because his payment depends on that.

The reality is that there are records for every one of those alleged transshipments, but one need the authority, the knowledge where to look and the willingness by the flag states to do something about it.

Back to the report, I pasted below the methodology of the study so that you can assess for yourself their robustness.


AIS Data
We identified the majority of the world’s reefers and then tracked the movements of these vessels using the Automatic Identification System (AIS), a type of transceiver that broadcasts a vessel’s location every few seconds. Originally meant for vessel collision avoidance, AIS can now be picked up by satellites and terrestrial receivers. This data is aggregated into global into global databases such as the one Global Fishing Watch obtains from the telecommunications company Orbcomm. The International Maritime Organization mandates that all vessels larger than 300 tons on international voyages carry AIS, and most countries have adopted similar or stricter regulations for their EEZs. In 2016, more than 300,000 vessels broadcasted an AIS signal, of which about 80,000 were fishing vessels, and a few hundred were refrigerated cargo vessels.

 Development of Reefer Database
Our database of reefers was compiled from the following sources:

  1. Refrigerated cargo vessels, fish carriers, and fish tender vessels were identified using vessel lists from the International Telecommunications Union and major Regional Fisheries Management Organizations (RFMO).
  2. If a vessel participated in multiple encounters with fishing vessels, we conducted a web search and reviewed RFMO registries using information from the vessel’s AIS to determine if the vessel was a reefer.
  3. Additional reefers were found by investigating documentation on registry websites and other online resources and determining alternate identities that we were able to match in our database.
  4. A vessel classification neural network, developed by Global Fishing Watch to predict vessel types based on movement patterns, was used to identify possible reefers.

Vessels that were identified as likely reefers by this neural network were manually reviewed through web searches and RFMO registries.

After developing the list, we verified vessel information using reputable online sources: the HIS shipping databases, MarineTraffic, ShipSpotting, VesselFinder, and FleetMon. Our database of reefers is now available through

We identified a total of 794 reefers. According to the US Central Intelligence Agency World Factbook, 882 refrigerated cargo vessels were active worldwide in 2010.Assuming that the number of reefers has not significantly increased or decreased since 2010, our dataset includes about 90 percent of the world’s reefer vessels. Some industry analysis suggests the number of reefers is decreasing, meaning that this 90 percent figure is a conservative estimate.1 7 Almost all reefers are required to carry AIS. Ninety-eight percent of the refrigerated cargo vessels in our dataset are larger than 300 gross tons and the International Maritime Organization mandates that vessels heavier than 300 tons on international voyages carry AIS.

Most countries have similar regulations for their EEZs. If we are missing reefers in our dataset, they are likely to be either smaller reefers or vessels that do not make international voyages.

Identifying Transshipments: Encounters and Rendezvous Behavior
We identified potential and likely transshipments in two ways: vessel encounters and rendezvous behaviour by reefers. We extracted these signals using our AIS and reefer databases with help from locations of known transshipments from the Indian Ocean Tuna Commission (IOTC).

Vessel Encounters
To identify likely transhipment events, we identified all interactions between two vessels which remained within 500 meters of each other for longer than 3 hours while travelling at less than 2 knots. These parameters balance the need to detect vessel pairs nearby for extended periods of time while recognising that satellite coverage and inconsistent AIS transmission rates may limit our ability to identify long periods in which vessels are in immediate contact (see data caveats below). We filtered our results to include only events where one of the vessels was a refrigerated cargo vessel and the other a fishing vessel. This left us with 5,065 encounters between reefers and fishing vessels, or “likely transshipments,” from 2012 through 2016.

Rendezvous Behaviour by Reefers
Refrigerated cargo vessels exhibit specific rendezvous behaviours during transshipments. We identified these behaviours by analysing known, observer-reported transshipments from the Indian Ocean Tuna Commission (IOTC; 5,874 transshipments between 2009 and 2015). Through our analysis, we identified reefers that exhibited similar patterns of moving less than 2 knots for longer than 8 hours. Distinctive C-shaped tracks and abrupt shifts in course following a period of slow speeds characterised most transhipment events. Following these metrics, we analysed 117 million reefer positions from 2012 - 2016 and identified 86,490 events where a refrigerated cargo vessel exhibited these behaviours, which we identify as “potential transshipments.”

Not all of these rendezvous events are transshipments of fish. Some may represent transfers of fuel or cargo, and others may be the reefer simply waiting until it is scheduled to travel to its next location. Future research will estimate the fraction of these loitering events that are transshipments of fish. For this report, we present these events as a proxy for transhipment of fish at sea, recognising that it is not a one-to-one relationship.

For this report, we call an event where a reefer encounters a fishing vessel a “likely transhipment” and an event where a reefer exhibits rendezvous behaviour a “potential transhipment.” Our set of “likely transshipments” is a subset of “potential transshipments.” In nearly all cases, we are not able to verify whether the transhipment actually occurs. Any reference to transshipments throughout this report is simply where we see likely or potential transhipment behaviour in our data. Also, we identified several thousand instances of reefers meeting up with non-fishing vessels, or meeting up with other reefers. For this initial report, we exclude these events, and focus only on fishing vessel-reefer encounters.

We also did not investigate transhipment between different fishing vessels.

We restricted our analysis to events occurring at least 20 nautical miles from shore to avoid capturing encounters occurring in ports. This distance is still well within the 200 nautical mile limit of EEZs. Future analysis will consider the distance from port instead of distance from shore so as to capture vessels close to shore but far from the port.

One data challenge is due to the limitations of the satellite receivers used to detect AIS signals. Satellites can fail to receive messages from fishing vessels for two reasons:

  1. High vessel density: A satellite can only record a limited number of messages at once, and when there are too many vessels beneath a satellite, some AIS signals are not recorded. As a result, in areas of high vessel density such as the South China Sea or regions off the coast of Europe, we cannot observe a vessel’s movements as accurately.
  2. Satellite coverage: Based on the number of satellites and their orbital patterns, there can be several hours a day when there is no satellite overhead to receive signals.

Fortunately, these limitations are being addressed by the launching of more satellites. In 2012, only two Orbcomm satellites, the satellite provider for Global Fishing Watch, were operating, and now 18 are in orbit. Also, these limitations do not apply along the coastlines of most developed countries, where terrestrial antennas, which are not as affected by vessel density, are present.

In addition, some vessels will not appear in the dataset for the following reasons:

  1. Vessels may intentionally turn off their AIS transmitters.
  2. Vessels may not have AIS at all. Regulations vary by country, and in international waters, vessels under 300 gross tons are not required to use AIS.
  3. AIS transmitters vary in quality, which results in patchier coverage of vessels with poorer quality hardware.
  4. Some fishing vessels use invalid Marine Mobile Service Identity (MMSI) numbers. For this analysis, we ignored these vessels, as they are difficult to identify. Doing so excluded less than one percent of our total encounters.

We have observed fishing vessels turning off their AIS in some areas of significant transhipment, including near the coast of West Africa, outside the Argentinean EEZ, and in some parts of the Indian Ocean. In future analysis, we hope to quantify this disabling of AIS and determine if it related to transhipment.

