Towards the Quantification of IUU Fishing in the Pacific Islands Region / by Francisco Blaha

FFA presented a big study (almost 2 years in the making) yesterday in Auckland. Is in many aspects a landmark work. I tender for that same study with a team when it was advertised, obviously we weren't successful, but noblesse oblige I have no issues to admit it is a solid piece of work by MRAG.

On one side it does not tell us nothing we didn't knew or suspect already, but it provides two solid tools: a methodology to follow in future studies and a specific quantification for the tuna fisheries in the pacific.

The study set a baseline for the scale, composition and quantified value on IUU fishing and what it is costing this region, against which future success can be measured. It will also help to provide a clearer basis to assess what is working and what needs reworking to ensure that collective regional efforts are targeted toward the most prevalent and costly forms of IUU in the evolving Pacific tuna fishery.

In many ways is a positive report, that provides a clearer sense of what the main IUU risks are, what is working, and what needs additional priority. So I was dismay for the complete negative twist that most news organizations put on it.

All estimations where presented in a lower end, upper end and best estimate, and of course this guys quoted the upper (worst case scenario) end. The risk scenarios that were presented for evaluation where quotedas the prevalent scenarios. Very disappointing coverage… No one ever says that there are no problems, but there are positive steps being made… and now we have well studied grounds to know where the limited resources we have need to go.

The biggest area of IUU activity is the Distant Water Fishing Nations (DWFN) longliners operating in the high seas (international waters) this fishery is “administered” by the Western and Central Pacific Fisheries Commission (WCPFC) but because is in international waters, the vessels fishing there are only under the “control” of the respective flag states (read China, Taiwan, Korea, Japan) which in principle don't give a shit for regulatory compliance.  And due to the structure of the WCPFC, is not much anyone else can do.

My friend and former boss Hugh Walton (uncle Hugh to my kids), FFA’s project manager for the EU-funded DEVFISH II programme, which coordinated the study, is on the spot when he points out that the study will allow discussion on mitigation measures “because we already know what they are but we don’t have the ammunition for them”.

“We’re hoping that this report will give us the ammunition, say management measures in the WCPFC sense, then for us at the regional level in terms on how we focus our MCS activities and then at the national level, in terms of our national level MCS activities, how they are focused.”

He cited as an example one of the MCS tools currently being discussed, e-monitoring and e-reporting in terms of the “U” for unreported. “When you look at the e-monitoring and e-reporting tools in terms of the unreported, the camera doesn’t lie. In the trials we’ve done, we have done enough to know that the camera doesn’t lie”

But still, is very hard to do much unless China and Taiwan play their part, and as we see from the news today, Chinese vessels are not always cooperating.

In any case, I quote here the executive summary of the report, and hopefully over time will be going over it with some more detail. And here is the link to download it.

This is the first attempt made to quantify the volume, species composition and value of IUU fishing in Pacific tuna fisheries specifically.  We used a ‘bottom up’ approach which aimed to quantify the level of IUU fishing associated with 11 main risks across four risk categories:

(i) unlicensed/unauthorised fishing, (ii) misreporting, (iii) non-compliance with other license conditions (e.g. FAD fishing during the purse seine closure period) and (iv) post-harvest risks (e.g. illegal transshipping).  Estimates of IUU volume and value were developed for each of the three main fishing sectors - purse seine (PS), tropical longline (TLL) and southern longline (SLL) – and then aggregated to produce an overall estimate for Pacific Islands region tuna fisheries.  Data was used for the period 2010 to 2015.

The approach took account of all of the available information to generate ‘best estimate’ values of IUU activity for each risk in each sector, as well as minimum and maximum range values.  We then used Monte Carlo simulation to account for uncertainty in the underlying information and produce probabilistic estimates of IUU activity.  The level of information available to support estimates of different IUU risks varied considerably between sectors and between risks.  For a small number of risks good quantitative information was available. However, for the majority of risks the level of information available was very limited, reflecting the secretive nature of IUU fishing.  

A key output of the project has been the development of a framework for the quantification of IUU fishing in Pacific tuna fisheries and the design of a basic model that can be refined and updated over time as IUU risks change and better information becomes available. Given the limitations in the information available to quantify many of the risks, the outputs of this work should be seen as a ‘first cut’.  Recommendations to strengthen the availability of information have been made and we would encourage the exercise to be repeated on a regular basis to track trends in IUU fishing activity and help target MCS efforts.

