Review of the use of Manual Reporting when VMS "Malfunction" / by Francisco Blaha

I'm always enticed by jobs that take you into "uncharted" waters. Here is one by my colleagues at FFA. They are calling for tender from consultants to review the use (or abuse) of manual reports of the vessels positions of in the case of VMS "malfunctions". 

 giving less options could be a good start

giving less options could be a good start

The aim of the contract is to conduct an independent analysis and assessment in two areas:

  1. providing an outline of the limitations of VMS manual reporting in order to facilitate improvements and developments to this process, both nationally and regionally amongst FFA Members; and
  2. proposing recommendations to address the limitations of VMS manual reporting, looking at potential technical, operational, and regulatory improvements or developments.

The issue is worrying one, the most recent version (2014) of the FFA Harmonised Minimum Terms and Conditions (HMTCs), which describes the rights and obligations of all vessels licensed to fish in the FFA region as a matter of “good standing” and includes requirements to carry VMS.

The HMTCs allow for a vessel to manually report its position at intervals of 4 hours or such shorter period as specified by the delegated authority. Additionally, under the criteria for withdrawal or suspension of a good standing designation, the HMTCs address the failure to provide manual reports when so directed by the delegated FFA member authority in the event of an ALC/MTU breakdown.

The use of VMS has proven a critical tool in not only detecting and deterring IUU fishing, but also for securing fundamental fisheries management information. However, MCS practitioners have noted that manual reporting represents a significant loophole in MCS efforts because, in its current form, it effectively allows for vessels to stay out at sea, unmonitored, for up to 45 days.

Pew Environment Group recently highlighted that 100 fishing and carrier vessels provided a total of 2,044 manual reports in just the first eight months of 2014 on the basis that their VMS unit malfunctioned or failed. Those manual reports, assuming a reporting rate of every 6 hours, amount to roughly 511 days where those vessels were effectively invisible. With fisheries observer coverage at less than 5 % of fishing effort for a number of fleets, that vessel time is almost completely unverifiable.

Furthermore, VMS equipment and service providers note that these failure rates are much higher than would be expected under normal operation, suggesting that operators are selectively turning off their units to evade detection.

In addition, regional and national capacity to utilize manual reports (data collection and entering) is also insufficient, further weakening vessel location verification and national and regional MCS capabilities.

Thus, given the potential abuse and under utilization of manual reporting and the importance of VMS to both fisheries management and MCS applications, in addition to a pending review of the requirements for manual reporting by the WCPFC in 2017, an analysis of the use of manual reports is both relevant and timely. FFA has partnered with WWF – New Zealand to provide resources for this consulting role.

So If anyone out there, is a VMS technical guru and wants to partner with someone with local knowledge and access to information for this really interesting job... just let me know :-)