While some fishing vessels turn off their AIS from time to time, the practice is significantly more rare among reefers. We analysed all the gaps in transmission from reefers that started and ended more than 10 nautical miles from shore and lasted more than 24 hours, and found that these gaps represented only a small percentage of the total time reefers were active. We estimate that reefers in our dataset only show 24 hours or longer gaps in their track approximately 2 percent of the time while at sea. Therefore, we are confident that the AIS data for refrigerated vessels captures the majority of their footprint.

Transhipment is Most Common in the High Seas and Russian EEZ
About 43 percent of the likely and potential transhipment events happen in the high seas, with the remaining 57 percent within EEZs of different nations. About a third of the total events occur in the EEZ of Russia, where transhipment appears to be a standard part of how their fishing fleet operates. After the high seas and Russia, transhipment is most common in the EEZs of Africa and Oceania.


Very little news on the US Seafood Import Monitoring Program starting next year by Francisco Blaha

I wrote before about the US Seafood Import Monitoring Program (SIMP), when the news came out, when some more explanations appeared, when the US industry took and NOAA to court about it.  I have to admit that for a system that will affect the seafood trade of the entire world, very little has been published or made known.

Besides the implementation guts of the system, we don't know if the legal challenge would change things and which way, now that Canada has also expressed their doubts.  Furthermore, being this an initiative of the Obama administration, chances are it can be cut off by the new lot, as they did with the climate change mitigation policies. 

Like we don't have enough problems with one half cooked catch certification programme...

Like we don't have enough problems with one half cooked catch certification programme...

A very small (5 pages) compliance guide, that recycle a lot that has been written already plus a few more details has been recently published by NOAA. I posted some of the main elements below... but don't be too hopefull, ain't much there. Many of the fears I had at time comments were requested in early 2016 still not explained

Based on our experience with the EU one, I don’t think that is enough, and they should get some group to do an impact study and to assess all the possible way in which the system can be used from the fishing boats up. We don't need another system with substantial changes of interpretations a few months after implementation that finish in an incomplete system like it happened with the EU one. 

To whom does the Program apply? 
The Seafood Import Monitoring Program requires additional data to be reported at the point of entry into U.S. commerce or retained by the importer of record for imported fish and fish products identified as priority species due to the risk for IUU fishing and seafood fraud activities. Importers of record are identified to U.S. Customs and Border Protection (CBP) on each entry filing. The U.S. importer of record will be required to obtain an International Fisheries Trade Permit (IFTP) from NOAA Fisheries to report certain harvest information at the time of entry filing, and to keep records regarding the chain of custody of the fish or fish product from harvest to point of entry into U.S.

Which species will be affected by this Program?
Thirteen species were identified as particularly vulnerable to IUU fishing and/or seafood fraud and therefore covered by the first phase of the Program, which is intended to expand in the future to cover all seafood:

  • Atlantic Cod
  • Blue Crab (Atlantic)
  • Dolphinfish (Mahi Mahi)
  • Grouper
  • King Crab (red)
  • Pacific Cod
  • Red Snapper
  • Sea Cucumber(Beche-de-Mer)
  • Sharks
  • Swordfish
  • Tunas: Albacore, Bigeye, Skipjack, Yellowfin, and Bluefin
  • Abalone and Shrimp (at some stage in the future)

What information is being required to be reported at the point of entry into U.S. commerce or retained by the importer of record for imported fish and fish products? 
The information to be collected includes: 
Harvesting or Producing Entity

  • Name and flag state of harvesting vessel(s) 
  • Evidence of authorization to fish (permit or license number) 
  • Unique vessel identifier (when available) 
  • Type(s) of fishing gear 

Note: The fishing area and type of fishing gear should be specified per the reporting convention and codes used by the competent authority exercising jurisdiction over the wild capture operation. If no such reporting requirements exist, the Food and Agriculture Organization (FAO) fishing area and gear codes should be used. 

Harvest Event – What, when and where

  • Species—FAO 3-Alpha Species Codes (Aquatic Sciences Fishery Information System - ASFIS) 
  • Harvest date(s) 
  • Product form(s) at time of landing - including quantity and weight of product 
  • Area(s) of wild-capture or aquaculture harvest 
  • Point(s) of first landing 
  • Name of entity(ies) to which the fish was landed or delivered 

Note: In cases where the imported shipment is comprised of more than one harvest event, each event that is relevant to the shipment must be reported. However, the importer does not need to link a particular fish or portion of the shipment to any one harvest event. 

Importer of Record 

  • Name, affiliation and contact information 
  • NOAA Fisheries issued IFTP number 
  • Importer of record is responsible for keeping records regarding the chain of custody detailed above. 
  • Information on any transshipment of product (declarations by harvesting/carrier vessels, bills of landing) 
  • Records on processing, re-processing, and commingling of product. 

What is the criterion to judge whether a product is included under SIMP?
The criterion to judge whether a specific fish product is included under the initial phase of SIMP is the Harmonized Tariff Schedule (HTS) Code used to file an electronic entry for the import shipment. NOAA Fisheries will provide to CBP a list of required data elements for each species under the HTS codes covered by SIMP. An updated list of HTS codes subject to SIMP will be posted soon under the message set implementation guide for NOAA Fisheries at:

How will this information be collected and reported? 
The collection of harvest and landing documentation for these priority seafood species will be accomplished through the International Trade Data System (ITDS), the U.S. government’s single-window data portal for all import and export reporting (maintained by CBP). Import harvest and landing data will be submitted through ITDS “message sets” at the time of entry, while chain of custody records for the fish after landing will be transferred through the supply chain and maintained by the importer of record. Importers of record are the U.S. entities taking responsibility for the import under U.S. Customs regulations and will be required to hold an IFTP issued by NOAA Fisheries. 

When will the Automated Commercial Environment (ACE) programming be released?
NOAA Fisheries is working with CBP to program the ACE portal for the pilot test. As soon as the programming has been certified, we will announce a pilot test in the Federal Register. 

What is the language of record for record-keeping? 
The U.S. importer of record must be able to personally review and verify the accuracy of recordkeeping documents regardless of language. Translation of recordkeeping documents into English is not a requirement of the Program but as noted above, must be reviewed and understood by the U.S. importer of record. 

How do I obtain an International Fisheries Trade Permit (IFTP)? 
The International Fisheries Trade Permit may be obtained at:  

Will product from each and every harvest event need to be segregated through processing and shipment in order to be traced back from point of entry? 
No— the segregation of harvest events through the supply chain is not required. An imported shipment may be comprised of products from more than one harvest event. In such instances, an importer of record must provide information on each harvest event relevant to the contents of the product offered for entry, but does not need to specify which portions of the shipment came from particular harvest events. 

How will the data collection requirements be applied to small-scale fisheries? 
The Program exempts an importer from the requirement to individually identify small-scale vessels—or small scale aquaculture facilities—if the importer provides other required data elements based on an aggregated harvest report. Aggregated harvest report is defined as a record that covers: (1) harvests at a single collection point in a single calendar day from small-scale vessels (i.e., twelve meters in length or less or 20 gross tons or less); (2) landing by a vessel to which catches of small-scale vessels were made at sea. 