Our simulations suggest the best estimate total volume of product either harvested or transhipped involving IUU activity in Pacific tuna fisheries is 306,440t, with 90% confidence that the actual figure lies within a range of 276,546t to 338,475t.  Based on the expected species composition and markets, the ex-vessel value of the best estimate figure is $616.11m.  The 90% confidence range is between $517.91m and $740.17m.  That is, there is a 95% chance the figure is greater than $517.91m and a 5% chance the figure is greater than $740.17m.

Of the three main sectors assessed, estimated volume of IUU product was highest in the purse seine fishery, accounting for 70% of overall volume.  Estimated IUU volumes in this sector were largely driven by reporting violations and illegal FAD fishing during the closure period.  The TLL and SLL sectors accounted for 19% and 11% of the overall volume respectively.  In the TLL sector, IUU volumes were largely driven by misreporting (49% of total TLL volume) and post-harvest risks (39%), principally illegal transhipping.  Estimates of both misreporting and illegal transhipping were, in turn, influenced by high levels of uncertainty.  Similar results were achieved in the SLL sector, with misreporting and post-harvest risks accounting for 57% and 36% of overall estimated IUU volume respectively.

By contrast, the TLL sector accounted for the highest ex-vessel value of IUU product ($272.55m) given the higher market value of its target species.    This sector accounted for around 44% of overall estimated IUU value, while the purse seine sector accounted for 37%.  The SLL sector had the lowest overall estimates of IUU product value (19%).

Of the four main IUU risk categories assessed, reporting violations and non-compliance with other license conditions (e.g. illegal FAD fishing; use of non-prescribed gear) accounted for 54% and 29% of the total estimated IUU volume respectively.  Post-harvest risks (mainly illegal transhipping) accounted for 13% of the estimated volume but 27% of the estimated value.  This was driven by higher estimates of illegal transhipping in the longline sectors which receive proportionally higher prices for product.  Unlicensed fishing accounted for only 4% of the estimated overall volume.

Among the main target species, skipjack accounted for the largest proportion of total estimated IUU volume (33%), but a lesser proportion of the total estimated ex-vessel value (18%).  The total estimated IUU volume of SKJ (100,730t) equated to around 5.1% of estimated total SKJ catch in the WCP-CA in 2014.   Yellowfin accounted for the next highest volume (96,126t), making up 31% of the total estimated IUU volume, and 27% of the ex-vessel value.   The total estimated IUU volume of YFT equated to around 15.8% of the estimated total catch of YFT in the WCP-CA during 2014.  Much of this is driven by estimates of misreporting in the purse seine fishery which is subject to 100% observer coverage, and therefore may result in little unaccounted for catch.  Bigeye also accounted for 19% of the overall estimated IUU volume, but 28% of the ex-vessel value.  The total estimated IUU volume of BET equates to around 35% of the estimated total catch of BET in the WCP-CA in 2014.  Importantly, this does not necessarily mean that 35% of additional BET have been taken in addition to reported figures.  For example, a substantial proportion of the overall IUU BET estimates come from estimates of illegal transhipping, the product for which may still be reported in logsheets.  ALB accounted for 4% of the overall estimated IUU volume and 6% of the total ex-vessel IUU value.  The total estimated ALB IUU volume equates to around 9.4% of the estimated total ALB catch in the WCP-CA in 2014, although a substantial proportion of this related to post-harvest offences for which information was uncertain.

Apart from the headline volume and value figures, there are a number of key messages arising from the analysis:

