Review of studies estimating levels of IUU fishing / by Francisco Blaha

In February 2015 FAO convened a workshop to consider methodologies for estimating IUU fishing at the global level. The premise underlying this workshop was that a new global estimate of IUU catch would be useful, as the 2009 paper estimating IUU-caught fish is now outdated both in terms of the 2003 estimate it provided and in terms of the changed international, regional and national context now influencing levels of IUU fishing. Concern has also been expressed over the wide range between the upper and lower estimates in the study, and over some of the methodological aspects and particularly the raising factors used to generate the global estimate

The workshop suggested that FAO could: (i) coordinate a ‘Study of IUU fishing studies’ to review the different methodologies being used to estimate IUU fishing; (ii) lead a process to develop technical guidelines for future studies so they could be conducted in a way that would allow for estimates to be combined to contribute to a global estimate; and (iii) consider indicators of IUU fishing for inclusion in FAO’s bi-annual SOFIA publication.

The resulting "study of studies", just completed by my colleagues Graeme Macfadyen from Poseidon Consultants, G. Caillart(don't know him) and David Agnew (that somehow finds time to do this type of work besides his responsibilities as MSC) is quite substantial and a necessary read, I just quote a summary.

Thefound that studies to estimate IUU catches range in geographical scope from those concentrating at very local levels, through national and regional studies, to those attempting to estimate IUU catch at a global level.

The sub-global estimates cannot be combined to generate a global estimate as they do not cover all fisheries or ocean areas, tend to focus on marine industrial IUU fishing (and often of foreign fleets), in some cases overlap in geographical coverage (but with different estimates of IUU catch being produced), and use different methodologies which are not comparable.

With respect to a number of studies providing global estimates, these tend to have especially high levels of uncertainty over the estimates produced, because as the scale of these studies increases, they either lose accuracy or lose granularity because of the assumptions that they have to make for elements for which there are no data.

A number of global (or regional) studies estimate ‘missing or unknown catch’ rather than catch that is specifically IUU. This is important as such studies have a limited biological focus/objective, which while of benefit, fails to recognize that IUU fishing is also an economic and social problem, with economic and social impacts not just biological ones in terms of impacts on fish stocks and the reliability of stock assessments based on known catches.

The inclusion of different aspects of illegal, unreported and unregulated fishing in the estimates are not consistent, nor is the definition of IUU fishing in the IPOA-IUU consistently applied. The studies demonstrate considerable confusion about what illegal catch is, what unreported catch is, and what unregulated catch is, often grouping unknown catches under a single IUU umbrella.

The studies use a wide range of different sources of information including: surveillance data and compliance levels; remote sensing (e.g. VMS, AIS); logbooks; expert judgment based on experience; interviews with fishermen and enforcement agencies; observer data; onboard cameras; stock assessment models; and trade data. These sources of information have different uses in terms of different methodologies used to generate estimates of different aspects of illegal, unreported, and unregulated fishing activity, for example of unknown IUU catch for known vessels, of unknown catch of unknown/unseen vessels, or of catch volumes which are known but which might nevertheless be illegal.

The study of studies concluded that most of the methods used have limitations. For example, they may be very good at estimating all the unreported catch of a particular species, but less good at identifying where it came from or what types of IUU were being used. Or they may be very good at identifying specific violation types, but poor at estimating quantities. Or they may estimate IUU catch of target species but have no estimate of the impact of IUU fishing on other species.

The study of studies also found that many of the studies are insufficiently transparent about the sources of information and weaknesses in the methods used, and make a large number of assumptions which lead to inevitable questions over the accuracy of the estimates produced.

 Keep making pictures and I estimate you gonna get beaten very soon

Keep making pictures and I estimate you gonna get beaten very soon

Conclusions
The study of studies recognizes that there may be some political support for an updated global estimate of IUU catch, and for FAO to be involved in its preparation given FAO’s global mandate for fisheries. However it notes that the importance of combatting IUU fishing is now widely recognized at the global level suggesting that the advocacy benefits of a global estimate may be limited. Advocacy benefits may also be diminished due to wide confidence intervals and the likely inherent technical weaknesses in the accuracy of any global estimate; from a technical perspective a global estimate may serve little benefit and not be advisable.

The technical guidelines on methodologies for estimating (global) volumes of IUU catch suggested by the workshop in Rome in 2015 might nevertheless be useful in improving the quality of studies being completed at local, national or regional levels.

In terms of contributing towards efforts to combat IUU fishing and reduce levels of IUU catch, of potential benefit could be the development of technical guidelines on how to conduct risk-based assessments of IUU fishing. A number of frameworks for IUU risk assessments are being used by RFMOs and national administrations. But as the 5th GFTEW in Auckland observed in March 2016, there is currently no guidance on how to complete such assessments, and many developing and developed countries alike would benefit from technical guidance. The completion of IUU risk assessments could also, but need not necessarily, result in and be the basis for estimates of IUU catches and further consistent monitoring of evolution of IUU catches. The first step in developing such technical guidelines would be the preparation of an inventory and review of all existing risk assessment frameworks in use.

Indicators of IUU fishing to monitor progress in combatting IUU fishing are critically important but from a technical perspective need not include a global estimate of IUU catch as levels of accuracy and large differences between upper and lower estimates would mean that it would be difficult to statistically demonstrate any difference between global estimates prepared at different intervals.

The problem of comparison would be compounded if methodologies were changed or improved between global estimates prepared at intervals. Indicators could thus focus on other aspects such as numbers of vessels on IUU fishing vessel lists, number of countries issued with ‘yellow’ and ‘red cards’ under the EU IUU regulation, the outputs of IUU risk-based assessments, and perhaps some specific regional or local estimates of IUU catch in high risk areas based on repeatable and robust methodologies. However more consideration needs to be given as to whether it is advisable to have a single indicator of IUU fishing, or whether a ‘suite’ of indicators might be more beneficial and if so what should be included.

Recommendations to COFI
Noting that COFI has not earlier endorsed the suggestions of the 2015 Rome workshop, the findings of the study of IUU studies, or the deliberations of the 5th GFETW, the study of studies recommends that COFI consider and advise FAO on whether:

  1. an updated global estimate of IUU catch is desirable and if so what would be its objective and what role FAO should have in supporting/developing such an estimate.
  2. FAO should lead a process to develop technical guidelines to improve the quality of studies completed at local, national and regional (and potentially global) levels to estimate IUU catch, and whether such guidelines should revisit the IPOA-IUU definitions, not necessarily departing from them but identifying separate categories of IUU that should be considered in risk assessments and monitoring studies that are more attuned to current experience and practices.
  3. FAO should support the development of technical guidelines on conducting IUU risk-based assessments.
  4. reporting globally on indicators of IUU fishing would be beneficial, and if so what the process should be for proposing, agreeing and reporting on such indicators, and what role FAO should play in such a process.