Are all products containing priority species included? 
No. The reporting and recordkeeping requirements will not be applied to imports of certain highly processed fish products, including but not limited to fish oil, slurry, sauces, sticks, balls, cakes, puddings, and other similar highly processed fish products, in cases where these products cannot currently be traced back to one species of fish or a specific harvest event(s) or identified through product labeling. The specific HTS codes for which the program applies are listed in the NOAA Fisheries Implementation Guide at:

Does this Program require any labeling modifications? 
No. The Seafood Import Monitoring Program is not a labeling program.

Does the Program apply to U.S. domestic seafood? 
U.S. domestic regulations are already in place requiring that catch and landing information for domestically caught seafood is reported to NOAA Fisheries. The rule establishing the Seafood Import Monitoring Program applies only to seafood entering the U.S. from a foreign country. 

Does the Program apply to domestically harvested seafood that is subsequently sent to a foreign facility for processing and/or storage and later imported back into the U.S.? 
Yes, it does. No exception for domestically caught seafood is made. Fish or fish products initially harvested in the U.S., but subsequently sent to a foreign country for processing, reprocessing, and/or storage prior to being sold in the U.S. are subject to reporting and recordkeeping requirements of the Seafood Import Monitoring Program for re-entry into the U.S. 

Some tuna products are already under existing regulatory reporting requirements for imports, how will they be impacted by the Seafood Import Monitoring Program? 
NOAA Fisheries has established harmonization of recordkeeping and reporting requirements of the Tuna Tracking and Verification Program used to document the harvest of tuna products being sold or exported using the dolphin-safe label includes many of the harvest, landing, and chain of custody elements included in SIMP. Implementation of the Seafood Import Monitoring Program data requirements will not create redundant reporting and recordkeeping requirements for importers of tuna products. Rather, the ITDS business rules will be written to ensure that each data element is reported only once in a given case. In order to ensure parity among the two programs, NOAA Fisheries may revise the Tuna Tracking and Verification Program to reflect new reporting and recordkeeping requirements as appropriate. This may also be the case for imports of swordfish and certain species of tuna covered by existing international statistical document or catch documentation programs. 

Will the data reporting and filing requirements of this rule be a matter of public or consumer record? 
The information collected under this program is confidential. SIMP establishes a business-to-government reporting system to allow U.S. government agencies to confirm the legality of imported fish and fish products. To address concerns about data confidentiality, data security will be given the highest priority throughout this process. Information collected via ACE and maintained by CBP systems such as ITDS, is highly sensitive commercial, financial, and proprietary information, and is therefore generally exempt from requirements for public disclosure (for example, the Freedom of Information Act). 

What is the effective date for implementation of the Program? 
Compliance with reporting and recordkeeping requirements in the rule for priority species other than shrimp and abalone will be mandatory starting January 1, 2018. As of the effective date, entries under the specified HTS codes subject to the program will require the message set and the U.S. importer will be required to have a valid IFTP. Entries subject to the Program that are filed without a complete message set (harvest event data and IFTP number) will be rejected and won't be released by CBP until the message set and IFTP number are provided. 
Because imported fish entered into U.S. commerce on or after January 1, 2018 will have been harvested prior to that date, the harvest event message set will pertain to fishing activity that occurred in advance of the compliance date. U.S. importers must work with suppliers to ensure that information on the harvest event exists for any product in the supply chain that will be entered after the compliance date.

Will there be any assistance provided toward complying with this rule? 
Subject to the availability of resources, NOAA Fisheries and the broader U.S. Government intends to provide assistance to exporting nations and domestic imports to support compliance with the requirements of the rule, including providing assistance to build capacity to: 

  •  Undertake effective fisheries management; 
  •  Strengthen fisheries governance structures and enforcement bodies to combat IUU fishing and seafood fraud; and 
  •  Establish, maintain, or support systems to enable export shipments of fish and fish products to be traced back to point of harvest. Priorities for capacity building are identified in a Strategic Action Plan for Building International Capacity to Strengthen Fisheries Management and Combat IUU Fishing 

Who can I contact if I have further questions? 
Information and materials about the final rule are posted to  
 For questions related to requirements of the SIMP, contact  
 For questions related to the use of the ACE or ITDS, contact  

Incorporating carbon footprints into seafood sustainability certification and eco-labels. by Francisco Blaha

I like reading because it makes me think, and I like thinking. This week a recent paper from Marine Policy by two Australian authors (Elizabeth M.P. Madin and Peter I. Macreadie) touched on a couple of issues I blogged before, carbon footprints and life cycle assessment. Since more and more we are expected to pay a premium for ecolabeled products (wich are a private business), I like to see that the assessments are "totally encompassing or we stay as we are. 

from the original paper

from the original paper

There a couple of areas I struggle with ecolabels and this is one of them, all the schemes avoid fully incorporating these topics. The other one I struggle more is flag state performance and the compliance index (or history) of the vessels in the assessment unit… but this is a topic for another blog

I quote parts of the paper below (go to the link above for the full version), the numbers you see in the text are the bibliography in the original.

The seafood industry has become increasingly interconnected at a global scale, with fish the most traded commodity worldwide. Travel to the farthest reaches of the oceans for capture is now common practice, and subsequent transport to market can require hundreds to thousands of miles of travel by sea and air. Refrigeration of seafood products is generally required at all stages of the journey from ocean to dinner plate, resulting in substantial energy expenditure. Energy input for aquaculture (including mariculture) products can also be high, namely due to the large amounts of feed required to support fish growth. As a result of these factors, the seafood industry has a substantial carbon footprint. Surprisingly, however, carbon footprints of seafood products are rarely integrated into assessments of their sustainability by eco-labels, sustainability certification, or consumer seafood sustainability guides. Suggestions are provided here for how carbon footprints could be incorporated within seafood sustainability schemes.

Incorporating carbon footprints into seafood sustainability
This study proposes another important way in which seafood awareness campaigns can be improved: through explicit consideration of the carbon footprint of seafood products. Including carbon footprints into their certification criteria would provide a more holistic basis for consumers and businesses to assess the sustainability of seafood products. This proposition is in line with recent calls by leaders in the field for seafood awareness campaigns to include the full seafood-production process into sustainability assessments [9] and has been suggested as a useful next step for wild-caught seafood eco-labels [10]. Explicitly considering carbon footprints would allow these campaigns to have a potentially far more powerful net effect by not only helping to mitigate specific environmental impacts of each fishery, as many currently aim to do, but would broaden their impact to confronting the global-scale problem of climate change. Given the substantial per-unit-product carbon emissions of fisheries, this is an area of environmental sustainability in which consumer and business choices could potentially have a large impact.