  • The estimates of IUU volume and value generated here are lower than most commonly quoted estimate of IUU fishing in the WCPO region ($707m – $1.557b), although these studies are not ‘apples Vs apples’ comparisons.  The previous study (Agnew et al, 2009) used a ‘top down’ approach that looked at IUU fishing across a suite of species wider than tuna (e.g. demersal fish, shrimp) as well as including parts of Indonesia and the Philippines (across FAO Area 71). Relatively high levels of IUU fishing in coastal states on the western Pacific seaboard influenced the overall results; 
  • Estimates of IUU are dominated by the licensed fleet - assuming catch transhipped illegally is taken by licensed vessels, IUU fishing by the licensed fleet accounts for over 95% of the total volume and value of IUU activity estimated here. This proportion rises to 97% if unlicensed fishing by vessels that are otherwise authorised to fish in the Pacific Islands region (i.e. they are on the FFA RR or WCPFC RFV) are considered part of the ‘licensed’ fleet.  This is consistent with previous studies and has important implications for MCS planning and investment;
  •  Ex-vessel value is not a good indicator of actual loss to FFA members – this is because the full value of the catch is not returned to coastal states under normal circumstances (only a proportion of total revenue is, typically through access fees) and because of their nature, some risks may not necessarily result in direct losses.  In general, a better measure of the actual impact on coastal states is likely to be the economic rent lost as a result of IUU activity.  Based on the most recent estimates of profitability in the WCPO purse seine and longline sectors, we estimate the rent associated with IUU product estimated here is around $152.67m.  Nevertheless, because of the nature of access arrangements in Pacific tuna fisheries, it is possible that much of the rent associated with IUU activity is captured anyway, and this estimate either overstates, or is at least at the upper end of, actual impacts on the real economy.  For example, in the purse seine fishery, there is a good argument that the competitive nature of the bidding process under the VDS means that rents generated through IUU activity would be captured in the prices that fishing companies are prepared to pay for fishing days and are therefore not lost to Pacific Island countries.  This is perhaps less the case for the longline sectors where current access arrangements are probably less efficient at capturing rent;
  • Stronger catch monitoring arrangements are required in the longline sector – mechanisms to independently verify catch in the longline sectors are limited for many fleets.  Additional measures are required to strengthen confidence in catch reporting and compliance with catch-based CMMs and generate better estimates of IUU activity;
  • "IUU’ is not straightforward – while the IPOA-IUU definition of IUU is clear in theory, applying it for the purposes of quantification is not always straightforward.  Interpretations on what is, and is not, considered IUU for the purposes of quantification can substantially influence results;
  • More accurate estimates of IUU activity require stronger monitoring and coordination of relevant statistics – the information available to support quantification of many risks was relatively limited and largely confined to expert judgement.  Achieving more accurate estimates of IUU activity will require stronger monitoring and analysis, and the coordination of relevant statistics.  While in some cases, this may require ‘new’ initiatives, in many cases it will simply require more effective use of existing facilities;  
  • Strong in zone MCS arrangements must be mirrored on the high seas – the outcomes of this study argue for stronger monitoring of catch and transhipment activity across all sectors, and in particular the longline sectors.  Given the shared nature of stocks in the region, stronger MCS arrangements in zone should be mirrored on the high seas;
  • Future IUU risks – the nature of IUU fishing is dynamic and influenced by the mix of incentives and disincentives, as well as changes in the regulatory environment.  Future iterations of the IUU model developed here will need to take changes in the nature of IUU fishing into account.  

Considerable efforts have been taken at the national, sub-regional (FFA/SPC/PNA) and regional levels (WCPFC) to mitigate IUU fishing in Pacific tuna fisheries.  Many of these are likely to have been highly effective at achieving their intended purpose (e.g. the FFA and WCPFC VMS, the FFA Regional Register, the FFA Harmonised Minimum Terms and Conditions for Foreign Fishing Access, the Pacific Patrol Boat Program, Niue Treaty, 100% observer coverage on the PS fleet) and will have contributed to the relatively low estimates of IUU fishing across a number of sector/categories.  Nevertheless, the results of this study indicate that substantial uncertainty still exists in relation to IUU activity across a range of key risks, and additional measures are required to strengthen incentives for voluntary compliance, reinforce deterrents to non-compliance and improve monitoring throughout the supply chain.

Ultimately the most practical mix of MCS arrangements to deal with IUU fishing will be a function of the balance between the likely effectiveness of the measure in treating priority risks, practicality of implementation and overall costs.   An outline and discussion of possible additional MCS measures that can be taken to further mitigate IUU fishing in WCPO tuna fisheries is provided, taking into account risks targeted, costs and practicality.  Key priorities identified in the longline sectors are to:

  • Strengthen mechanisms for independent monitoring of catch through the supply chain;
  • Strengthen transhipment monitoring and control;
  • Strengthen on-board monitoring of fishing activity through improved observer coverage and the introduction of electronic monitoring technology.

In the purse seine sector, MCS arrangements are generally stronger than the longline sector, though based on the current management of the fishery priorities include:

  • Strengthening mechanisms to verify fishing activity (e.g. to assess non-fishing day claims; FAD fishing during the closure);
  • Catch verification through the use of cannery data;
  • Better monitoring and management of FAD usage.


And above all this, a solid Catch Documentation Scheme (CDS) for the WCPFC, could help tie all the loose ends and hopefully disincentive the buying of fish that has not been officially certified as legal. and that CDS is what I'm working over the next years.