While a number of “single-issue” carbon footprint eco-labels for other industries have been implemented – i.e., those that specify the exact or relative carbon footprint of a product and rank it on this basis only – it is suggested that this measure should be considered alongside other key sustainability criteria to generate a robust measure of a seafood product׳s overall sustainability. To our knowledge, only one international seafood awareness campaign, Friend of the Sea, explicitly incorporates carbon footprints into its selection criteria and one smaller-scale domestic seafood eco-label, Swedish KRAV [4], does so. While many campaigns have energy and pollution consideration built into their assessment criteria [9], none of the most widely recognised or scientifically rigorous campaigns, including the world׳s largest by far (Marine Stewardship Council, or MSC), incorporate climate effects in any explicit fashion. Nonetheless, the idea of incorporating carbon footprints into the criteria used in these campaigns has the support of at least one major international conservation NGO, the World Wildlife Fund (WWF; [11]). Likewise, Food and Water Watch, an environmental and consumer rights NGO organisation, has identified this gap as a concern with existing seafood eco-labels [12]. Given recent calls for overhaul of, for example, the MSC certification programme [13], as well as calls for integrating other sustainability criteria (such as pre-emptive credits for fisheries that set aside no-take areas [8]), inclusion of carbon footprints into its criteria would seem an obvious and important step towards increasing its potential to ensure environmental sustainability.

Benefits and methods of integrating the carbon footprint
Inclusion of carbon footprints into seafood awareness campaigns could potentially have a number of key benefits on both the consumer and producer ends of the seafood industry. First, giving consumers and businesses (e.g., restaurants) information about the relative contribution to climate change that one product has versus another may promote lower carbon footprint products (e.g., by shifting buying towards locally-produced seafood (Fig. 2c)) or, conversely, towards imported products that have a lower carbon footprint than locally-sourced products (e.g., Fig. 2d). This could come about through a number of mechanisms. Limited evidence suggests that giving consumers access to information about other aspects of seafood sustainability can lead to preferential buying of lower-environmental impact products when presented with a range of choices varying in environmental impact [14]. Conversely, consumers׳ choices can be constrained through retailers stocking only “sustainable” seafood products. Evidence to date suggests that the latter mechanism may be more likely to have a substantial impact on consumption patterns, given that uptake of seafood eco-labels by a number of major retailers has already occurred and continues to grow [e.g., Wal-Mart, Whole Foods, Tesco (but see [18]); [9]]. By including carbon footprint criteria, these actions could potentially increase both consumer and industry awareness of the impact of the seafood industry on climate change, opening up the potential for specific fisheries to consider if and how they could modify operations to achieve lower carbon footprints and thus potentially greater demand by retailers and/or consumers.

A seafood product׳s carbon footprint can be measured through life cycle assessment [4]. This assessment results in a net carbon contribution of a specific product, from “cradle to grave”, for a given point of origination and point of sale (e.g., [4]). Carbon footprints could be integrated into existing sustainability certifications, eco-labels, and/or consumer guides via regionally-specific labels or guides. At least one major, scientifically-robust consumer guide (the Monterey Bay Aquarium׳s Seafood Watch guide) already produces regionally-specific guides for different areas that reflect the regional availability of different seafood products. Carbon footprint could be added as an additional criteria calculated as an average over spatial scales that match these existing regional guides, for example. Alternatively, campaigns could provide consumers, retail businesses and seafood producers with information tables of various products׳ estimated carbon footprints to cover various combinations of points of origin and sale. One seafood certification organisation, Friend of the Sea, has done so partly by devising a carbon footprint calculator. This tool allows users to input distance travelled and method of transport and subsequently returns the product׳s transport-generated CO2 emissions [15]. This organisation further provides the option for fisheries to buy carbon offsets (through the organisation), in turn receiving “credits” towards reducing their carbon footprints that are presumably reflected in their calculator. Various other possible methods of carbon footprint integration could be tailored to other existing seafood awareness campaigns or integrated from the outset in future campaigns.

Key considerations and limitations
As with any change to the status quo, a number of challenges must be considered with regard to incorporating carbon footprints into seafood awareness campaigns. Indeed, each stage of the carbon labelling process raises issues which must be addressed, such as agreeing upon a standard methodology for calculating carbon footprints (e.g., life cycle analysis, or LCA), collecting adequate and reliable data, establishing a trusted verification process, and determining how best to present carbon footprint information to consumers and businesses within a sustainability certification, eco-label, or consumer guide. In many cases, even with a standard methodology, a lack of product-chain information could hamper efforts to calculate a carbon footprint in the first place [16]. On a related note, as with the information given in most types of non-eco-labels, the accuracy of the carbon footprint component of any eco-label or sustainability guide would be difficult, if not impossible, for consumers to check. Another challenge faced would be how to weight the carbon footprint component of a given campaign against the other environmental measures it considers (e.g., fisheries’ harvest sustainability and other environmental criteria [4] and social development and economic considerations [9]). One possible solution to this issue is for international campaigns to tailor the specific weighting of carbon footprint versus other criteria to individual countries or regions, as has been done with the Forest Stewardship Council׳s criteria [17]. Lastly, the cost of generating the carbon footprint information for any given product will be an important consideration for its ultimate feasibility. As an example, UK׳s supermarket-giant Tesco recently dropped its highly-publicized adoption of the Carbon Trust׳s carbon reduction label on many of its products, citing the prohibitive time and costs involved in researching products׳ carbon footprints [18]. Likewise, only a tiny fraction of small-scale fisheries from developing nations, which collectively make up the majority of fisheries worldwide [7], are currently certified by MSC [13] – a likely consequence of the prohibitively high cost of becoming certified. The cost of adding yet another certification criteria, such as carbon footprint, would need to be factored in so as not to further this imbalance.

Moving forward
This study has proposed that integrating carbon footprints into existing and future seafood awareness campaigns would create more holistic yardsticks by which the environmental impact of fisheries products can be assessed by consumers, retail businesses and producers. Emerging technologies and tools, such as the recently launched Global Fishing Watch (, will increasingly facilitate accurate calculation of specific seafood sectors׳ – and even potentially individual vessels׳ – carbon footprints. The debate surrounding the inclusion of carbon footprints into sustainability campaigns in other industries is recognised – namely, that inclusion of carbon accounting into existing sustainability certification programs may overshadow other environmental and/or social objectives – and seafood awareness campaigns can learn from these industries׳ dialogues. The inherent interrelatedness of fishing pressure and climate change on fish stocks has led to calls for them to be addressed jointly [19]. This study proposes that seafood awareness campaigns provide one avenue for doing so. Importantly, both the scale of international fisheries trade (e.g., [3]) and the potential effects of future climate change on increasing variability in fisheries stocks [19] suggests that sustainability campaigns within the realm of the seafood industry have both substantial responsibility and incentive to be at the forefront of this new approach.

The PNG FAO – PSMA workshop by Francisco Blaha

It has been a good week here in PNG. The FAO – PSMA workshop included over 50 people from all the line agencies that are involved in the process of having fishing vessels arriving into a port. While well hosted by NFA (the Fisheries Authority) it included ports authority, customs, maritime safety, quarantine, navy and maritime police. Since all these organisations have a role and a mandate over the process.

lets go on board

lets go on board

The team from FAO that run it is top notch Pio Manoa is Fijian lawyer that is now based in Rome after working for FFA, the USP and many others, we had also Matthew Camilleri who has been FAO PSMA master for a few years now and is at helm of the advances over the last few years. It has been a pleasure to be working with both of them and I hope they enjoyed working with me.

The logistics were clever with not a lot of presentations, but a lot of interactions, working groups and visits to vessels in Raboul lagoon

we still on paper, but not for long :-)

we still on paper, but not for long :-)

I think that everyone got some really positives inputs and lot to think on the way home, yet on the other side our work with the CDS has incorporated a lot of the PSM principles already.

I talked many times about how fascinating and challenging is to work in PNG, I been coming here for 19 years, which is almost half the history of the country… 800 cultures trying to strengthen their identity as a nation implies a lot of challenges. Therefore challenges are nothing new for PNG, I always joke that here in PNG we have challenges for breakfast!  An my local colleagues will, as always rise to the challenge, in their own way

What a place for a group picture

What a place for a group picture

Back in PNG with FAO and Port State Measures by Francisco Blaha

I have been coming to PNG since 1999 and the place and people here have a special place in my hearth. I go back a long time with many people in NFA (National Fisheries Authority) and I see many of them as extended family, I know their family, they know mine, I been to their house, they have been to mine.

I think that those human connections are the key part of the job, since they mean trust. So I was quite happy to be invited to be part of a mission with my former colleagues in FAO to deal with a topic that is an integral part of my CDS and MCS work: Port State Measures Agreement.

The PSMA needs to approached with care, not because there is anything wrong with its principles (all the opposite), but because developing countries should move progressively towards it as not to “choke” with all the requirements and then go backwards with the steps done.

Using another analogy: PSM is a tool… and you need to know how to use the tool before trying to fix a car with it after taking from the box.

And is not an easy task, legislation need to be updated, logistics of vessels arrival, notifications, intelligence work prior use of port authorization, inspection capacity and enough people to do it, communication, reporting capacity and many more issues.

Also, you need to draw some lines on the sand, one can interpret it that the use of, and access to, ports should be denied irrespective of the gravity of the illegal activity… and while this is a potent tool to force change, has implications for developing states particularly if the measures are not taking regionally, as the boats can travel to another nearby state and have it “easier” there.

There are considerations when countries like here in the pacific have overlapping requirements as part of the WCPFC and their membership with FFA and PNA.

The reporting alone can be quite complex, as there are quite a few parts to please.

Some worry that it can be felt that small states are “subsidising” the poor flag state performance of most DWFN. Most vessels transhipping and unloading in the region are not flagged here, so it kinds of become the “obligation” of the port state to “police” them. And while one could argue that is in the coastal/port states interests to do so, this still is huge stretch for many fisheries administrations, plus the basic issue that for example Philippines, Taiwan, Korea, etc. should be taking care of their vessels and not PNG or the Solomons… they have a job to do, but the ultimate responsibility is in the flag state… and we all know how “responsible” they are.

Also, any measure taken by individual countries may loose strength if is not reflected by regional neighbours, and when you have a very different variety of resourcing and capacities (beyond political wills), the scenario can become really complex, even if all good intentions are there.

So yes, this are only some of the considerations I’ll need to take care, beyond the capacity building, the operational considerations and the IT structure behind all these.

Yet PNG has faced many challenges before and it keeps dealing with them with principle and pride, so I’m very much looking forwards to be involved with them once more


On the EU yellow cards by Francisco Blaha

I wrote many times before about the EU IUU Regulation (EC No 1005/2008), the Catch Certification Scheme (CCS) and yellow and red cards the EU has been delivering around. My 1st contact with this regulation was when 2008, 2 years before its entry into force, and since then I been working with it at various levels.

It is important to understand that the EU IUU Reg has as its implementation tool, the Catch Certification Scheme, while the “yellow and red card” is a football analogy to the process that the EU DG MARE enters when it invokes Chapter IV of the regulation with “non-cooperating third countries”.

Sri Lanka went to Red

Sri Lanka went to Red

While being a unilateral measure (meaning that it just intends to close only its market to IUU fish), the legislation brought the IUU issue to the public forefront and always recognised that is a very good thing. Its implementation tool never lived to its full potential due to profound flaws in its design and implementation. A group of us have been very vocal about this for years, and I was happy to see that that message has finally been taken by EU based NGOs. My criticism was always constructive and not against the legislation or the CCS, but aimed at maximising its benefits... yet 7 years after its implementation, the key flaws still have not been fixed.

The “cards” analogy is perhaps the most visible element of the regulation application. The effectiveness of the strategy has worked in some of the countries that have been “given a card”, the “shaming” and the possibility of having the products caught by its vessels barred from the EU market is an effective way to get them into action, no doubts there.

Furthermore, over the last 7 years, at least a big chunk of my work has been helping countries to deal with the legislation and the cards, and most of that works has been paid with EU funds. And in that aspect the EU is unique as it consistently supports developing countries with strengthening programmes, this is to be recognised (and I’m grateful for that).

Criticism is valid tho, on the way and reasons those cards have been handled. My good friend and colleague Gilles Hosch has  encapsulated that criticism in a direct way (as usual), during his response to an article (actually more like a copy of the EU press release), in a leading fisheries news website announcing the lifting of the yellow card to the Solomons (a place very close to my soul and were I spend over 2 years working on this process), criticizing the lack of journalistic depth around this issue. I quote him textually: 

"What I find striking in news items relating to EU yellow, red and green cards – such as this one above – is the complete lack of journalistic curiosity and scrutiny regarding the seemingly random selection by the EU of so-called “third” countries, threatening them with trade sanctions for their perceived lack of commitment to combat IUU fishing. Does it ever occur to anybody that 38% of all south-west Pacific island nations have been yellow-carded under the EU IUU regulation – when only 24% of countries in Asia, and 0% in South America, the near east and in Europe have been objects of such cards? Yes, of course it is nice for the Solomons to have that threat lifted – as it would be for any ACP country totally dependent on the EU seafood market for the continued survival of its export sector – but would it not be equally important to question how it is possible that small countries like the Solomon’s are serially pre-identified by the EU commission, and threatened with the extinction of their seafood trade sectors, while other major fishing nations – in their role as recognised state-sponsors of international IUU fishing ventures – are never even making it onto the EU radar!? I am missing the elements of critical and vital news reporting here"

And yes, it is hard to disagree. The initial targets have been very soft, the yellow card to Tuvalu (10000 inhabitants and 2 vessels) is quite puzzling. 

I did got hopes with Philippines and Korea, yet they got off very easily, and I have not noticed any changes regarding behavior or compliance history for their vessels operating in the Pacific.

The hopes rekindled when Taiwan and Thailand got cards (even if in the case of Thailand would not mean anything unless they are in connection with the sanitary side, as Thailand has no tuna boats). Yet not news are heard for a while out of them.

And as Gilles mention what happens with the other ones? 

Vietnam has abysmal flag state performance record with dozens of their boats been arrested in other jurisdictions… surely they would benefit of being pushed to act.

I work substantially in Latin America (as recent as last week), they as a whole must be the main exporter of fisheries products to the EU by volume and value. The evaluations we did in 2011 showed all sorts of issues, and there are no objective reasons to assume that they fisheries administrations and enforcement bodies are insulated of the otherwise well-known corruption culture that permeates their governments... but not even one yellow card. 

And then is China, by far the nation that has been involved in more IUU fishing events worldwide, had vessels sunk, arrested, detained, notorious flag hoppers and the lot... yet not one visit has been raised.

I know Brussels takes their time and if you gonna go in the fight, is better to do sparring first, the problem is that if they don’t go with the good fight to an equal size opponent, they are going to be seen as a bully and not the good guys they want to be.

Can the United States have its fish and eat it too? by Francisco Blaha

A recent paper caught my attention a few days ago. In the present situation of unilateral marine management policies that force greater reliance – and biodiversity impacts – on distant ecosystems, the authors call into question their global effectiveness and conservation from an ethical point of view. The paper has 3 NOAA employees as authors (one is retired), one of them Stephen Stohse, was kind enough to send me the paper.

I would like to have the time to do similar work with the EU approach (and with ecolabels), I’m sure the results will be in the same line, rich countries make a “firewall” around them and say, “we play our part because we can”, that way placating their “conscience” and pass the bucket down to the poor.

I quote below some parts of the paper that impacted me (the numbers refer to the bibliography)

As domestic affluence increases, nations advocate for conservation policies to protect domestic biodiversity that often curtail natural resource production activities such as fishing. If concomitant consumption patterns remain unchanged, environmentally conscious nations with high consumption rates such as the U.S. may only be distancing themselves from the negative environmental impacts associated with consuming resources and commodities produced elsewhere. 

This unintended displacement of ecosystem impacts, or leakage, associated with conservation policies has not been studied extensively in marine fisheries. This paper examines this topic, drawing on case studies to illustrate the ways in which unilateral marine conservation actions can shift ecosystem impacts elsewhere, as has been documented in land use interventions. 

The authors argue that the U.S. should recognize these distant ecological consequences and move toward greater self-sufficiency to protect its seafood security and minimize leakage as well as undertake efforts to reduce ecosystem impacts of foreign fisheries on which it relies. 

Six solutions are suggested for broadening the marine conservation and seafood consumption discussion to address leakage induced by U.S. policy.

1. Introduction
Due to the spatial separation of production from consumption activities, consumers in higher-income countries may be unaware or otherwise fail to account for the full environmental costs caused by the production of goods they utilize [9]. These negative environmental externalities, or impacts which manifest outside existing borders, are referred to as “leakage”,2 of which there are four types: conservation, production, consumption, and trade. Conservation leakage results when domestic measures to conserve resources lead to negative environmental impacts from an increase in foreign production to meet persistent demand; production leakage arises when regulation of domestic producers results in a transfer of production effort to foreign producers; consumption leakage results when unmet internal consumption demand is satisfied by external supplies (e.g., imports); and trade leakage results when an import ban from particular industries causes a redirection in the flow of trade to other consumer markets Leakage related to land use including forest conservation policies has been well documented at local and national [12–16] and at international [17–20] scales. Similar efforts to evaluate leakage caused by marine conservation policies affecting U.S. fishery production systems (i.e., the capture or culture of finfish and shellfish resources) are limited (i.e., [21–25], even though the U.S. continues to be a major importer of seafood [26], ranked second only to Japan for all fishery and fishery product imports [27].

A recent debate has emerged over whether U.S. marine conservation policies3 that curtail fishing activities externalize negative environmental impacts of U.S. seafood consumption to other jurisdictions.
Some conservation policy advocates argue that marine conservation efforts in the U.S do not redistribute ecosystem impacts.4 However, the potential for transnational leakages seems probable when U.S. consumers rely on fishery production systems beyond the reach of U.S. management authority. Given international trade in seafood products, a unilateral conservation regulation that reduces production in one nation's fishery can be met by increased production in another nation where such conservation measures may be less stringent, thereby offsetting the environmental protections in the regulated fishery. Furthermore, the limited availability of information on such conservation leakage impacts makes them difficult to detect - much less address.

4. Leakage related to U.S. fisheries
Leakage occurs in a given fishery or fisheries when production impacts such as overfishing, habitat degradation, or bycatch are curtailed by regulations resulting in reduced supply in one area and a shift in production to other less regulated areas. 

For example, regulatory policies to address sea turtle bycatch in the Hawaii swordfish fishery provide an example of multiple types of leakage occurring concurrently. Both swordfish and sea turtles are trans boundary (transnational) resources and vulnerable to multiple fleets serving global seafood markets. Concerns about domestic bycatch of leatherback and loggerhead sea turtles led NOAA's National Marine Fisheries Service (NMFS) to close the Hawaii swordfish fishery in 2001. The fishery was reopened in 2004 with several additional technological and administrative requirements. Sarmiento [21] measured trade leakages (i.e., transfer effects) generated by the closure and determined that imports of swordfish from other nations, primarily Ecuador and Panama, increased appreciably. Rausser et al. [22] calculated conservation leakage resulting from the closure, with an estimated increase of 1602 mt of swordfish imported annually due to the closure, resulting in an estimated 2882 additional (net) sea turtle interactions from the swordfish fisheries of foreign nations combined.

In a similar study, Chan and Pan [24] examined the period when the Hawaii shallow-set longline swordfish fishery reopened (2005– 2008), and estimated that the increase in average annual Hawaii swordfish production contributed to 1841 fewer turtle interactions worldwide by displacing imports from fisheries that had higher sea turtle bycatch rates. They concluded that the regulatory changes reducing Hawaiian swordfish production did not reduce total regionwide sea turtle bycatch because the Hawaii fleet has one of the lowest sea turtle bycatch rates among the fleets fishing in the region [41].bInstead, with the reduced swordfish production from Hawaii's fleet, foreign fleets increased their harvests to maintain overall production, resulting in a net increase in sea turtle bycatch.

Squires et al. [25] provide another example of leakage associated with a time-area closure in the West Coast drift gillnet (DGN) swordfish fishery. In an effort to reduce fishery interactions with the endangered leatherback sea turtle, NMFS established the Pacific Leatherback Conservation Area (PLCA), which overlaps substantially with the DGN fishing grounds along the U.S. West Coast. Since 2001, this time-area closure has prohibited DGN fishing for three months during the prime swordfish fishing season. The authors’ benefit-cost analysis of the regulation's impacts determined a U.S. production leakage of $27.5 million due to lost producer and consumer surpluses in the West Coast fishery with increased imports. In addition, the transfer of swordfish effort to other Pacific Rim nation swordfish fleets is estimated to have caused a conservation leakage of an additional bycatch of 1457 endangered leatherback sea turtles compared to 45 turtles had the U.S. fishing grounds remained open.

Policy-induced leakage is not limited to international contexts; it also can occur domestically. Cunningham et al. [42] reportedly found evidence of production leakage between two adjacent regions subject to management by two separate U.S. fishery management councils (FMCs) resulting from a catch share program. The authors assert that such leakage is most acute in fisheries with low institutional barriers, similar gear, and high market substitutability for managed stocks with other species.

5. Discussion
While documented examples in fisheries are rare, the foregoing examples suggest that market-driven, economically-based leakage can occur in fisheries when unilateral conservation policies are put in place similar to land use interventions. Marine conservation policies can stimulate resource production or exploitation activities in other locations, leading to production leakages in foreign [25] or neighbouring jurisdictions [42]. This finding is not surprising as a regulated decrease in production at one location coupled with unchanged demand is expected under standard economic theory and assumptions to shift demand to other locations, stimulating increased production and increasing producer revenues elsewhere. Wear and Murray [12] documented the case where U.S. Endangered Species Act (ESA)-driven restrictions on federal timber harvests in the Pacific Northwest implemented to protect northern spotted owl habitat redirected production to southern U.S. and Canadian lumber producers. Mayer et al. [17] demonstrated how the increasing demand for wood products along with new forest conservation programs in Finland increased pressure on forests in neighbouring Russia through wood imports.

The case studies also illustrate examples of trade leakages from increased imports [21], and conservation leakages from increased bycatch [22,24]. Consequently, reducing domestic production to achieve a particular conservation objective can lead to unintended negative consequences, reducing the net gains – and possibly increasing net losses – globally. Such outcomes suggest the need for multiple within- and across-border policy instruments to reach an optimum regulatory strategy.

The need for global cooperation has been recognized in fishery [43] and forest conservation efforts [18,44]. At the local and regional scale, policy-makers should be mindful of negative consequences that may arise from unilateral actions especially in the context of global markets and possibly weaker environmental governance in other locations. In particular, as part of the ESA and National Environmental Policy Act consultation processes, federal managers need to take leakage into account as part of the net effects analysis for any proposed Federal action.

In terms of marine biodiversity, conservation leakage is of particular concern because much of the seafood imported into the U.S. is believed to be harvested under less stringent conservation requirements than imposed on U.S. fisheries [49–51]. Such leakages could be minimized if there were greater reliance on countries with sustainable fishing practices and more importantly, on U.S. capture and culture fisheries. However, efforts for greater self-sufficiency can only succeed if there is a fundamental change in U.S. attitudes that reconciles marine conservation goals with the reality that eating fish means harvesting seafood somewhere, just as Berlik et al. [44] reasoned that using wood means cutting trees somewhere.

Such changes in attitude could begin with shifting from excessive or outright fishing prohibitions to finding ways to minimize domestic biodiversity impacts. For example, the PLCA closure was implemented as an avoidance strategy to prevent interactions between DGN gear and leatherbacks sea turtles. A more effective alternative might have been considering other gear types that produce a comparable volume of swordfish catch with lower sea turtle interaction rates. Such a tactic would have reduced the negative economic impacts to fishermen and the reliance on imported swordfish while still achieving conservation goals. 

Another approach could include transitioning from static management regimes to dynamic ones where fisheries are managed in real or near-real time in response to shifting oceanographic, biological and ecological conditions [52–55]. The use of adaptive tactics also could be adopted by other nations to enable compliance with proposed NMFS regulations prohibiting seafood imports that do not meet U.S. standards for marine mammal protection.

6. Solutions
Global demand for food is expected to continue increasing well into the second half of this century corresponding with continuing population growth [45]. Seafood consumption is expected to continue to rise at a faster rate than freshwater fish consumption in both industrial and developing countries [56]. Environmentally concerned U.S. consumers can distance themselves from leakage concerns by reducing their seafood consumption, albeit at the expense of foregoing the known health benefits derived from seafood [57]. Further, limiting consumption of fish may generate leakage into agricultural production systems, which can create other environmental externalities such as fertilizer and pesticide runoff, which degrades terrestrial, freshwater, and marine ecosystems. Alternatively, the U.S. can consider its own seafood security by moving toward greater self-sufficiency as well as undertaking efforts to reduce biodiversity threats in foreign fisheries it relies upon to meet domestic seafood demand. To meet these challenges, several approaches for addressing leakage are suggested:

1. Increase awareness of U.S. fisheries. Most Americans remain unaware of the high environmental standards by which U.S. federal marine fisheries – and many state fisheries - are managed, in compliance with multiple state and federal laws. These standards conform to or exceed internationally accepted guidelines for sustainable fisheries adopted by the Food and Agriculture Organization of the United Nations [58]. Sea Grant Extension Programs in U.S. coastal states and territories have conducted education and outreach, with NOAA Fishwatch and a number of nongovernmental organizations also helping to bridge this gap. However, further efforts to address this lack of understanding are needed.

2. Develop U.S. domestic aquaculture to complement capture fisheries. The global status of marine capture fisheries is considered stable; however, increased catches are considered unlikely [59], suggesting that aquaculture will need to play a greater role in seafood security [60]. Aquaculture is considered the fastest growing animal food production sector and supplies more than half of the world's seafood for humans [61]. While there has been a reluctance to embrace aquaculture more enthusiastically in the U.S. because of its own set of externalities (e.g., environmental impacts of fish feed, waste, disease control substances), it is a form of seafood production that can be managed for ecological and economic sustainability.

3. Support sustainable fishing practices in other nations. Such capacity- building efforts include transferring best fishing practices, technologies and monitoring practices to nations whose fisheries continue to supply U.S. markets. A few examples include NMFS programs for training Columbian fishermen on the effective use of turtle excluder devices in Caribbean and Pacific coast shrimp fisheries, instructing fishery observers in Ghana, Senegal, Sierra Leone, Liberia, and Gabon, and providing circle fishing hooks to South American countries.

4. Multilateral cooperation. Overarching World Trade Organization consistent trade laws and regulations can help address production and trade leakages and their negative impacts across the entire ranges of affected stocks. Policy instruments and harvest strategies addressing information requirements (e.g., eco-labeling, certification, standards, consumer awareness campaigns and similar approaches) on bycatch reduction can be designed to create market prices and conditions that address external costs and benefits. U.S. delegations participating in international regional fishery management organizations and other fora can initiate that dialogue.

5. Recognize the externalities of management decisions. Leakage occurs when the spatial scale of intervention does not match the scale of the targeted problem [62]. Ignoring environmental impacts associated with goods produced elsewhere creates what Berlik et al. [44] described for U.S. timber management as the “illusion of natural resource preservation.” Policy-makers need to be mindful of and evaluate the challenges and trade-offs among the full range of impacts, including those beyond their jurisdictions, as part of the decision-making process.

6. Treat wild capture and aquaculture fisheries as part of the food system. Seafood represents a part of the nation's food system [63,64]. Nonetheless, within the context of managing marine resources and ecosystem impacts, seafood rarely is acknowledged as a component of the human diet, despite its recognized importance as a source of nutrition and sustenance. Olson et al. [64] argue that treating seafood as a food production system provides a different frame of interpretation that does not end with harvesting but also includes distribution and use. Such a broader conceptualization can re-establish the connection between consumption and production behaviours, which underlies the reality that humans are part of the marine ecosystem.

7 Concluding remarks
The title of this paper plays on the popular 16th century English proverb questioning whether people can both have their cake and eat it too. This aphorism describes the challenge confronting fishery management decision-makers and seafood consumers. Reckoning with the inherent tradeoffs between conservation goals and seafood consumption demands may be a more practical approach rather than assuming “win-win” outcomes, where both are fully satisfied [65].

Decision makers cannot dismiss this reality especially in the context of climate change and a growing human population [60]. Unilateral marine management policies that force greater reliance – and biodiversity impacts – on distant ecosystems call into question their global effectiveness and conservation ethicality.

Rothman [31] questioned whether wealthy nations were merely “passing the buck” when distancing themselves from the environmental degradation associated with their consumption habits. The full impact of U.S. seafood consumption patterns needs to be considered at the global level in light of continuing efforts to further marine biodiversity protections. Failing to do so only serves to counteract the effectiveness of domestic actions by externalizing negative environmental costs to others.

Tenders invited for Capitalisation of Vessel Day Scheme Effort Study for PNA by Francisco Blaha

PNA is inviting for tenders of Consultants to conduct a Study to provide preliminary advice to VDS participants on the feasibility and the potential benefits and costs of transforming the value of VDS PAEs into capital assets for the purpose of improving access to development finance.

Fishing rights have value.  Private rights holders in several countries, including Iceland, Chile, Peru, Namibia, New Zealand and Russia are known to have been able to capitalise this value of rights in ways that have increased the willingness of banks to finance ventures associated with the rights or increased the price that buyers might pay for the business.  

Some VDS participants have taken the capitalisation process a step further and have used the value of VDS days made available for a venture as their contribution towards the equity of joint ventures.  In this way, they have ended up as part owners of a vessel or vessel-owning venture through contributing only the value of VDS access without contributing cash or other assets.

The primary objective of the Study is to provide preliminary advice to VDS participants on the feasibility and the potential benefits and costs of transforming the value of VDS PAEs into capital assets for the purpose of improving access to development finance.

As part of this work, the Study is also aimed at:

  1. establishing the value of VDS PAEs for the purposes of measuring the effectiveness of the VDS over time and benchmarking the effect of proposed changes to the VDS; as well as establishing a basis for counting PAEs as assets of VDS participating governments, including for the purpose of the operation of a capital market for PAE; and
  2. providing advice on including the value of PAEs as assets in the public accounts of VDS participating governments for the purposes of making governments and communities aware of the value of their PAE and their tuna resources and how that value changes over time and is affected by the management and operation of the VDS; as well as strengthening the financial position of VDS participating governments.

The full details of this opportunity are at the following link 

The use of life cycle assessment (LCA) in fisheries by Francisco Blaha

My views on ecolabelling are not new, and a recent experience with a leading ecolabel assessment I did, leaves me with an “incomplete” feeling, particularly regarding vessels compliance history and flag state performance. On that frame, my friend Elsie sent this blog by Teressa Pucylowski that added an interesting twist.

Jameel, F., Daystar, J., & Venditti, R. A. (N.d). Environmental life cycle assessment

Jameel, F., Daystar, J., & Venditti, R. A. (N.d). Environmental life cycle assessment

I quote here from her thought-provoking blog:

Many concerns regarding seafood harvest are often overlooked. For instance, how much fuel do fishing boats use or how much feed was used to produce farmed salmon? Life cycle assessment has shown these two factors are the largest contributors to greenhouse gas emissions from wild and farmed fish, respectively (2). Such information is rarely considered by current sustainable seafood sustainability labels or consumption advisories.
LCA can account for more than just greenhouse gas emissions. In fact, this method allows consideration of other broad but significant environmental impacts that are often overlooked in other methods—including toxic emissions released by food production systems such as antibiotics and pesticides, and the use of limited resources such as freshwater and oil.
Life cycle assessment is not a new methodology – it was originally designed to follow a given product from “cradle-to-grave”, beginning with the assemblage of raw materials and resources used for its production and ending with its disposal, thus giving it a holistic analysis [3, 4]. To put this into a seafood perspective: you could, for example, follow the production of one ton of live lobster starting with trap setting and bait selection, continuing through the supply chain, and ending with the lobster served on your dinner plate [5]. As one study mentioned “not even certification, which assesses products, takes a product perspective”; in other words, programs like MSC do not look at the full environmental consequences of actually processing a product [2].
LCA can also be broken down into subsystems like “feed production” or “transport”, identifying all inputs (e.g. electricity use) and outputs (e.g. emissions) within the system. Thus allowing identification of stages within the system with the highest environmental impact [3]. Importantly, this is a standardised method so that impacts can be quantitatively compared between products [2].
With a growing number of LCA studies focused on seafood we are continuing to gain new insights into our current understanding of sustainability. For example, the amount of fuel used to harvest an overfished stock is significantly greater than that for an abundant stock due to the extended amount of time needed to find enough fish. The type of gear used to catch fish can also make a notable difference in fuel use, e.g. using seine nets to collect tuna is three to four times more energy efficient than hook-and-line methods. Even the energy source itself is an important thing to consider, i.e. whether it comes from fossil fuels or renewables. LCA is useful in that it actually takes into account all of these considerations, thus amplifying our understanding of the environmental impacts of seafood production [2].
Unfortunately, none of the above-mentioned methods adequately address social issues. However, as awareness of inequity and social injustices relating to the seafood industry rises, there is increased pressure to include these elements in sustainability assessments. In recent years, efforts to include social and economic implications have been developed within LCA studies, although there is much progress yet to be made.
The bottom line is that there is a lot to think about when choosing what fish to buy. The number of factors to consider can be overwhelming, but it is important to be aware of the various contemplations. With all this contrasting information, it may also seem nearly impossible to pick a truly sustainable seafood option. You may decide to go with values that matter most to you. Are you mostly concerned with climate change and carbon emissions? Are you worried about chemical use and potential effects on human health? Perhaps high rates of bycatch are the most troublesome to you. Regardless, LCA can help make this information available for consumers to make their own educated choices.

I discussed before the question of When a fishery is sustainable? and of course there are not easy answers. But my gut feeling is that at this stage, true sustainability is long gone. Furthermore, as I expressed before, it would be imposible for science, policy and MCS to tell you what environmental impacts are low enough – that is a question of individual choice and public policy via political pressure.

And I know this will sound terrible, but the only guaranteed way to have no impact on our environment is for all of us (humanity) to disappear (fast and at once). All other options imply compromises


[1] Pelletier, N., & Tyedmers, P. (2008). Life cycle considerations for improving sustainability assessments in seafood awareness campaigns. Environmental Management, 42(5), 918-931.
[2] Ziegler, F., Hornborg, S., Green, B. S., Eigaard, O. R., Farmery, A. K., Hammar, L., … & Vázquez‐Rowe, I. (2016). Expanding the concept of sustainable seafood using Life Cycle Assessment. Fish and Fisheries.
[3] Baumann, H., & Tillman, A. (2004). LCA in a nutshell. In The hitch hiker’s guide to LCA: An orientation in life cycle assessment methodology and application (pp.19-41). Lund, Sweden: Studentlitteratur AB.
[4] Pelletier, N. L., Ayer, N. W., Tyedmers, P. H., Kruse, S. A., Flysjo, A., Robillard, G., Ziegler, F., Scholz, A. J., & Sonesson, U. (2007). Impact categories for life cycle assessment research of seafood production systems: review and prospectus. The International Journal of Life Cycle Assessment, 12(6), 414-421.
[5] Driscoll, J., Boyd, C., & Tyedmers, P. (2015). Life cycle assessment of the Maine and southwest Nova Scotia lobster industries. Fisheries Research,172, 385-400.